United States
             Environmental Protection
             Agency
                          Office of Policy
                          Planning and Evaluation
                          Washington DC 20460
EPA 230-09 88-037
September 1988
s>EPA
             Municipalities, Small
             Business, and Agriculture

             The Challenge of Meeting
             Environmental
             Responsibilities
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     MUNICIPALITIES,  SMALL BUSINESS,  AND AGRICULTURE:

THE CHALLENGE OF MEETING ENVIRONMENTAL RESPONSIBILITIES
                   REPORT TO LEE M. THOMAS
                   Sector Study Steering Committee
                          Rebecca Hanmer
                             Don Clay
                           Victor Kimm
                           Louise Jacobs
                          Thomas Devine
                          Gerald Yamada
                          Alexandra Smith
                       Robert Wayland (Chair)
                         SEPTEMBER 1988

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                Report Prepared By:
          ECONOMIC STUDIES BRANCH

OFFICE OF POLICY, PLANNING AND EVALUATION
               Workgroup Participants

                 Allen Basala (Air)
             Allen Jennings (Pesticides)
            Karen Klima (Surface Water)
            A.  W. Marks (Drinking Water)
          Elizabeth LaPointe (Solid Waste)
         Michael Shapiro (Toxic Substances)
            Ralph Luken (Policy) (Chair)

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                                 CONTENTS
                                                                         Page
            EXECUTIVE SUMMARY	i


Chapter 1    INTRODUCTION	1-1

            The Changing Nature of Environmental Regulations	1-1
            The Need for Broader Analyses	1-3
            The Sector Studies	1-3


Chapter 2   MUNICIPALITIES	2-1

            Municipalities and Environmental Regulations	2-2
            Study Methodology and Limitations	2-6
            The Impact of Environmental Regulations	2-11
            Conclusion	2-19


Chapter 3   SMALL BUSINESS	3-1

            Small Business and Environmental Regulations	3-1
            Study Methodology and Limitations	3-4
            Impacts Upon Selected Industries	3-6
             Conclusion	3-16


Chapter 4    AGRICULTURE	4-1

             Agriculture and Environmental Regulations	4-2
             Study Methodology and Limitations	4-3
             Impacts on  Livestock and Major Field Crops	-  ...  4-8
             Impacts on  Specialty ,Crops.	4-12
             Conclusion	4-15


Chapter 5    POLICY CONSIDERATIONS	5-1

             Municipalities.	5-1
             Small Business	5-5
             Agriculture	5-8
 Appendix    Environmental Regulations Included in the Sector Studies

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                            EXECUTIVE SUMMARY
     Over  the  years, the U.S. Environmental Protection Agency's (EPA) mission  has
broadened  considerably, and so has its reach into society.   New regulations of toxic
materials, hazardous substances, and solid wastes will affect hundreds of thousands of
farms and small businesses, and new drinking water regulations will affect tens of
thousands  of  small municipalities.  This  report  summarizes  the  findings  of three
studies  designed  to  take  a first  look at  the combined  impacts  of  EPA's  new
regulations upon municipalities, small business, and agriculture.

     The  sector   studies  examined   85  recent   and  forthcoming   environmental
regulations that have the potential for large and far reaching  impacts.  The costs of
existing  environmental regulations and  all other government programs were  assumed
to remain constant over the study  period.  Although the regulations included in these
studies will lead to improvements in environmental quality, the sector studies do  not
assess the benefits that will accrue to the  municipal, small business,  and agricultural
sectors.

      Because  the  sector  studies were meant to  be initial efforts, they are subject to
a  number  of  qualifications.  For  example: (1)  each study limits the range of its
analysis  by selecting a sample of sources, and (2) the costs and even the final forms
of many of the regulations studied are  not yet certain.  In spite of these limitations,
the  sector studies  provide an  initial reading  of the potential  impacts of the  new
environmental  programs  and  suggest  several  potential policy initiatives that   may
prove useful.
MUNICIPALITIES
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     Recent revisions  to  environmental legislation have  established  a broader  and
more stringent  set  of  standards to be  met by  municipalities.   Meeting these new
standards  will  require additional  investments  in capital, and increases  in  rates
charged to customers for improved environmental  services.

     The potential cumulative cost  of  the environmental regulations examined in the
municipal  sector  study may require  that  the  national  average household spend an
additional $100 per year by  1996.  Both municipalities under 2,500 persons  and over
250,000 persons  will experience  the largest average increases  in  total user charges
and fees  paid on a  per household  basis, with potential  average  annual increases in
user charges and  fees of $170 and  $160, respectively.  Because  smaller municipalities
tend  to  have lower  average household incomes  and higher unit costs  for improved
environmental services, however, households in communities under 2,500 persons  will
be  required to pay a greater proportion (0.7%) of their income, on average,  for  these
services than will households in larger cities (0.5%).

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     Most municipalities will be able to meet the expected increases in environmental
expenses and still  remain  financially  sound.   The  municipalities  most likely  to
experience  difficulty will  be those with populations of 2,500 or less.   Between 21%
and 30% of these communities may have difficulty because of the high cost  of some
individual regulations, the cumulative costs of recent legislative requirements, and the
limited margin  for expanding  financial obligations  in small  communities due  to
existing  demands  for  environmental  and  other  infrastructure  services.    These
difficulties  are  not  limited to small  cities, but  the  results  suggest  that  a  much
smaller proportion (between  3% and  7%) of the cities  over  2,500  persons will face
financial constraints when subject to additional EPA requirements.

     The individual environmental regulations that account for the largest potential
increases  in expenses  in  small  communities are  the  drinking water  and  sewage
treatment requirements.   Several of the more costly drinking water regulations will
apply  to a  greater proportion  of smaller municipalities than  larger  municipalities.
These  regulations  do  not  single  out smaller municipalities  per se, but  instead deal
with environmental risks that are present at smaller community water systems.  Many
larger  water supply  systems already  have  introduced  treatment systems capable of
handling some of these  risks.  The costs of solid waste disposal, asbestos removal in
schools, and underground  storage tank  regulations, when totalled, also account for a
significant portion of the costs borne by smaller communities.
SMALL BUSINESS

      Although it might seem  that EPA's 85 regulations would overwhelm any small
business,  the actual impacts will vary  greatly.   Most  small  businesses will not  be
affected directly by any of  the 85 regulations. Some firms will be affected adversely
by the regulations, but others  -- particularly those that provide pollution control
products  or services  -- will  find  that  their businesses grow.   Thus,  the overall
impact of EPA's forthcoming regulations is by no means self-evident.

      An examination  of statistics provided by the  U.S. Small Business Administration
(SBA) reveals that  seventy percent of the 3.5  million small businesses in the United
States are in sectors of the economy that produce little or  no pollution — wholesale
and retail trade, finance, and services.   Most of  these businesses  will not be affected
directly   by  any  of  the  85  regulations.    Small  businesses  that contribute  to
environmental problems will  incur  additional costs  to  comply with  the regulations,
however, and in some industries the costs may be  high.

      The small  business sector study examined the impacts  on small businesses  in
nine industries  judged  likely  to be adversely affected  by several environmental
regulations.  The study found that costs may be  high for  small businesses in three of
the  industries  --  electroplating,  wood  preserving,  and  pesticide formulating and
packaging.   If  costs  prove  to be as high  as  estimated and cannot  be  passed  on to
consumers,  some  small businesses in these industries may  be forced to discontinue
part of their operations or  to close.  Some small dry cleaners that have underground
storage tanks  or  require substantial  perchloroethylene emissions controls may also
have difficulty meeting environmental requirements.  In addition, certain gas stations,
trucking  firms, and farm supply stores  with leaking underground storage tanks may
face corrective action costs  beyond their financial  means.  Small  private water supply

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companies  are  in  a unique  position,  in  that they  operate as utilities  and generally
obtain rate increases to cover  increased  costs.    While  these  firms would not  be
expected to go out of business, high environmental costs for water supply companies
that fail to meet new drinking water  standards  may  necessitate  large  increases in
household  usage  fees.   Environmental  costs  for one of  the industries  studied—
photofinishing  laboratories — were found to be negligible.

     The regulations that appear to be most often responsible  for high  costs in the
industries studied are those  covering  the handling and reporting of  toxic chemicals;
the handling,  treatment, and disposal  of hazardous  wastes;  and the  operation of
underground storage tanks.  Although cost estimates are available for only  some of
these  regulations,  those that are available indicate that the  regulations  will  affect a
large  number  of  firms  in  many industries  and  may  entail costs  in  the $5,000 to
$10,000 range.   Although these costs  may be managed easily by small  businesses of
moderate  size,  they  present  difficulties  for  businesses  with  fewer  than  twenty
employees.   It  is  these  very small  businesses  that  comprise  the  majority  of  U.S.
businesses.
AGRICULTURE

     The objective  of the agriculture sector study was to examine  the cumulative
effect of recent and proposed future EPA actions on the financial condition of farms
in the United  States.   Because of the complexity of the agricultural sector and the
many uncertainties  that still accompany  the new environmental  programs, this study
had  to  limit its  focus to  a few "representative" farm types and had to make many
assumptions  about  future  environmental requirements  and other  factors  that will
affect the financial condition  of  farms, such as farm  support  programs  under the
Food Security Act.

     For livestock and  major  field crops, three specific farm types  were examined:
(1)  an Illinois  corn soybean farm, (2) a  Mississippi cotton soybean farm, and  (3) a
Kansas  cattle  wheat  farm.   For specialty crops,  six  crops  were  selected:  apples,
tomatoes,  potatoes,  peas, caneberries  (e.g.,  raspberries,   blackberries,   etc.), and
peanuts.  There  proved to be  insufficient  information  to  complete the analysis for
caneberries and  peanuts,   however,  so that  results  are available  only  for  apples,
tomatoes, peas, and  potatoes.  The difficulty in obtaining information  about producers
of specialty crops was itself a significant  finding of the study.

     Three regulatory  scenarios  of  future  EPA  actions  were considered  in the
agriculture sector study,   ranging  from  a conservative (low cost)  scenario  to  an
expansive (high  cost) scenario.  In addition, two  alternative  levels  of  effects were
considered for each of  the farms  that were examined.   In  an  average impact case it
was assumed that the farm would  incur  the average environmental costs of all farms
of  that  type and in  a  maximum  impact case it was assumed that the farm  would
incur  all  of the environmental costs that a  farm of  that  type might  face.  The
maximum impact cases represent  very unlikely worst  cases,  but provide  an  upper
bound on the potential losses under each regulatory scenario.

      For the three  types  of major field crop and livestock farms examined in this
study, the effects of EPA actions on farms in different  financial conditions were
considered.  The loss  in  income  incurred  by farms in  average financial condition

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under  the  average impact case (average environmental costs)  was 3% or less under
each of  the  regulatory scenarios considered.   Losses  of  this  magnitude resulted  in
only very small changes  in these farms' debt to asset ratios (less  than  1%).   Under
the unlikely maximum impact cases, farms in average financial condition experienced
substantial losses in income, but were not forced out of business as a result  of  EPA
actions.

     The major field crop and livestock farms  in  vulnerable condition  were  more
sensitive  to   increased  environmental  costs  than  their  counterparts  in  average
financial condition. Although  the absolute reduction in income was similar for farms
in  vulnerable  and  average financial condition under each  scenario,  these  losses
resulted  in much  larger changes in  the  vulnerable farms' debt to asset  ratios.   Even
though the vulnerable  farms'  financial  conditions were  found  to deteriorate  more
than the farms in average financial condition,  only one of  the vulnerable farms was
predicted to  go out of  business  during  the forecast  period  (1987-1996).   The  Kansas
wheat  cattle  farm  in  vulnerable  financial  condition  was  predicted to  go  out  of
business  even  without any environmental  costs  and  was  predicted to  go  out  of
business  one year earlier than  it otherwise would have under one of the regulatory
scenarios considered.

     Because of limited data availability, the study did not forecast losses in  income
or  changes in debt to asset ratios  for specialty crop  farms.   Instead, it examined
changes  in net returns  per acre (which reflect returns to land and farmer provided
labor).   Under the  least  costly  regulatory  scenario, the changes  were generally less
than 1% for  farms experiencing average environmental  costs  and less  than  8% for
even  the  maximally affected  farm.    Under  the most  costly  regulatory  scenario,
however,  losses  of   the  average   impacted   producers   increased  substantially,
particularly for apple producers in New York and Michigan,  where  predicted losses
were 60% and 84%, respectively.  These dramatic decreases in  net returns may bring
about  substantial  structural changes  in the  production  and  markets for the  crops
affected.  Large  differences  in the impact  of EPA regulations  on   crops grown in
different  regions   occurred  because  some  of  the  proposed  restrictions  involve
pesticides that are used in some regions and not in others.  Even though the results
of  this study must be  considered  preliminary, these figures show that EPA  actions
could  create economic  problems for some specialty crop  farms and suggest that the
Agency exercise caution in this area.
POLICY CONSIDERATIONS

     In response to the findings of these sector studies, several areas for potential
policy initiatives have been suggested.  While none  has  been endorsed by the Sector
Study  Steering  Committee,  they  are presented  to  illustrate  the kinds of  activities
that might be considered and to promote further discussion.

Municipalities

     A number  of activities have been implemented by EPA and other initiatives have
been  suggested  to  support  small  communities'   compliance  with  environmental
regulations.   These include establishing better lines of communication among  EPA,
community leaders, and  citizens, and  extending  technical  and financial  assistance
programs,  as well as several more innovative programs.  Public partnerships might be

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promoted,  for example,  to  allow  two  or  more  communities  to  share  expertise,
purchase services  and goods  in  larger volumes  for discounts, or to raise  capital in
larger, more  cost-effective blocks.   Regionalization is  a more structured form  of
partnership,  in which  two  or  more communities  create  a  joint  venture for  a
particular purpose, such as construction  of  a water supply system.   Privatization, in
which communities  work  with  private  companies  to  assist  in  the  provision  of
environmental services,  is  another  concept  that might  be promoted to  help reduce
costs.

     An important finding of the municipal sector study  is that not all  communities
are expected  to face financial difficulties.   This fact suggests that further  analysis
should  be conducted in order  to  identify the characteristics  of  small  and large
communities that  make  them  more likely to experience difficulty  in  financing  and
affording  new  environmental  protection.    If  EPA  can  better  identify  those
characteristics, then it can  improve upon its current efforts to design and  implement
programs that will be  of  greatest  benefit  to  those  communities  most in  need of
assistance.

Small Business

      Because  the  new environmental  programs cut across  many industries  and affect
thousands   of small  businesses,  new  compliance  strategies  may  be  needed  to
supplement EPA's  traditional enforcement efforts.   Many  policy initiatives  are
available to help small businesses learn about and comply with the new environmental
regulations.  These include educational programs, preparing  standardized responses to
paperwork  and other requirements, helping  to  expand environmental  services,  and
fostering new technologies.  All of these potential programs can be developed with
the cooperation of other government agencies and with industry trade associations.

      This study has highlighted  the value of detailed small  business analyses and the
importance of maintaining a current small business data base.  The Fin/Stat data
base  used in this study was compiled  by  the  SBA, but  was discontinued  in 1983.
Although slightly out of date, the data  enabled  the analysis to focus on the smallest
of businesses.  EPA  might consider working with  SBA  and other interested  agencies
to fund a  common  small  business  data base that could be  used  for all economic
analyses, particularly the  small business  analyses  required  under  the Regulatory
Flexibility Act.

Agriculture

      The agriculture sector study illustrates  the advantages  of examining the impacts
of environmental regulations  at the farm  level  as well as at the  aggregate  national
level.  While  national analyses provide useful information concerning the total losses
incurred by different aggregate types of farmers (e.g., corn farmers as a whole), the
impact  of environmental regulations on farms'  financial  conditions depends on the
distribution of those losses among farmers and  on the initial financial  conditions of
the  affected  farms.   In order  to  determine the effect of EPA regulations on the
ability of farms to survive, both aggregate and farm level analyses are necessary.

      This   study  highlights   the  data  and analytical   requirements  necessary  to
determine the impacts  of  EPA actions  on  agriculture.   Such requirements include

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accurate pesticide  usage  and efficacy  data,  improved  national  commodity  price-
quantity models, and better information on the  financial and production conditions of
farmers. The importance of using farm level models and improving data and modeling
capabilities  is likely to increase in the future as EPA tries to cost-effectively reduce
environmental risks associated with agriculture.
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                                   Chapter 1


                               INTRODUCTION
     Environmental  regulations touch all  sectors of society  -- agriculture, business,
government, and  individuals.   As these regulations  have evolved, their  impacts upon
society have evolved as well.

     When the U.S. Environmental  Protection Agency  (EPA) was  founded in 1970,
environmental regulation focused on the major  sources of air and water  pollution—
principally  the  "smokestack"  industries and  large  municipalities.   Over  the  years,
EPA's  mission has broadened  considerably, and so has its reach into society.   New
regulations  of  toxic materials, hazardous  substances, and  solid wastes  will affect
hundreds of thousands of municipalities, small businesses and farms, and new drinking
water  regulations will affect  tens of thousands of  municipalities  and  water supply
systems.

      This report summarizes  the findings of three studies designed to take a first
look at the combined impacts of EPA's new  regulations upon  municipalities, small
businesses,  and  agriculture.   Because the  scope  of  environmental  regulation  is
broadening  to affect these  sectors of  society  more  and  more,  the  Agency  has
commissioned these  studies  to  provide  an initial  assessment  of  what  economic
problems, if any, can be expected  to  arise and to suggest areas  for more detailed
study.
THE CHANGING NATURE OF ENVIRONMENTAL REGULATIONS

     In  1970,  the most  pressing environmental  problems seemed  obvious,  and the
perpetrators  easy to identify.   Soot  and smoke  from  automobiles  and smokestacks
were  fouling our air,  and sewage  and  wastewaters  from municipal  and industrial
outfalls  were  contaminating  our rivers and  streams.    Air and water  pollution
regulations  have done  a great deal  to  abate these more visible forms of pollution.
The air in most of our cities today  is far cleaner and healthier.  Thousands  of miles
of  rivers and streams, and  thousands  of  acres  of  lakes, have been restored for
fishing and swimming.  These accomplishments are especially  impressive when seen in
the context of the economic  expansion and population growth that occurred during
the same period.  There are  25 percent  more people  in the  United States now than
20 years ago, and our gross national product has increased by over 60 percent.

     But the job is far from finished.  As EPA is continuing  to implement traditional
environmental  programs,  it  also  is confronting  new  challenges.    Environmental
dangers  from the use of toxic substances and  the disposal of hazardous wastes are
now a major concern.   More  and  more contaminants  are being discovered in our
drinking  water, so that the Agency  is taking a  new look at drinking water standards
and is putting  in place programs  to  protect our  groundwater  from pesticides and
leaking underground storage tanks.

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     These new environmental  programs present regulatory  problems that in many
ways are similar to traditional pollution control programs.  As with existing air  and
water regulations,  the Agency must determine how stringent standards should  be  and
what  technologies  are available to  meet those  standards.   The  new programs  also
present  some new  challenges, however.  One of these  is assuring the compliance of
the ever-increasing number of smaller and smaller sources that  are  covered  by  the
new regulations.   Over  the  past  twenty years, the  Agency  has developed complex
permit programs that govern the discharge of contaminants by large facilities.  Now,
EPA must establish programs that govern the activities of hundreds of thousands of
small sources.

     Congress  recognized  the fact  that small  sources  were  an  important  future
challenge when it  amended the  Resource Conservation  and Recovery  Act (RCRA) in
1984 to include generators of relatively small  volumes of hazardous waste.   These
amendments extended RCRA's coverage from about  15,000 facilities  to over 200,000
facilities.

     The  underground   storage tank  (UST)  program  covers even  more facilities.
Literally millions  of  USTs are  located  throughout our country in every imaginable
setting.    Gasoline service  stations  operate about  half of these  USTs, but  the
remainder are  operated  by a diverse  community,  including trucking companies,  dry
cleaners, farm  supply   stores,  chemical companies,  local  and  state  governments,
military installations, and  airports. Altogether,  over  500,000 facilities are covered by
the UST regulations.

     The  new  environmental programs not only  bring many  new sources into the
regulated  community, but also  bring  many  new regulations  to bear  on sources  that
before  were  regulated  less  intensively.    Farmers, for  example,  once were  not
regulated  directly, but  were affected  by restrictions on which pesticides they could
use.  Now,  farmers not only are encountering more pesticide  restrictions, but  also
must  comply with new  regulations  covering surface water  runoff,  the storage  and
handling of  pesticides   and  other toxic substances,  and  the disposal  of hazardous
wastes.  There are  over 2,000,000 farms in the United States today.

     Municipalities provide an even more striking  example of the broad scope of the
new environmental programs.   There  are over  35,000  municipal governments  in the
United  States  that are covered by   EPA's regulations  and  many more  separate
government  jurisdictions,  including  water  supply  districts  and  school  systems.
Although  local governments provide a broad range  of services,  the  only  significant
environmental  regulations  that affected them in 1970 were those  pertaining to sewers
and wastewater treatment. Now, municipalities find  that several  of their services are
governed  by environmental  regulations.  Two  services commonly  provided by local
governments  -- waste disposal and drinking  water  supply ~ are  the primary focus of
new environmental programs.  In both of these areas,  programs encompassing several
new environmental regulations  are bringing about significant changes.  In addition,
municipalities are required to form local planning  committees to  coordinate plans for
dealing with  hazardous substance emergencies.   Even local school  systems,  hardly
considered polluters in  the conventional sense,  now find that they must comply  with
new regulatory programs covering asbestos and radon contamination.
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     In today's complex environmental setting, EPA's regulatory mission is governed
by major laws covering air and water pollution; radiation; the protection of drinking
water; the treatment, storage, and  disposal of hazardous wastes;  the  use of toxic
chemicals and pesticides; and the storage of substances in underground tanks.  Not
only do  EPA's environmental  regulations touch every sector  of American life,  but
each  sector  finds  itself   covered  by  several different kinds  of  environmental
regulations.
THE NEED FOR BROADER ANALYSES

     EPA has been  analyzing the impacts of its regulations since its inception, both
to provide information essential to fulfilling its statutory responsibilities and also to
comply with executive orders.  Each  of  the major environmental statutes designates
different factors that EPA must consider when establishing environmental regulations.
At the same time, EPA must provide regulatory analyses for review by the Office of
Management and Budget (OMB). Beginning with the "Quality  of  Life" reviews under
the Nixon Administration, the requirements for review by OMB have evolved from a
relatively simple analysis of costs to  the  comprehensive  benefit-cost analyses  required
for today's Regulatory Impact Analyses (RIAs).

     As  the analytic techniques and  data sources  available to EPA have improved,
the regulatory analyses performed as part  of  the rulemaking process have become
increasingly sophisticated.    Their  focus,  however,  has remained  on  individual
environmental regulations.  When one sector  of  society or one  industry is affected by
several environmental  regulations, each  analysis  of an  individual regulation paints
only  part of the  total  picture.  Recognizing this, EPA  from time  to  time has
examined  the  combined  impacts of  several existing regulations  on  a few major
industries.  Furthermore, EPA's periodic Cost of Clean  Air and Cost of Clean Water
reports examine the overall  impacts of existing  environmental regulations on the
entire  U.S.  economy.  EPA has never taken a broad  look at  the sectors included in
this  report,  however,  nor has  it taken  a  prospective  look  at  the entire  range of
forthcoming environmental programs.

     The changing  nature of environmental programs has prompted many questions
about  their potential impacts on the  various sectors of  society.  Will farmers,  small
businesses, and  local governments be able to afford the combined costs of  the new
environmental  programs?   Will  they be  able to carry  out all  of  the  required
activities?  Where are  problems likely to arise?  To answer these questions,  broader
analyses are needed — analyses that  look at entire sectors of the economy,  span the
complete spectrum of environmental programs, and include forthcoming regulations as
well as those already on the books.
THE SECTOR STUDIES

      The three sector studies  summarized in this report represent  EPA's  initial
efforts  to examine  the  overall impacts of new environmental programs on agriculture,
small businesses, and municipalities.  They are not meant to  be exhaustive  studies,
and their conclusions must be regarded as tentative.  Rather, they must  be regarded
as  pilot studies intended to shed a first light  on  areas  where potential  impacts can
be  expected and to  provide guidance for further study.

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     The sector studies examine 85 recent and forthcoming environmental regulations.
Although  EPA  may issue over  200 regulations in  a single  year,  most  of  these
regulations are  relatively  minor,  without broad-ranging  effects.   Only  5-10  of the
regulations  issued  in  a  single  year  may   be  considered  to  be  major.    The  85
regulations  examined  are those deemed  to have  the potential  for  large and far
reaching  impacts.    All  other  costs,  including those  of  existing   environmental
regulations and other government programs, were  assumed  to  remain constant over
the study period.

     Appendix A presents a list of  the 85  environmental regulations covered  in the
three sector studies.  Because the titles  of most of these  regulations are rather long,
the sector studies refer  to the regulations by the short titles listed in the appendix.
These short titles were created for the sector studies and  may differ from  titles used
in other EPA publications.

     Because the sectors studied are fundamentally different, each study  employs a
different approach.  The municipal  study  uses a newly developed model of municipal
finances to determine the financial conditions of 270 randomly selected municipalities
with  and  without  the regulations.   The   small  business  study  focuses on nine
industries   (1)  that  will  be  required to comply with a number of  environmental
regulations, and  (2)  that contain   a  high  percentage  or  high  number  of  small
businesses.  The agriculture study examines  the  impacts of environmental regulations
on a selected set of livestock, major field crops, and  specialty crop farms.

      Because the sector studies were meant to  be  initial efforts, they are subject to
a number of qualifications. For example:

          1.   Each study limits the range of its analysis by selecting
              a sample  of sources.   While the municipal study uses a
              random   sampling  process,  the   small  business   and
              agriculture  studies focus  on  sources  that  will  be  most
              affected by the regulations. Thus, these two studies are
              not  so  much representative  of  the sectors  studied, as
              they are illustrative of the heavily impacted segments of
              those sectors.

          2.   Because many  of the regulations included have  not  yet
               been promulgated, the costs and even the final forms of
               the  rules  are  not  yet   certain.    Thus,  the  studies'
               conclusions about the impacts of  some regulations  may
               prove to  be inaccurate, should those regulations not be
               promulgated in the forms assumed.

      In spite of these limitations, the sector studies provide an initial reading of the
 potential  impacts  of the new  environmental  programs.   The methodology, major
 limitations, and principal conclusions of each of the studies are  summarized in the
 following  three chapters.  The final chapter  presents  a  summary of  the policy
 initiatives that have been  suggested as a result of these three sector studies.
                                        1-4

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                                    Chapter 2


                                MUNICIPALITIES
     Municipalities play  a major  role in supplying  environmental services.   Local
governments  have taken  responsibility for  providing  drinking  water,  sewage treat-
ment, and  waste disposal  in  a majority  of communities.  Over the past fifteen to
twenty years, most of  the mandates found  in the federal environmental legislation
enacted in the  early  1970s  have been met.  The  increase in the number of people
served and improvements in the quality of  local environmental  services  has  been
considerable, as  has the investment in public  infrastructure to  meet these laws.

     Recent revisions to the environmental legislation have established a broader and
more  stringent set of standards to be met by suppliers of environmental services.  As
a result,  many local governments are now faced with having  to  maintain all or  some
part of their  public services  at  a  higher level of performance.  To meet these  new
standards  will  require  additional  investments in  capital,  and  increases in  rates
charged to  customers for environmental services.

     Improvements in environmental  services is but one of several demands being
made of local public infrastructure.  Studies prepared on public infrastructure needs
and the  availability  of funds  to  meet  these needs indicate that  there may be an
excess demand for financial resources to  rebuild and improve upon the existing  stock
of  public  infrastructure.   Therefore,  it is  important to recognize that additional
environmental requirements may have to compete  with other  infrastructure needs
(e.g.,  highways,  bridges),  as  well  as other  public  services  (e.g.,  police, education,
health and welfare programs)  provided at  the local  level.

     Given the  increasing demand for  public  services,  this study* examines  what
additional  investments  the new  environmental legislation will  require local  govern-
ments to undertake,  and  the likelihood  that  they will  face difficulties raising  the
necessary funds  through capital markets  and revenues from customers.  The economic
impacts of individual future EPA actions are considered during the regulatory process
in those  situations permitted  by environmental statutes.   The unique feature of this
study  is its   attempt  to  estimate  the  cumulative  costs and impacts  of  meeting a
combined  set of  EPA requirements,  and to  determine whether they may  place a
significant burden on  the  fiscal conditions 
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significantly increase existing charges for improved environmental services.
MUNICIPALITIES AND ENVIRONMENTAL REGULATIONS

     Because municipalities* are a  primary provider of environmental services, they
are also the focus of many  regulatory  programs.   Drinking  water  standards, for
example, establish criteria for  the quality of the water  that is supplied by municipal-
ities to their  residents.   Water pollution control  standards  establish how municipal
sewage  is  to be treated, and  solid  waste regulations  govern  how the sludge  from
wastewater  treatment  is to be disposed.   Other solid waste  regulations set standards
for building and operating municipal waste disposal and treatment facilities.

     In  addition  to  these  environmental  services,  a  number  of  other  municipal
activities fall under the control  of environmental  regulations.   Most municipalities
store  fuel  for  their vehicles in  underground storage tanks  that  are  subject to EPA
regulations.   Schools  and  other  public  buildings  must  meet  EPA  standards for
asbestos.   Municipalities must also  meet the  requirements of  new environmental
regulations  that govern  the  reporting of and emergency planning for users of  toxic
chemicals.

     The ability  of  a  municipality  to  meet  the  requirements of  environmental
regulations  depends not  only on  which  regulations it must  meet,  but  also on its
financial health and  on how it  organizes its environmental  services.  Geographic,
demographic, and political factors all contribute to  a municipality's decision to own,
operate, and choose the level  of  environmental services it will  provide its residents.
In  addition, municipalities  that  allocate  resources  to environmental services  may
effectively  reduce expenditures for  health care,  welfare,  and  housing. Communities
that reduce environmental risks may succeed in reducing medical and disability costs
from pollution-related illnesses,  and limit the damaging  effects of  pollution  to  the
existing infrastructure (e.g.,  roads, bridges, buildings).   As  shown  in  Figure 2-1, the
relative proportion of  a  municipality's budget allocated  to environmental services falls
as  the  size of the community rises.  The environmental  costs in the figure  include
annual operating and capital costs for drinking  water,  wastewater  treatment, and
solid  waste disposal.   Other miscellaneous expenditures  associated  with asbestos
removal or underground storage tank  technical  and  financial  standards are  not
included in this figure.  Therefore, these  percentages may underestimate the propor-
tion of current municipal budgets expended on all environmental services.

      The  top  graph  in  Figure  2-2 shows  how  the average  percent of  household
income expended on  drinking water, wastewater  treatment, and solid waste disposal
      *For purposes of  this  study,  municipalities are defined  as those government
 bodies  defined  by the U.S. Bureau of  the Census  as  municipal  governments  and
 township governments.  Municipal governments are political subdivisions within which
 a municipal corporation has  been established to provide general local government for
 a specific  population concentration in a  defined area.   This  includes  most units
 designated  as  cities,  boroughs,  towns,  and villages.   Townships  exist  to  serve
 inhabitants  of  areas defined  without  regard to  population  concentrations.   This
 includes  units designated  as  towns,  plantations, locations and townships.  For further
 discussion, see 1982 Census of Governments, Volume 1: Governmental Organization.

                                        2-2

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                                   Figure 2-1
DISTRIBUTION OF MUNICIPAL EXPENDITURES FOR SERVICES  IN 1984-1985
                       Municipalities Under 50,000  Persons
                   Energy (18.2%)
         Miscellaneous  (8.8%)

       Interest on Debt (4.9%)

           Administration (7.0%)
          Natural Resources (3.7%)
                      Housing (2.0%)
                                    Education (4.6%)
                                       Welfare (0.4%)
                                       ~    ealth  (3.8%)
                                             Transport (9.9%)
                                                Police/Fire (15.5%)
                                        ENVIRONMENT (21.1%)
                 Municipalities Between 50,000  and 250,000 Persons
                      Energy (12.4%)


         Miscellaneous (10.3%)


       Interest on Debt (5.2%)

         Administration (5.8%)

        Natural Resources (4.8%)
                   Housing (3.8%)
                                         Education (1,0.3%)
                                            Welfare (0.7%)
                                             Health (3.6%)
                                                Transport (9.5%)
                                               Police/Fire (17.8%)
                                           ENVIRONMENT (15.8%)
                         Municipalities Over 250,000 Persons
                                            Education (9.0%)
                                                 Welfare (5.1%)
                                                   Health (5.2%)

                                                     Transport (8.7%)
                     Energy (11.7%}


        Miscellaneous (12.3%)


      Interest on Debt (5.6%)

         Administration (4.9%)        ^^^^
       Natural Resources (3.9%)V" ^^^   /Police/Fire (15.1%)
                  Housing (4.5%)
                                       ENVIRONMENT (14.0%)
Source: 1984-1985 Census of Governments - City Finances
                                   2-3

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            CURRENT AVERAGE ANNUAL HOUSEHOLD

             COSTS FOR ENVIRONMENTAL SERVICES
                                     \
               I. Percent of  Annual Gross Household  Income
           0 - 2.5K   2.5 - 10K    10 - 50K   50 - 250K    > 250K
      $700
                      II. Annual Dollars Per Household
                   2.5 - 10K   10 - 50K   50 - 250K    > 250K

                       MUNICIPALITY SIZE CATEGORY
0 - 2.5K
              ••  Sewer    &SS  Water

Source: Municipal Sector Study Database

                              2-4
National
Average
                                    Solid Waste

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services varies by size for municipalities sampled in the study.  The  lower portion of
the figure shows the  dollar  expenditures for  these same services.   The  differences
between  the two  presentations is  attributable  to  several factors.  For example, the
percent of  household income spent  for  drinking water  and  wastewater treatment
services tends  to  fall  as municipality size increases, but dollars  expended for  these
services remains  constant or rises with population.  Smaller communities tend to have
lower average  household incomes than do larger communities.   Therefore, households
in  smaller  municipalities  must  spend a  larger  proportion of  their  income  than
households in larger communities in order to expend equivalent dollar amounts.

     For  many environmental services, the ability  of larger  communities  to  take
advantage of scale economies will allow them to  enjoy lower unit  costs for services
than consumers living in smaller  communities.  The  numbers  in Figure  2-2 do not
show a large decline in expenditures  as population size rises.  These lower unit costs
are partially  offset by  greater consumption  of these  services,  so the total user fees
paid by  households in larger municipalities  can be comparable,  on  average,  to fees
paid by  households in smaller communities.   Grants and  loans to communities  have
also helped  to lower  household costs for  drinking  water and  wastewater treatment
services, but it is not clear that  the  distribution of assistance  has been weighted in
favor  of  small versus large  communities.  An additional factor  contributing to the
similarity  in  costs across municipality sizes is the  more  advanced  average  level of
services provided in larger municipalities.  Larger communities  have  invested in  more
advanced and  costly treatment technologies, which can offset the advantages of scale
economies for comparable levels of  services.  The net result  is that households in
smaller communities generally spend  a larger portion of their available resources—
when  measured  as a  percent of  household income  --  to obtain drinking water and
wastewater treatment services than do households in larger communities.

     Likewise, although scale economies may  also occur in solid waste treatment, the
costs in  Figure 2-2 do not reflect this.  The  higher relative household costs of solid
waste  disposal for larger municipalities are  primarily  due to the limited number of
requirements currently affecting smaller communities, and the reliance of some larger
communities on more sophisticated and costly disposal techniques.

     When  improved environmental  services are  supplied by  municipalities, the
additional costs  of raising capital  to begin construction of facilities can be funded
through  different revenue-raising mechanisms.  Current revenues, or "pay-as-you-go"
financing, uses a proportion of revenues to support a  capital  reserve account.   The
revenues  may come from taxes or  usage  fees.   This method has  often  failed  to
provide  for adequate reserve funds  capable  of  financing large  capital investments.
Smaller  communities  are more  likely to use  this mechanism,  given the amount of
capital they  require  is  often small.   They  are  also  likely to  use  this mechanism
because they lack sufficient  expertise and  fiscal capacity to raise funds through bond
markets.

     Debt service financing involves  the issuance  of bonds to finance construction of
large-scale  projects.  General obligation (g.o.)  bonds  are repaid with revenues raised
from  property or income taxes.   They are  best  applied  in  situations where the
general public benefits  from the  project, such  as with  public education or transporta-
tion systems.  Revenue bonds are supported by the  user charges assessed to  custom-
ers  directly  benefiting  from the  project.   Since revenue bonds  rely  on customer
payments  and g.o. bonds rely on the taxing  authority of the  local government, the

                                        2-5

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revenue  bonds are perceived  as  more risky to investors and, therefore,  require a
higher rate of  return on  the amount invested.   Revenue, bonds can  be a  more
accessible  financing  instrument than  g.o. bonds,  since  local governments may  be
constrained by federal and  state statutes as to the amount of debt  the  community
can  issue,  or  the amount it can increase tax rates.   Revenue bonds  are now the
preferred choice of local municipalities to finance drinking  water  and  wastewater
treatment projects.  There is also increasing interest in their  potential  use for  solid
waste treatment projects.

     The declining availability of  federal  grants has  contributed  to  the greater
interest in alternative financing mechanisms.  A substantial proportion of the capital
investment in wastewater treatment since  passage of environmental legislation in the
early 1970s has been  financed with federal and  state grants.  Grants were once a
major  source  of capital financing for many public infrastructure programs.   These
programs have been reduced in favor of federal, state, and local  government loan or
debt financing  programs.  Although federal and state grants  will continue into the
next decade, funding  levels will decline, so alternative financing  mechanisms will be
adopted  to meet increasing demands for resources.
STUDY METHODOLOGY AND LIMITATIONS

     This  study examines the  impacts of  recent  and  forthcoming  environmental
regulations  upon user  charges  and finances in municipalities.  The outputs of the
study include projections of the cumulative costs to communities of upcoming actions,
the  proportion  of  communities expected to face potential  difficulties  meeting the
household user charge increases necessary to pay for additional requirements, and the
proportion of communities that may have  financial difficulties meeting the require-
ments given their present financial conditions.

     In addition to having to use a relatively small sample of  communities,  the study
had to rely  upon  a number  of simplifying assumptions, including  the omission of
several important  environmental regulations for which estimated costs are not yet
available and  the use  of economic  indicators  to  assess  household  burdens  and
financial capabilities  of  municipalities to  fund improvements  in  environmental
services.

Methodology

     This study used EPA's MUNFIN model of municipal  finances to calculate the
effect of adding the estimated aggregate  costs of environmental regulations to the
current  user  charges  and financial  statistics of  270  sampled municipalities.   As
indicators of potential financial difficulties, the study examined  several measures of
the  predicted increases in user fees and municipal debt.  The environmental regula-
tions considered in the sector study are  listed in Table 2-1.  The overall methodology
is summarized below.

     The study estimated the  cost and the incidence  rate  of  each environmental
regulation for municipalities in each size  category in order to produce "probabilities
of occurrence" and the  relevant associated  capital, maintenance, and administrative
costs.    The  probabilities  and  cost figures  were used  to  determine  the  weighted
average costs  of  each new requirement, and cumulative totals  of weighted average

                                        2-6

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                                         Table 2-1


LIST OF REGULATIONS CONSIDERED IN THE MUNICIPAL SECTOR STUDY


          Regulations Included in the Cost Analysis                Regulation Status

          A. Drinking Water
              1. Inorganic Compounds (lOCa)                              In Development
              2. Synthetic Organic Compounds (SOCa)                      In Development
              3. Volatile Organic Compounds (VOCs)                       Promulgated
              4. Fluorides                                              Promulgated
              5. Lead and Copper Corrosion Control                        Proposed
              6. Lead and Copper MCL                                   Proposed
              7. Coliform Monitoring                                     Proposed
              8. Surface Water Treatment Rule: Filtered                    Proposed
              9. Surface Water Treatment Rule: Unfiltered                   Proposed
              10. Radionuclides                                         In Development
              11. Disinfection                                           In Development

          B. Wastewater Treatment
              1. Secondary Treatment of Municipal Wastewater              Promulgated
              2. Pretreatment Requirements                              Promulgated
              3. Sewage Sludge Disposal - Technical Regulations              In Development
                   for Use and Disposal

          C. Solid Waste Disposal
              1. Municipal Landfill Subtitle D Criteria                      Proposed
              2. Municipal Waste Combusters - Air Standards               In Development
              3. Municipal Waste Combusters - Ash Disposal                In Development

          D. Miscellaneous Regulations
              1. Underground Storage Tanks - Technical Standards           Promulgated
              2. Underground Storage Tanks - Financial Standards           In Development
              3. Stormwater Management                                In Development
              4. Asbestos in Schools Rule                                 Promulgated
              5. SARA Title III Requirements                             Promulgated
          Regulations Omitted from the Cost Analysis (due to insufficient data)

          A. Drinking Water
               1. Wellhead Protection Plan                                In Development
               2. Pesticides in Groundwater                               In Development
               3. Disinfection By-Products                                In Development

          B. Wastewater Treatment
               1. National Estuary Program                               In Development
               2. Wetlands Protection Program - 404(c) Permits              Promulgated
               3. Nonpoint Source Regulations/Guidance/Mgmt. Plans         In Development
               4. Section 304(1) - Toxics in Water Bodies                    In Development

          C. Solid Waste Disposal
               1. National Contingency Plan - Superfund Program            In Development
               2. Low-Level Radiation Waste Standards                     In Development
               3. Toxicity Characteristics of Solid and                       In Development
                   Haiardous Wastes

          D. Miscellaneous Regulations
               1. Heavy-Duty Diesel Vehicles                              Promulgated
               2. Gasoline Marketing                                     In Development
               3. Diesel Fuel Standards                                   In Development
               4. Revisions to National Ambient Air Quality                  In Development
                   Standards (Oeone, Carbon Monoxide, Particulate
                   Matter, Nitrogen Oxides, Sulfur Oxides)
               B. Asbestos in Public Buildings                             May Be Required

                                            2-7

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costs  for  four service categories  (i.e.,  drinking water, wastewater  treatment,  solid
waste, and  miscellaneous  costs)  were used  in the analysis.   The weighted average
costs  were used to calculate the additional  charges to  households for environmental
services  that  would  be  in  effect by  1996.    These weighted average  costs  were
examined in  light  of the  current revenues  and  expenditures for  environmental
services in each municipality in  the municipal data base.  Taken together, these data
bases provide  current and  future expenses  for all environmental  services.    The
change  in total charges and fees  paid  by households to meet  the new requirements
was used  as an indicator of the expected severity of the impact to households.   The
household burden measure used was the percentage increase in  total charges and fees
paid  relative to current charges and fees.  As there is  no  established limit on  what
this  increase can  or should  be when addressing  the  degree of  impact to  households,
the distribution of the municipalities'  percentage increases is presented, and several
points along the distribution  are highlighted.

      The study also examined  the  capability of each  municipality to obtain financing
for the additional capital expenditures required for the environmental  regulations.
Three financial mechanisms  were  addressed - revenue bonds, general  obligation (g.o.)
bonds,  and bank  loans  (primarily for  smaller  communities  excluded  from  bond
markets).*   The  first  stage  of the financial  capability analysis considered whether
municipalities  in  the  sample would have difficulty issuing a revenue bond to  cover
the  costs of   meeting additional  drinking  water or  wastewater  treatment  system
requirements.   Their ability to meet the  requirements  was assumed to  be contingent
upon the condition that the increase in user charges to households necessary to meet
additional EPA requirements  will not  exceed  a  given  level of the household's  gross
(pre-tax) annual  income.   Municipalities that  will be required to set user charges at
levels that  exceed specified ratios of  current gross household  income (1.0%,  1.25%,
and  2.0%) are  projected to have  potential long-term difficulty issuing  a revenue bond
to finance the new  requirements.  Drinking water  and wastewater treatment services
were examined in this manner because most  municipalities operate these  services  as
enterprise units, or independent  business units, which are normally supported through
user charges and  fees.

      These  thresholds  are derived using  information on the distribution  of current
user  charges   to  households  for  each  drinking  water and  wastewater  treatment
services.   As  shown  in Figure   2-2,  current  operations  require   households pay
approximately  0.5% of gross  household  income for  each individual  service.   The
thresholds set separate limits of  1.0%, 1.25%, and 2.0% for each of the drinking water
and   wastewater  treatment services.  The  1.25% threshold  attempts  to  address  the
sensitivity of  the results  to the selection of  a threshold based upon current  condi-
tions. The  2.0%  threshold -- an  approximate doubling of the higher observed  current
       Although municipalities under  2,500  do not normally issue revenue bonds  or
g.o. bonds, financial institutions will use  criteria similar to  those used by  investment
bankers  in cases  involving  larger  municipalities.   To qualify  small  systems and
municipalities  for  long-term  loans,  investment  bankers  will  evaluate  performance
history,  user  charges (often as a  percent  of income),  and use  revenues from  the
service as collateral  for  a loan.    Just  as  in cases where large cities  are  denied
access to revenue bonds  and g.o. bonds, so  may  banks refuse to approve loans  to
smaller  municipalities  where  their  systems  or finances  do  not pass the  criteria
described in the study.

                                        2-8

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user charges for either drinking water or wastewater treatment in the sample -- is
used to  present  the  consequences of  using  a more  relaxed  criteria for households
user charges.

     For  example, for a  drinking water  system to  exceed  the  1.0% threshold,  the
addition of new  environmental costs to the current costs of supplying drinking water
would  require  that average household user  charges  be set  above  1.0%  of  the gross
household  income  for  the  population  served by the system.   The  same approach is
followed  for  each  of  the three  thresholds, and  is  repeated  after  calculating  the
additional  environmental costs for wastewater treatment. Therefore, using the 1.0%
threshold example, a municipality  may find itself facing one of  four  possible out-
comes  after calculating new  household user charges: (1) both drinking water and
wastewater treatment costs fall  below the  1.0%  threshold;  (2)  only drinking water
costs exceed the  1.0% threshold; (3)  only  wastewater  treatment costs exceed the 1.0%
threshold;  and (4) both drinking water and wastewater  treatment costs exceed  the
1.0% threshold.  If the municipality was  projected to  face  either  of the conditions
described in situations  (2), (3), or (4),  then it was assumed that the relevant drinking
water and/or wastewater treatment system would have difficulty raising capital using
revenue bonds.

     Costs  for solid waste and miscellaneous requirements  are not included  in  the
revenue bond  test due to  the  limited number of instances  that this mechanism  has
been used  with these "non-enterprise"  services.  Although more local governments are
choosing  to operate their solid  waste  services  as  enterprise  systems,  the  limited
number of  enterprises in the sample led to the exclusion of solid waste services from
the revenue bond section of the analysis.

     The second stage of  the financial capability analysis introduces the additional
costs for  solid  waste  disposal and miscellaneous  requirements,  and  examines  the
ability  of  the  municipality  to use municipality  revenues  and  taxing  authority to
finance capital requirements.  For  those  municipalities projected  to have  long-term
difficulty  issuing revenue bonds for their drinking water and/or wastewater treatment
systems, these costs  are included  with the  solid waste and miscellaneous require-
ments.   Where no  long-term  difficulties are anticipated for the drinking water  and
wastewater treatment  services, only  the solid  waste  and  miscellaneous  costs  are
examined against the municipality's revenue base.
                                 i
     The ability of a municipality to  issue a g.o. bond  was  assumed to be contingent
upon the municipality's total existing  and new environmental debt  service obligations
relative to two measures:  (1)  the  municipality's  1986 total general revenues,  and (2)
the  municipality's total 1986 market  value  of  assessed  taxable property.   The  first
condition  measures existing revenue sources, whereas the second condition considers
potential  revenue  sources.   A  series of threshold  values  were  established  using
information on the distribution of  values for the two  measures from the sample of
municipalities.  The values were  used  in conjunction with the relevant environmental
costs to determine which  municipalities would have  potential difficulty issuing  g.o.
bonds  (or  for smaller municipalities, obtaining a  bank loan).  A municipality had to
exceed  the threshold value for both measures before  it was assumed to have difficul-
ty  using  g.o.  bonds.  It is the number of  municipalities having difficulty meeting
these conditions that  best represent  the  severity of the financial  impacts  of  the
additional EPA regulations considered  in this study.


                                       2-9

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Limitations

     Many  simplifying  assumptions  necessary  to  carry  out  this  study  limit  its
accuracy.

     The municipal data base consists of  a relatively small  sample of communities
(270),  and  may  not be  adequate to form  the  basis  for  national  estimates.    In
particular, the analysis may fail to adequately portray the conditions of the smallest
of local governments  -  those  under  500  persons.   Furthermore, the data  base  was
prepared from fiscal balances for only one year (1986).  Because the  fiscal conditions
of communities continually change with the economy, the data from  1986  may not be
representative of the financial conditions that will exist during the 1988-1996 period.

     The cost data used in this  study were taken from a limited set of EPA regula-
tions.   Although about  40 of  the  85  regulations  considered in  the  study  were
identified as having some implications for local government,  only  22 were at a  stage
where cost  data  were available  to be used in the analysis.   Several of  the omitted
new requirements may require significant  investments  in local government  resources
(e.g., asbestos  in  public buildings), or  may  lead to major changes in  current land use
patterns (e.g.,  groundwater protection,  nonpoint  source guidelines).   Furthermore,
because some  of  the regulations  included in the study are  not yet  final, the  eventual
costs  may differ from those estimated in  this study.   Therefore,  the results of  this
study cannot provide a definitive picture of what local governments  will be spending
by  1996 to  meet  EPA requirements.   This  study only  captures a portion of the total
picture, and even this portion is subject to change.

     In preparing the cost data, it was assumed  that  small municipalities  generally
are served by  small environmental service systems and large municipalities by large
systems.  The  actual distribution of systems across municipalities may be different, so
the costs to households  may not be well  represented  by this  method.   Furthermore,
to reduce the  costs of environmental  regulations,  municipalities may change the  way
they provide  environmental services.  Municipalities may enter into regional service
agreements  in order to  take  advantage of scale economies, or  they  may look to
private companies or contractors to provide  services, thus freeing themselves of sole
responsibility  for financing the  construction of  facilities.   They may  also  find  it
economical  to purchase  services from  adjacent  municipalities or  special   districts,
rather than build new systems to supply the services themselves.

     The financial  indicators  used to estimate households'  ability to  pay  increased
user fees and  municipalities' ability  to finance capital expenditures are  based  upon
measures currently used in the financial community, but only until local governments
make  arrangements to raise fees or  initiate  bond referendum to finance new  con-
struction will  the preferences  of consumers be known. Consumers  may  be more or
less willing to pay for improved environmental services than these indicators suggest.
On the other  hand, some municipalities may have  to finance  a large number of public
works other  than those included  in this study, and  consequently may encounter
financial constraints  even though they are  not predicted  to exceed  the  financial
indicators used in the study.
                                       2-10

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THE IMPACT OF ENVIRONMENTAL REGULATIONS

     The  study first examined  how much municipalities' expenses for  environmental
services would  increase with the  additional environmental  regulations.   These new
expenses were  then  added to recent  financial statistics from the  270 sample munici-
palities to determine whether the  increased environmental expenses would cause  any
of the municipalities to fail the financial indicator tests.

Environmental  Expenses

     The  estimated  increases in environmental expenses  for  households in municipal-
ities in each of  five  size categories  is presented in Figure  2-3, both  in  terms of
dollars per  household and percent  of household  income.   The  largest  potential
increase in average  annual costs per  household will occur in communities under 2,500
persons, which  will  experience  an  increase  of $170  in  their annual costs.  The
households in   communities between  2,500  and 250,000  persons  will  experience  a
smaller potential increase  of $80  to $90 in their annual expenditures  for environ-
mental services.    Communities  over  250,000  persons  may  also  experience large
increases  in  costs for  services.  The  average  potential  increase  in annual  costs for
the largest communities is $160.   The national  average  increase in  annual household
costs is $100.

     When expressed  as  a percentage  of  household  income,  the  greater relative
increase in costs to  communities under  2,500 persons is more evident.   The average
increase will require households in the smallest  communities spend an additional 0.7%
of  gross  household  income on  environmental  services.   Households in  communities
between 2,500   and  250,000 persons  will spend an additional 0.2% to 0.4% of gross
household income.  Communities over 250,000 will spend an additional 0.5% of gross
household income on environmental services.  Although  the average dollar increases
in  communities over 250,000  are comparable  to  average  dollar increases in  com-
munities under 2,500, larger communities have higher average household income levels
than  do smaller communities.  The  potential national  average increase  in costs  will
require that an additional 0.4%  of  gross  household  income  be spent on  improved
environmental  services.  Adding potential  additional costs to  existing  environmental
expenses  suggests that total future  dollar  expenditures  will be  approximately  the
same for  all but the largest municipalities.   However, because household income tends
to be  lower  in smaller communities,  the percentage of  household income devoted to
environmental  expenses will be greatest in  communities under  2,500 persons, followed
closely by municipalities over 250,000 persons.

      The  individual environmental regulations  that account for the largest potential
increases   in  expenses in  small  communities  are the  drinking water  and  sewage
treatment requirements.   Several of the more costly drinking water regulations  will
apply to   a  greater proportion of smaller  municipalities  than larger  municipalities.
These regulations do not single out smaller municipalities per se, but  instead  deal
with  environmental risks that are  present  at smaller community drinking water
systems.   Many larger  water  supply systems  already  have  introduced treatment
systems capable of  handling  some  of these risks.   This helps to explain why the
overall increases for smaller  communities  exceed  those for the larger  communities.
The  costs of  solid waste  disposal,  asbestos removal  in schools,  and  underground
storage tank regulations, when totalled, also account for a significant portion of the
costs  borne  by smaller communities.   Taken individually, these costs tend to be less

                                        2-11

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                            Figure 2-3
   CURRENT AND POTENTIAL ADDITIONAL AVERAGE ANNUAL
HOUSEHOLD COSTS FOR IMPROVED ENVIRONMENTAL SERVICES
   8
   53
   o
   g
   UJ
   o
   a:
   s
   LU
   tn
   o
   UJ
   Q.
        2.4
                  I.  Percent of Annual Gross Household Income
            0 - 2.5K
                   2.5 - 10K
10 - 50K  50 - 250K
> 250K
National
Average
       $700
                        II. Annual  Dollars Per Household
        $o
                                                         National
                                                         Average
           0 - 2.5K   2.5 - 10K    10 - 50K   50 - 250K    > 250K
                     MUNICIPALITY SIZE CATEGORY
            V~* Current Charges          ^H  Additional Charges
Source: Municipal Sector Study Database
                              2-12

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than  the  drinking  water  and wastewater treatment  regulations.   However, most
municipalities are subject to these requirements,  whereas the costlier  water regula-
tions  affect  a smaller  proportion  of municipalities.   As  a result, not only do  the
drinking water regulations  lead to relatively large changes in fees in a few munici-
palities, but  the cumulative costs of  the other regulations  can add  up to sizable
increases in user charges and fees for some municipalities.

Increases in Household User Charges  - Household Burden Measures

     When the costs of complying with the environmental regulations are  added to
existing environmental expenses, the user  charges  and fees of the vast  majority of
municipalities  will  increase.   Some  municipalities  may  have  to  raise  user  fees
considerably  above current  rates. Table 2-2 presents information  on the percentage of
municipalities that  may  potentially  burden households with  requests for large user
charge and fee increases.   The percentage increases are  based  on a comparison of
current (1986) average  charges to households for existing environmental services (i.e.,
drinking water, wastewater treatment, and solid waste  disposal)  and potential future
(1996) average charges  for  improved environmental services, once all of the  addition-
al regulations examined  in the analysis  are  in-place.   Because  the study  was con-
ducted using average charges and costs of additional regulations  to municipalities, the
specific requirements for individual  municipalities may require that some spend either
more or less than the average impact results described in the study.

     Most  of the  municipalities that would experience the largest overall percentage
increases  in  fees  are the smallest municipalities.   As  shown in Table 2-2,  the  user
fees of 20%  of  the municipalities  under 2,500 persons  may rise over  100%  above
current levels by  1996.  An additional 35% of these sized communities may find their
environmental bills  increase between 50% and  100%. None of the municipalities above
2,500 persons in the sample are projected to  have their household costs  rise by over
100%.  Households in 10%  of the  communities between 2,500 and 10,000 persons and
20% of  communities between  10,000 and  50,000 persons may find  their  expenses
increasing between 50% and 100%.  All communities in  the sample between 50,000 and
250,000 persons  are projected to  experience less than 50%  increases  in  household
expenses for improved environmental services.  Approximately 20% of  the municipal-
ities above 250,000  persons may require household  expenditures rise between 50% and
100%.   Although a significant number  of larger communities may  need  to  raise
household  fees  between  50%  and 100%,  most  households  will  not  experience  large
percentage  increases in  costs  of  environmental  services.    Nationally,  only 2% of
households may  have their current  environmental service charges and fees rise by
more than 100%, and 15% may have  to pay between 50% and 100% above their current
payments.   Many  of the  households that are expected  to  experience  initial  "rate
shocks" when confronted with rising user fees are in communities having fewer than
2,500 persons.

     The magnitude of the rate increases suggest  the  extent to  which problems  may
occur, not necessarily  where rate increases will  be  rejected and municipalities  will
fail to meet required improvements  in  environmental quality.   Efforts  to inform
voters of  the benefits of  environmental  improvements can play a useful  role when
faced  with households reluctant to  accept projected  increases in user fees.   Further-
more,  municipalities may  be able to mitigate the increases in household  costs by
using  innovative technologies or  alternative  methods  of supplying services  (e.g.,
regional service arrangements).

                                       2-13

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                                      Table 2-2
POTENTIAL CUMULATIVE IMPACT OF ENVIRONMENTAL REGULATIONS:
            PERCENT INCREASE IN HOUSEHOLD USER CHARGES
Municipality
Size Category
0 -
2,500
2,500 -
10,000
10,000 -
50,000
50,000 -
250,000
> 250,000
Percent
Percent
Number of
Municipalities
26,315
6,279
2,694
463
59
of Municipalities
of Population**
This percent increase is calculated as follows:
(Additional Drinkine Water + Wastewater
Percent of
Increase as
0 - 50%
45%
90
80
100
80
56%
83%
Municipalities in the
a Percent of Current
50 - 100%
35%
10
20
0
20
29%
15%
Category
Charges
> 100%
20%
0
0
0
0
15%
2%
+ Solid Waste + Miscellaneous Costs) x 100
          (Current Drinking Water + Wastewater + Solid Waste Costs)

 Percent of U.S. population living in municipalities and townships within each municipality size category. According
 to the 1982 Census of Governments, approximately 85% of U.S. population resides in these government organizations.
 Distribution is: 0-2,500 (10%); 2,500-10,000 (16%); 10,000-50,000 (29%); 50,000-250,000 (23%); > 250,000 (22%).
                                          2-14

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Capital Financing Indicators

     Table  2-3  presents the  percent  of  municipalities that  may  have  long-term
difficulties  raising  funds with revenue bonds because of the eventual household rates
that must be charged to meet existing and potential EPA requirements.  The drinking
water and wastewater systems were examined using  three different threshold values-
--  1.0%,   1.25%,  and  2.0% of  gross household  income.  The  two lower  thresholds
represent an effective doubling of average  current  user charges  for  each of these
improved services.   The 2.0% threshold ~ an amount not currently expended  in  any
municipality in the sample  ~ represents  a more relaxed  criteria of user charges
expended for these  services.

     Some systems  currently have  user  charges  in-place that exceed  the  lower  two
income  thresholds.   The  numbers in brackets  in  Table   2-3  show  the  estimated
percentage  of  systems  that  exceed  the thresholds  prior   to  adding  the costs  of
additional environmental requirements.  These systems, as  well as systems charging
households  rates  below  the thresholds, may need to raise rates further if  subject to
the additional requirements.  Their current conditions may  lead to different difficul-
ties  in obtaining  financing from systems presently below the financial thresholds,  and
suggest  different  solutions  may  be necessary to meet their financial needs.   The
numbers show  that a  greater percentage of systems  serving communities under 2,500
persons  presently  exceed  the  1.0% and  1.25% thresholds than do systems in  larger
communities.  These circumstances have  already  led EPA to initiate several programs
to assist smaller communities  seeking to meet  environmental  objectives.  Several of
these programs are  discussed in Chapter 5.

     As  shown in  Table 2-3, if a  1.0% threshold is used for each  individual service,
approximately 26%  (21% above the 5% baseline failure  rate) of the drinking water or
wastewater  systems in  municipalities  under 2,500 persons  may have  difficulties in
revenue  bond  markets.   Raising  the threshold up  to 1.25% of household  income
reduces  this to 12% (10% above the 2% baseline failure rate) of systems in  municipal-
ities under 2,500  persons,  and raising the threshold up to 2.0% reduces  the  failure
rate down  to  2%   of  systems.  Larger municipality size  categories  will have  less
difficulty meeting  the  additional requirements.   Using the  1.0%  threshold measure,
between 4% and 8% of the  systems in  municipalities  with 2,500  to 250,000 persons
may have difficulty in the  revenue  bond markets.  Raising the  threshold to 1.25%
decreases the percent of systems  failing the test to 2%.   No systems  in  the sample
serving  more than 2,500  persons  fail  the  2.0% threshold,  because   none of these
systems are expected to  raise rates above  2.0% of gross household income.

     A  greater percentage  of systems  in municipalities over 250,000 may  experience
difficulties at the  1.0%  threshold (11%, or 7% above the 4% baseline failure rate), but
this number falls  to 3% when using  the 1.25% threshold,  and down to zero for the
2.0% threshold.   For  the nation,  21% (15% above the 6%  baseline failure  rate) of
drinking water and wastewater treatment systems may  have difficulty  using revenue
bonds/loans when  using the 1.0% threshold.  The number drops to 9%  (8% above the
1%  baseline rate) of systems when using the 1.25% threshold,  and  less  than 1% using
the  2.0% threshold. Because  most  of the municipalities projected to have difficulties
are  small in  size,   the  percent of  persons residing  in  municipalities  that may face
each of  the income thresholds is relatively smaller than the number of municipalities
failing the criteria (e.g., 9 percent of  households  exceed  the  1.0%  threshold, con-
trasted against 21% of the municipalities).

                                       2-15

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                                            Table 2-3
POTENTIAL  IMPACT OF ENVIRONMENTAL REGULATIONS ON THE ABILITY OF
     DRINKING WATER AND WASTEWATER TREATMENT SYSTEMS  TO ISSUE
           REVENUE BONDS/OBTAIN BANK LOANS IN THE LONG TERM*
                             Percent of Municipalities Whose Systems May Be Unable to
                                   Issue Revenue Bonds/Obtain Loans in the Long Term
                                        User Charge/      User Charge/       User Charge/
 Municipality        Number of     Household          Household          Household
 Size Category     Municipalities    Income > 1.0%     Income >  1.25%    Income > 2.0%
 0 -                   26,315                 26%                  12%                   2%
       •>**
  2,500                                       [5%]                 [2%]                 [0%]
 2,500 -               6,279                  820
   10,000                                      [2]                   [1]                    [0]
  10,000 -              2,694                  720
   50,000                                      [3]                   [1]                    [0]
  50,000                   463                   4                    0                     0
   250,000                                    [4]                   [0]                    [0]
> 250,000

Percent
Percent
59

of Municipalities
e r\ i • ****
of Population
11
[4]
21% [4%]
9%
3
[0]
9% [1%]
3%
0
[0]
< 1% [0%]
< 1%
 *    Long Term Revenue Bond/Loan Criteria for Drinking Water and Wastewater Services. Percent of municipalities whose
      new user charges for either one of the services is greater than the stated threshold value (either 1.0%, 1.25%, or
      2.0% of gross household income). The model examines the financial capability of each service separately. For
      example, the results in the 1.0% column refers to the results of imposing a 1.0% threshold on drinking water and a
      1.0% threshold on wastewater treatment services.  A municipality effectively fails the threshold test if either one
      or both of the drinking water and wastewater treatment systems fails the 1.0% threshold. The sum of each individual
      service is not examined in the study because a significant number of municipalities operate these two services as
      separate enterprise units.  For more information on thresholds, see Municipal Sector Study report.

      Smaller municipalities (under 2,500 persons) generally do not issue revenue bonds.  Instead they obtain bank loans
      backed by user charges. The criteria used in the revenue bond tests can be applied to these smaller municipalities.

      Percent of systems exceeding the threshold prior to incurring potential costs of additional requirements (baseline
      systems failing the criteria).

      Percent of U.S. population living in municipalities and townships within each municipality size category. According
      to the 1982 Census of Governments,  approximately 85% of U.S. population resides in these government  organizations.
      Distribution is: 0-2,500 (10%); 2,500-10,000 (16%); 10,000-50,000 (29%); 50,000-250,000 (23%); > 250,000 (22%).
                                                 2-16

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     The final stage of the financial analysis takes the information from the revenue
bond test and combines it with  information on solid waste and miscellaneous expenses
to determine if the general revenues and taxing authority of  the municipality can be
used to finance the additional  costs to non-enterprise services and, if necessary, the
enterprise services.  As shown  in Table 2-4,  the municipalities expected to have the
greatest difficulty using g.o. bonds and  loans  to  finance additional  environmental
requirements are  in the smaller size categories.  The small municipalities will  have
greater  difficulties  meeting  the  solid  waste and  miscellaneous  EPA  requirements,
particularly in those instances  where the drinking water  or  wastewater system  costs
must also rely upon  the  municipality's revenue base to raise funds.  Using the two
different tests, between 21% and 30% of municipalities under 2,500 persons may have
difficulty  financing  the additional EPA requirements  using both revenue  and g.o.
bonds.  The table shows that 4%  to 9% of  municipalities between 2,500 and 10,000
persons, and 2% to 6% of municipalities between 10,000 and 50,000 persons may have
difficulty  obtaining  capital financing for the  cumulative set of  EPA  requirements.
Municipalities  over  50,000  persons are expected  to have no difficulty obtaining
financing for their projected requirements.

     Although omitted from the presentation in  Table 2-4, the different revenue bond
threshold values do  not  appear to  play an  important role  in determining whether the
municipality can  meet its financial requirements.  Using a threshold of  1.0%  versus
1.25% for drinking water or wastewater treatment  costs does  not significantly change
the number  of municipalities expected to face financial difficulties.   Although the
selection of the income  threshold  in  Table  2-3 significantly altered the number of
systems failing the revenue bond test, the g.o. bond  test results are most  affected by
the current financial conditions of the municipality. The information in brackets in
Table 2-4 show the estimated number of municipalities exceeding  the thresholds prior
to adding  additional environmental requirements.  As  many  as 8% of the municipal-
ities under 2,500  persons fail the criteria  in Test  I, and  12% fail the  criteria  using
Test II.  Small municipalities that have already  committed themselves to large capital
projects  for environmental or other infrastructure needs may have to complete these
projects  prior  to  investing in  new projects.   Nevertheless, they will face additional
costs and increasing demands on their current financial base.

     In addition  to the  number of financially weak  communities,  some small munici-
palities currently in good  financial shape may be pushed beyond the  criteria.  The
costs of some individual requirements,  or  the cumulative costs  of  several require-
ments that must  be  met within  a short  period  of time, may strain  the financial
capability  of several small  communities.  The large increases  in costs for environmen-
tal services  in small  municipalities may result in a significant  proportion of these
municipalities --  between  13% and 18%  —  having  financial difficulty meeting the
additional EPA requirements  for  improved  environmental services.  The  cumulative
results indicate that between  21%  and 30%  of  the communities in the sample  under
2,500 persons may have difficulty financing the  requirements.

     The  numbers in Table 2-4 indicate  that  the  percentage of communities  with
more than 2,500  persons  failing  the  baseline  is  not  noticeably  different from the
percentage  of  municipalities  failing the  criteria  after  adding  the  costs  of the
additional requirements.  These results suggest that the financially weaker municipal-
ities  above  2,500 persons  are  likely to  face  financial constraints,  but  the  other
communities that  have sufficient financial latitude may have little difficulty meeting

                                       2-17

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                                              Table 2-4
  POTENTIAL IMPACT OF ENVIRONMENTAL REGULATIONS ON THE ABILITY OF
MUNICIPALITIES TO ISSUE GENERAL OBLIGATION BONDS/OBTAIN BANK LOANS



                                    Percent of Municipalities That May Fail to Issue G.O.
                                            Bonds/Obtain Loans in Each Size Category*
   Municipality           Number of             G.O. Bond/Bank        G.O. Bond/Bank
   Size Category      Municipalities             Loan Test I             Loan Test II



   0 -                         26,315                     21%                      30%
    2,500***                                              [8%]****                 [12%]



   2,500 -                      6,729                      4                          9
    10,000                                               [3]                        [9]



   10,000  -                     2,694                      2                          6
    50,000                                               [0]                        [6]



   50,000                         463                      0                          0
    250,000                                              [0]                        [0]



   > 250,000                      59                      0                          0
                                                          [0]                        [0]



                  Percent of Municipalities           16% [7%]                24% [11%]


                  Percent of Population****            3%                        6%



       Combined G.O. Bond/Loan and Revenue Bond/Loan Thresholds:  Solid waste and miscellaneous regulatory capital costs
       are always examined. The capital costs of drinking water and/or wastewater system requirements are included in
       calculating required new debt service (total capital costs) if the 1.0% Revenue Bond/Loan Threshold for either
       system has been exceeded. For more information on thresholds, see Municipal Sector Study report.

       G.O. Bond/Loan Thresholds - percent of municipalities exceeding both of the following: (i) Current annual debt
       service plus new debt service expressed as a percent of current annual municipality revenues: (Test I: 20%1. (Test
       II: 15%|. (ii) Current annual debt service plus new debt service expressed as a percent of the market value of
       taxable property: (Test I: 0.8%). (Test II: 0.6%). Results using 1.25%  and 2.0% threshold are not included because
       they are not significantly different from results using  1.0% threshold.

       Smaller municipalities (under 2,500 persons) generally do not issue revenue bonds or g.o. bonds. Instead they obtain
       bank loans that are backed by user charges. The criteria used in the two bond tests can still be applied to these
       smaller municipalities.
  ***
       Percent of municipalities exceeding the threshold prior to incurring potential costs of additional requirements
       (Baseline municipalities failing criteria).

       Percent of U.S. population living in municipalities and townships within each municipality size category. According
       to the 1982 Census of Governments, approximately 85% of U.S. population resides in these government organizations.
       Distribution is: 0-2,500 (10%); 2,500-10,000 (16%); 10,000-50,000 (29%); 50,000-250,000 (23%); > 250,000 (22%).



                                                  2-18

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additional  EPA  requirements.   This  conclusion is,  in  part,  contingent upon the
willingness  of the  community to  support  its  local drinking  water or  wastewater
treatment systems.  If the community should choose not  to  assist  financially con-
strained  drinking water or wastewater treatment system operations, then  the number
of larger systems and  communities failing to obtain  financing for additional environ-
mental requirements may fall between the numbers presented in the revenue  bond
results of Table 2-3 and the g.o. bond results of Table 2-4.


CONCLUSION

     The major findings of this study may be summarized as follows:

Household Impacts

     The potential cumulative cost  of regulations examined in  the study that improve
environmental services  provided by municipalities may  require  that  the national
average household spend an additional $100 per year by 1996.

     Both municipalities  under 2,500 persons and over 250,000 persons will experience
the largest average  increases  in  total user  charges and fees paid on  a per household
basis.  The  average potential increase in user  charges  and fees  will  be $170 and
$160, respectively.   Some of the  more costly regulations address technologies that are
in operation  at most  large  municipalities,  but have  yet to be  adopted  by  small
municipalities.  Also,  costs per  household for many regulations tend to  fall as the
population increases,  due to  economies of  scale.  These  conditions,  plus the  lower
average household income levels  in smaller  municipalities, will require that households
in communities under 2,500 persons pay a greater proportion (0.7%)  of  their income,
on average, for these services  than households in larger municipalities  (0.5%).

Financial Impacts

     Most municipalities  will be able to meet the expected increases in environmental
expenses and  still  remain financially sound.   The municipalities  most  likely to
experience difficulty  will be the  municipalities with populations of 2,500 or less.
Between 21% and 30% of the communities under 2,500 persons  may  have difficulty
using revenue bonds, g.o.  bonds,  and loans  because  of  the high cost of  some in-
dividual regulations  and the  cumulative  costs of recent legislative  requirements
(affecting between 13% and 18% of small municipalities), and the limited  margin for
expanding  financial obligations  in small communities due to existing  demands for
environmental and  other  infrastructure services (the remaining  8%  to  12% of  small
municipalities).

     These difficulties are not limited to small municipalities, but the results suggest
that a much smaller  proportion of the municipalities over 2,500 persons  will face
financial constraints when subject to additional EPA requirements.  Unlike the  small
municipalities, most of the constrained municipalities already are in financially  weak
positions, given the criteria.  The additional environmental requirements,  on average,
should not place financially strong communities into  weak financial positions.

     Some portion  of enterprise systems  serving larger municipalities,  particularly
those over 250,000 persons, may have  difficulties financing their additional require-

                                       2-19

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ments.  If the municipalities served by these systems fail to offer support to finance
some  portion  of the  requirements,  these  systems  and  municipalities  may  have
difficulty meeting the additional capital requirements.

     Because of  the  many simplifying assumptions required to carry  out this study,
care should be taken in interpreting  the results.  The municipal government sample
database requires that  caution be exercised  when seeking to extrapolate results to
the nation as a whole,  particularly for very small systems  and communities.  Several
of the regulations considered are not yet final, so their costs may  change. Regula-
tions  likely to  be important for municipalities and households were not included in
the cost analysis  because of insufficient information on costs and number  of affected
communities.  Their omission may  result in an underestimate  of  the costs  to affected
municipalities.   On  the other hand, municipalities may be able  to undertake  alter-
native means of  meeting environmental  objectives that are less costly than original
EPA estimates.

     The  analysis underscores  EPA's efforts  to  seek additional  information on  the
finances and environmental options available  for smaller  municipalities.  Knowing
more  about individual community requirements will assist EPA in better designing  and
modifying programs capable of dealing with their unique problems.  This information
may be of most  value  for smaller  communities, as they face  the potentially greatest
challenges in the  coming decade.
                                       2-20

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                                   Chapter 3


                               SMALL BUSINESS
     The  United States is a nation  of small businesses as much as it is a nation of
large  corporations.   Over  ninety-five percent  of all businesses  have fewer than 50
employees.  Although these firms employ only  about  one  quarter of the  people in the
United  States  and  account  for  about  one  quarter  of  total sales,  they  are  an
important part of the economy and an integral part of the American way of life.

     While environmental regulations affect all businesses, small businesses have  their
own special problems in dealing with them.  Firms  with only  5 or  10  employees do
not have  the financial  resources or the legal  and engineering staffs  available to
larger firms. Often their costs  per unit of production to comply with environmental
regulations are much larger than those of their large competitors.

     From its inception in 1970, EPA has recognized  the  special  problems of small
businesses in dealing with environmental regulations and  has  taken these problems
into account in  its rulemaking  process.  Often, EPA has relaxed some  environmental
regulations  for  small  businesses  and,  for some regulations,   has  exempted  small
businesses.  EPA's  Small Business Ombudsman has  been appointed  to  represent the
special needs of  small businesses within the Agency.

     This  study*  investigates the   potential  impact  upon  small  businesses of  the
environmental regulations that  will  have the most  effect from 1988  through  1992.
The study  first examines how these  regulations  will  affect small  businesses in
general, and then examines in more detail the impacts upon selected industries.
SMALL BUSINESS AND ENVIRONMENTAL REGULATIONS

     Although it might  seem that EPA's 85 regulations would overwhelm any small
business, the  actual impacts will vary  greatly.   Many small businesses will not be
affected directly by any of the 85 regulations.  Some firms will be affected adversely
by  the regulations, but others -- particularly those that provide pollution  control
products or  services --  will  find  that their  businesses  grow.   Thus,  the  overall
impact of EPA's forthcoming regulations is by no means self-evident.
       The  Small Business  Sector  Study:  Impacts  of Environmental  Regulations  on
Small  Business:  prepared for the  U.S. Environmental  Protection Agency, Office of
Policy, Planning  and Evaluation by Lyman H. Clark and E. H. Pechan  & Associates,
Inc.; September 1988.

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     Whether  a small business  is affected by  many  environmental regulations, only
one  regulation, or none  at all depends  upon  whether the  business  contributes to
environmental  problems or  helps to solve  them.  Most small businesses - for example,
those in the wholesale, retail, financial, and services sectors -  are relatively  neutral
as regards  environmental  problems and, hence,  are not directly affected by  any
environmental  regulations.   These sectors of the  economy include 70%  of all small
businesses.

     Small businesses are adversely affected  by environmental regulations  when they
create environmental problems that the  nation has decided to address.  Traditionally,
the  businesses  associated  with  environmental problems have been those  in  the
"smokestack"  industries,  such  as  mining  and  manufacturing   —  industries  that
discharge pollutants into  the air or waterways.  The  businesses  adversely affected by
the new regulations are those that  use toxic  chemicals in  their processes or generate
hazardous wastes.  These include some industries that  usually are considered to be
polluting industries — petroleum refiners, iron  foundries, and electric  utilities  —  and
other industries that generally  are  not regarded as polluters  —  dry cleaners, gasoline
service stations, and farm supply stores.

     Because  one firm's  expenditure  to comply with an environmental regulation is
often  another  firm's receipt, many small businesses will  find  that the forthcoming
environmental  regulations create an increased demand for  their  products and services.
Small  businesses  that provide  engineering  or  laboratory services,  for example, or
manufacture pollution control or monitoring equipment, or clean  up hazardous waste
sites should be positively affected by  the new environmental programs.  Although this
study  does  not examine  these  positive  impacts, they are  worthy  of  note  as  part of
the total economic picture.

     A list of the industries that could be either negatively or  positively affected by
EPA's regulations was prepared  as part  of  the small  business sector study and  is
presented  therein.   While  this list  is  not  exhaustive and  was  prepared using
information that, in many  cases, was still  preliminary, it provides a representative
picture  of the  kinds  of  industries that  are most likely  to be affected, either
adversely  or  positively.   Those industries  listed  most frequently  as  potentially
adversely affected by the environmental regulations are examined  in Table 3-1.  They
include about 3.5% of all small  businesses in the United States.

      Although firms with fewer than 50 employees account for 95% of all businesses,
the  relative importance of small businesses  varies from sector to  sector.  Firms with
fewer than 50 employees  account  for  over  half  the employment and sales in some
sectors - agriculture, construction,  and  wholesale  trade  -  but less  than 20 percent of
employment and  sales  in other sectors - mining, manufacturing,  and transportation.
Thus, some sectors of the economy can be said to be "small business  dominated," and
others can  be  said to be "large business dominated."   Several of the industries listed
in Table 3-1 are clearly small business dominated.
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                                  Table 3-1
            SMALL BUSINESSES* IN SELECTED INDUSTRIES - 1986
SIC   Industry	

2491  Wood Preserving
2861  Gum & Wood Chemicals
2879  Pesticide Formulators
2911  Petroleum Refining
3292  Asbestos Products
3321  Gray Iron Foundries
3341  Secondary Smelting
3471  Electroplating
4213  Interstate Trucking
4911  Electric Utilities
4941  Water Supply
4953  Refuse Systems
5191  Farm Supply Stores
5541  Service Stations
7216  Dry Cleaners
7395  Photofinishing  Labs
  Number
    of
  Firms

   344
    70
   338
   315
   114
   602
   506
 3,350
24,608
 1,376
 2,109
 2,868
15,810
54,930
15,728
 4,739
Number of
  Small
Businesses

   309
    61
   307
   241
    91
   370
   435
 3,050
22,656
   864
 1,977
 2,742
15,609
54,077
15,438
 4,547
Small Business Portion of
Firms   Employment Sales
90%
87%
91%
77%
80%
62%
86%
91%
92%
62%
94%
96%
99%
98%
98%
96%
49%
 4%
13%
 1%
 4%
10%
25%
56%
27%
 4%
32%
31%
66%
71%
79%
42%
54%
18%
14%
 5%
 3%
11%
25%
51%
30%
 4%
28%
30%
65%
62%
79%
47%
* Includes businesses with 1-49 employees.
Source:   U.S. Small Business Administration: Small Business Data Base (SBDBX United
         States Establishment and Enterprise Microdata (USEEM).
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STUDY METHODOLOGY AND LIMITATIONS

     Because  the  number and diversity of  small  businesses  make  it impossible to
cover all small businesses in this study, the study focuses upon describing the impact
of the environmental regulations upon  representative small businesses in nine selected
industries.    The  methodology has  been  designed  to  describe the  environmental
regulations that different types of industries  will face and to provide a preliminary
indication  of  how  the  costs  of  these  regulations  will  compare  to the  financial
capabilities of small businesses in each industry. This methodology necessarily limits
the detail of the analysis and the accuracy of the results.

Methodology

     The first step  in  this  study  was  to  examine the list of 85  environmental
regulations  to  determine which industries  would be most  affected.  These industries
were then  examined to determine which would be most appropriate for further study.
Table 3-1  lists  those  industries  that were  found  to  be  most  affected  by the
environmental regulations and presents statistics on the relative importance  of small
businesses  in  each  industry.   Several of the  industries listed  in  Table  3-1  were
selected  for further  study  because  they  have  a high  percentage of employment or
sales accounted for by  small  businesses: dry cleaning, gasoline service stations, farm
supply  stores,  electroplating, wood  preserving,  and  photofinishing  laboratories.
Although small businesses do  not account  for a high portion of employment or sales
in  the interstate trucking  industry,  this industry was  selected  simply because  it
includes such  a  large number of small businesses.  Two other  industries,  pesticide
formulators  and water  supply companies,  were selected because their environmental
problems are different from those of most of the other industries on the list.

      Definitions of a "small business" vary.   The U.S. Small  Business Administration
(SBA) uses different definitions for each industrial category.  For most manufacturing
industries, SBA defines  a  small business  as a  firm  with fewer than 500 employees
(99.6%  of  all firms).   The  U.S.  Occupational Safety  and  Health Administration
(OSHA), on the  other hand, defines a small  business as  a firm with fewer than 10
employees (75.4% of all firms). Most of the statistics presented in  this sector study
focus on businesses with fewer than  50 employees (95.3% of all firms).   While this
definition is somewhat arbitrary,  it in no way affects the conclusions of the study.
Whatever  the  definition used, most businesses are small, and the number  of small
businesses is about 3.5 million.

      The  approach  used  in  analyzing each  of  these  industries  selected  may be
outlined as follows:

          1.   Describe a "typical" small business in the industry.

          2.   Identify  the  environmental "problems"  associated with
              small businesses in the industry.

          3.   Identify the environmental  regulations that will apply to
              these   small  businesses,  and   estimate  the   associated
              compliance costs.
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         4.   Estimate   the   paperwork  costs   associated   with  the
             environmental requirements for each industry.

         5.   Compare  the estimated  compliance  costs,  including the
             paperwork burden,  with  industry  financial  statistics to
             determine  whether small businesses might be expected to
             have   difficulty  meeting  environmental   requirements.
             Where the estimated annual  cost of compliance was  found
             to exceed  30% of net profits  and/or  where the estimated
             capital  costs were found to exceed  30% of  equity, then
             small businesses in the industry were  identified as having
             the potential for financial difficulties.

     The  threshold value of 30% was selected on more  or  less  an arbitrary basis.
Time and  data limitations prevented  any  extensive financial  modeling or detailed
analysis of  potential business impacts.  This study  was designed,  instead, to identify
potential  problem  areas.  When  estimated environmental  costs  exceed  30%  of the
median small business's annual net  profits and/or  estimated capital costs exceed 30%
of the median equity, then there seems to be cause for concern.  Small businesses in
some industries may be able  to pass such costs on  to their customers and others may
be able to  reduce  the  costs through  innovative  techniques.  Some of the costs will
be absorbed by  reduced taxes.   There are a  variety  of ways that businesses may
adjust to  increased costs.  Nevertheless, when it appears that increased costs  in any
size  category of any industry may exceed  30% of profits, it is safe to  say that the
potential  for financial difficulties  exists.   Because the study examined the financial
statistics of both the median firm  in  each size category and  the firm at  the lowest
quartile  level, the results of the analysis  are not particularly sensitive to the 30%
threshold value.  When costs were close to  30% for the median firm, they were well
in excess of 30% for the firm at the lowest quartile.

      This study  did  not address the issue of whether small businesses will be able to
pass  increased  environmental  costs on to their  customers  in the form  of  higher
prices.   While economic theory suggests  that prices in an  industry should  rise to
reflect producers'  costs, such adjustments  may take time  and may be inhibited by
competition from substitute or imported  products  or simply by  consumer resistance.
Furthermore, the increased costs experienced by small businesses  may be greater than
industry  averages.  Predicting the price  increases that might  result  from increased
environmental costs is a complex exercise that is beyond the scope  of this study.

      Exceptions  to the general  methodology were  made for two industries: gasoline
service stations and private  water  supply systems.  The analysis of gasoline service
stations was based  upon a financial model developed for EPA's Office of Underground
Storage Tanks.  The analysis of private water supply systems was provided by EPA's
Office of Drinking Water based upon its surveys of water supply systems.

      For  information on the financial condition of  small businesses, this study used
the  1976-1983 Fin/Stat file compiled  by  the SBA.  This is the  only  data base  that
provides  separate  statistics  for many  different sizes  of  businesses, including those
that  have fewer  than  10 employees.   Because  the estimates of  environmental costs
often were  available only for  an "average" small business, it  was  not possible to
conduct detailed financial analyses on businesses  of each size category.  Using the

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Fin/Stat file made it possible, however, to examine the financial capabilities of firms
of different sizes and to identify potential problem areas.
     Although  1976-1983 financial data is slightly outdated,  inflation from  1983 to
the end  of 1987 was  relatively  low,  about 16%.  This  is well within  the range of
accuracy of  the  other data used in  the  study  and within the  normal year-to-year
fluctuations in the Fin/Stat data.  The average  (median) dry  cleaner  in the Fin/Stat
file had  lower  net profits in 1983 ($12,000) than in 1977 ($14,900), for example, even
though the inflation over that period was almost 64%.

Limitations

     The approach used in this study has several limitations. For example:

         1.  Many of the regulations included in the study are not yet
             final.    One   of   the   major environmental regulations
             affecting  electroplaters  —   for  example,   the  hexavalent
             chromium  air emission  standard  ~ is not  available yet in
             even  a  preliminary  form,  and  one  of   the regulations
             affecting  dry  cleaners  -- the   perchloroethylene  air
             emission standard — is  still  under formulation with many
             options under study.  Thus, the eventual costs and impacts
             of  many regulations may  vary considerably from  those
             indicated herein.

         2.  The performances  of individual  small businesses  differ
             considerably from  industry averages.  Although  this study
             attempts to take this  into  account in a qualitative  way,
             the  study cannot  go so far as  to say how many small
             businesses might experience difficulties in any industry.

         3.  The data used in  the study, including both the estimates
             of   environmental  costs   and   the   business   financial
             statistics, are of limited accuracy.  Thus,  the conclusions
             must be  regarded as preliminary.                                       I

     In  spite  of  these  unavoidable limitations,  the  study  provides  an initial
description of how  environmental   regulations  will  affect small  businesses  and
identifies many potential policy issues and problem areas for further study.
IMPACTS UPON SELECTED INDUSTRIES

     Table 3-2 summarizes  the  results of the industry analyses.   The study  found
that costs  may  be  high for  most  small  businesses  in  three of the  industries-
electroplating, wood preserving, and  pesticide formulating and packaging.  If costs
prove  to be as high  as  estimated  and cannot be passed  on to consumers,  some of
these small businesses may  be forced to discontinue part of their operations or to
close.  Costs also may be high for  small businesses in certain segments  of five other
industries.  Some  small dry  cleaners that have underground storage tanks or require
substantial perchloroethylene  emissions  controls  may  have difficulty  meeting

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                                   Table 3-2
            SUMMARY OF IMPACTS UPON SELECTED INDUSTRIES
Industry
Electroplating
Wood Preserving
Pesticide Formulating
   and Packaging

Farm Supply Stores
Interstate Trucking
Gasoline Service
   Stations
Dry Cleaning
Photofinishing
   Laboratories

Water Supply
  Most Significant
    Regulations

Toxic Chemicals
Hazardous Waste
Chromium Emissions*

Hazardous Waste
Toxic Chemicals
Corrective Action
Stormwater Control*

Toxic Chemicals
Hazardous Waste

Pesticides
UST Standards
UST Corrective Action

UST Standards
UST Corrective Action
UST Standards
UST Corrective Action
Hazardous Waste

UST Standards
UST Corrective Action
Hazardous Waste
Perc Emissions*

None
Drinking Water Standards
 Firms That Might
Experience Difficulty

Firms with 1-49
employees
Firms with 1-49
employees
Firms with 10-19
employees

Firms with leaking
underground storage
tanks

Firms with leaking
underground storage
tanks

Firms with leaking
underground storage
tanks

Firms with 1-9
employees that have
USTs or require perc
emissions controls

None
Firms that serve fewer
than 2,500 people
     * These regulations are still being formulated.

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environmental  requirements.   In  addition, certain gas stations, trucking firms, and
farm supply stores with leaking underground storage tanks may face corrective action
costs beyond their  financial means.   Small  private water  supply companies are in a
unique position, in that they operate as utilities and  generally  obtain rate increases
to cover their  increased costs.  While these  firms  would  not  be expected to  go out
of business, high treatment  costs for water supply companies that fail  to meet new
drinking water standards  may necessitate large increases in household usage fees.
Environmental  costs for one of the  industries studied  -- photofinishing  laboratories-
  were found to be negligible.

     The environmental regulations that appear to be most often responsible for high
costs in the industries studied  are those covering the handling and  reporting of toxic
chemicals;  the  handling,  treatment, and disposal of hazardous  wastes;  and the
operation  of underground storage tanks.  Although costs  estimates are available for
only some  of  these regulations, those that are available indicate that the regulations
will affect a large number of firms in many industries and may entail costs in the
$5,000 to  $10,000  range.   While  these  costs  may   be  managed  easily  by  small
businesses  of  moderate size, they present difficulties  for the smallest  of  the small
businesses.   It  is these very  small  businesses that comprise the majority  of U.S.
businesses.

     The  following sections  briefly describe the results  of  the  analyses for each
industry.
Electroplating

     The  electroplating  process  requires the  use  of  many  toxic  and  hazardous
materials,  such as metals and solvents.  Although electroplaters generally reclaim and
recycle these materials,  many  of which are valuable,  some  of the toxic materials
remain in  electroplating  wastewaters  and solid wastes.  In addition to these problems
associated  with hazardous  wastes, electroplaters  that use chromium may  also have a
problem with hazardous air emissions.

     Most  of the  environmental expenditures for  electroplaters over  the next few
years will  have to do with handling and  disposing of the sludge that is generated  by
these wastewater  treatment systems and  with the recordkeeping and reporting that
will become a  necessary part of  handling toxic substances  and  hazardous wastes.
One other  potential expenditure --  emission controls for hexavalent chromium -- will
apply only to the chrome plating segment of the industry.

     Because electroplaters with  fewer  than  10 employees  will  be  exempt  from
Section 313 of SARA Title III, their additional  costs for the 1988-1992 period will be
approximately  $4,430  per year, with an additional cost of approximately $3,680 in the
first year  for the hazardous waste  generator regulations.  The estimated annual costs
amount to about 32% of  the median small electroplater's net profit  and  the additional
first year  costs amount  to about 7% of their  equity.   Electroplaters  at the lowest
quartile of this size category averaged net  profits of only  $3,400 over  the 1976-1983
period and lost $9,100 in 1983.  Although the additional  first year expenses amount
to only 15% of their  equity, the $4,430 in additional environmental expenses amounts
to  130% of  their net profits  over  the 1976-1983 period.  These figures suggest that
the  electroplaters in  this  size  category may   experience  difficulty  managing   the

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increased environmental costs.  Because the $4,430  in annual  expenses  represents only
about 2% of their  average sales,  it seems  probable that many of these electroplaters
will  be able to adjust to  the  increased costs,  but for some marginal electroplaters
the additional expenses could present financial difficulties.

     The relative impact  of environmental  regulations during the  1988-1992 period
will  be  greatest on electroplaters with  10-19  employees.   These  are the  smallest
electroplaters that will be  subject to Section  313 of SARA Title III.  Section 313 may
add $9,000 to these electroplater's annual costs,  with  an additional $3,000 in the first
year.   This  $9,000  plus $4,430 of other expenses amounts  to  over 70% of the median
electroplater's  1976-1983  net profits.   Electroplaters  at the lowest quartile in this
size category averaged net profits of only $3,400 over the 1976-1983 period and lost
$4,300 in 1983.  The estimated environmental costs would amount to almost 400%  of
their  average  net  profits.   These figures suggest that many electroplaters  with 10-19
employees will have difficulty meeting the  costs  of  the environmental regulations.

     Electroplaters  in the  next size category,  20-49  employees, may also  experience
some  difficulty  meeting   the  environmental   requirements.    Their  costs  will  be
approximately  the  same as those of the smaller electroplaters, and even though they
have  a  larger annual profits, the annual costs  are still relatively high.  The median
electroplater in this  size  category  had net profits  over 1976-1983  of  $34,000  on
equity of $228,000.  The estimated annual  environmental expenses of $13,430 amounts
to 40% of their average  1976-1983 net profits.   Electroplaters  at the  lowest quartile
level  averaged net  profits  of only $9,000  over  1976-1983 and  experienced a $15,200
loss  in  1983.   The estimated  environmental costs amount  to  almost  150% of  their
average  net profits.  Thus, some electroplaters in this size  category  also  may  have
difficulty meeting the environmental requirements.

     It  is  only  in the   next  largest  size  category  of  50-99 employees  that the
environmental  expenses amount  to  less than 30% of  the median  electroplaters' net
profits  ($70,000).   The electroplaters in the lowest quartile  averaged  net  profits  of
$40,000, however, so that  the estimated environmental costs amount to approximately
34% of these  electroplater's annual net profits.   Thus, the increased expenses will  be
high for some of the firms even in this larger size category.
Wood Preserving

     Almost all of the substances and chemicals used at a wood preserving facility
are  considered  toxic  or  hazardous.    In  previous  years,  as  the  industry  was
developing, and environmental  concerns were  not an  issue, the practices  of many
wood  preserving facilities  eventually  contributed to serious  contamination  of the
surrounding area's soil and water.  Many of these facilities have had to implement
extensive  cleanup operations to  correct these  problems.   The cleanup  costs  have
strained the financial  resources  of many firms  severely, and several  firms have gone
bankrupt.

     Over  the  period  1988-1992,  the  cleanup of  wood  preserving  facilities  will
continue,  and  wood  preservers  will be faced  with  new  regulations  governing the
disposal of their hazardous wastes,  the  reporting of toxic  chemicals, and the  control
of  stormwater flows.    The  problems  associated with  these  new  regulations may
involve not only increased costs, but also the unavailability of disposal sites.  Wood

                                        3-9

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preservers now are finding that there are no disposal alternatives available for their
pentachlorophenol wastes.

     Management and reporting of hazardous  wastes  and  toxic chemicals will add
approximately $14,300 in  annual costs  to  wood  preservers' environmental expenses.
These  costs amount to  about 32% of  the  1976-1983  median  net  profits  for  wood
preservers in both  the 10-19  and  20-49  employee size  category, and  over  four  times
the reported 1983  net profits.  In  addition  to  these  costs, some  potentially  large
costs  of forthcoming  waste disposal  regulations  and  potentially  large  capital costs
associated  with  waste-minimizing  technologies  have  not been  included  in  the
estimates. These  figures  all  suggest that  some wood  preservers  may have  great
difficulty meeting environmental expenses.

     In addition to these  increased  annual costs, wood preservers may incur  major
construction costs to control  stormwater.  Although these regulations are still in  the
formative stages, the costs of some of  the  principal regulatory alternatives,  such as
constructing  roofs  or  wastewater  collection systems for  storage  yards,  have been
estimated to be $200,000  even for small facilities.  Capital costs of this magnitude
amount to  150% of the  median  equity of wood  preservers  with fewer than  10
employees, and  about 80%  of the median equity  of  those with  10-19  employees.
Should costs prove to be  as  high  as  the preliminary estimates indicate, small  wood
preservers would find it  very  difficult to meet these requirements.


Pesticide Formulating and  Packaging

     Pesticide formulating and packaging (PFP) firms handle many materials that are
considered toxic and may  present an environmental danger  if spilled.  Similarly, many
of  the wastes generated  from  PFP processes  are  considered hazardous.   Process
wastewaters from  PFP  firms may be contaminated with  the toxic  substances used
and/or with the hazardous wastes generated.   Finally, the  pesticides  produced  by
these firms are themselves dangerous and  subject to stringent labeling  and handling
requirements.

     The environmental regulations  that will affect PFP  firms directly  during  the
period  1988-1992 include  those concerned with the handling of toxic substances  and
hazardous  wastes as well  as  those governing the  handling  and labeling  of pesticides.
The PFP  plants  that currently discharge wastewaters into  municipal sewers also  will
be subject to categorical  pretreatment standards at some time in the future.

      The smallest PFP firms, those with 1-9 employees, will be exempt  from the most
costly regulation, Section  313 of SARA Title III, and  will have annual  costs of only
$2,560.  These firms should  have no difficulty meeting environmental  requirements.
PFP firms with  10 or more employees will  have to comply with Section  313 of  SARA
Title III and will  face  costs of $11,560 per year plus  increased waste  disposal costs
and an additional $6,680 in the  first  year of regulation.  They also  may  have  to
replace some of their labels at a cost  of  $1,000-$2,000 each.  Although  the capital
costs are relatively low, the annual costs are about 37% of median  net profits of PFP
firms with 10-19 employees,  and about  200% of the  net profits of firms at the  lowest
quartile level.  These figures suggest that  some PFP firms  with 10-19 employees  may
have difficulty meeting the requirements.  Unlike firms in other industries, small  PFP
firms  may have the  option  of discontinuing  some of their  operations  rather than

                                       3-10

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closing, if they cannot afford to meet these environmental requirements.

     PFP firms will  be subject not only  to the current and  forthcoming regulations
that are covered in this  study, but also to the  continuation  of and possible changes
in the many existing regulations that  govern the manufacture, distribution, and use
of  pesticides.  Firms in the pesticide industry are subject  to  many environmental
product regulations as well as regulations governing the discharge and disposal of
residuals.   Regulations  governing  the registration and labeling  of  pesticides, for
example,  already are  a major  factor in  the  PFP industry.   EPA  is  considering
changing many of these existing regulations, which may have a more profound effect
on  the PFP  industry than the regulations covered in this study.


Farm Supply Stores

     Many  farm supply stores  handle pesticides, with  the  resultant environmental
dangers  in  possible spillage.  For those firms that offer pesticide application services,
the mixing and  use  of  these pesticides require stringent handling procedures  so  as
not to contaminate  the environment.   In addition,  those farm  supply stores that
provide  fuels are concerned with potential spills and  leaks from underground storage
tanks containing gasoline or diesel fuel.

     Which environmental regulations  affect farm supply stores directly depends upon
whether the stores handle pesticides and/or sell gasoline or diesel fuel.  Farm supply
stores  that  handle pesticides will be affected by new  pesticide regulations concerning
farmworkers  and  groundwater.   For those farm supply  stores  that  also  provide
petroleum products,  the  underground  storage tank  technical  standards and financial
responsibility  requirements  will apply.  Farm supply stores  will also  be affected  by
reporting requirements for toxic chemicals and  by restrictions on the land disposal of
hazardous wastes.

     A  farm  supply store  with  fewer  than  ten employees,  that  does not handle
pesticides and does not sell petroleum fuels, would have no costs associated with the
major regulations.  A farm supply store that handles pesticides would face increased
annual costs of  approximately $2,100  and would have first-year costs  associated with
the farmworkers regulation of approximately  $9,000.  These  annual  costs amount to
approximately 5% of annual net profits.   The first-year  costs amount  to about  2% of
the average store's  equity.   These  figures suggest that farm supply stores  that  do
not sell  petroleum  should  be  able  to   meet  environmental requirements  without
difficulty.

      A  farm  supply store  that  sells  petroleum fuels would have  increased  annual
costs of  approximately  $4,765,  plus  capital costs and  additional first-year costs  of
approximately $11,900.  These  annual costs  amount to about  11%  of annual net
profits.   The capital  and  first-year  costs amount to  approximately 3%  of  equity.
Again,  these  figures  suggest  that  farm supply  stores  should  be able to  meet
environmental  requirements  without  difficulty.    Farm supply  stores  that  store
petroleum or chemicals  in underground storage tanks, may find that  their tanks are
leaking,  however.   In  this  event,  they  would  face corrective  action  costs.   If
groundwater   contamination  or  other  serious  damage  must  be   repaired,   these
corrective  action costs  could exceed $100,000,  and thus could exceed the equity  of
the smallest farm supply stores that are in less than average financial condition.

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Interstate Trucking

     Environmental concerns associated with the trucking industry include potential
spills and leaks  from underground storage tanks (USTs) containing diesel fuel or used
oil.  If a trucking  operation performs  its own  maintenance, then it uses solvents for
degreasing parts.  Waste disposal problems would involve used oil and  spent cleaning
solvents.  The used  oil might be put  into  USTs  or into drums.  The washing of
trucks is done with chemicals  and steam cleaning, creating wastewater  runoff.  For a
tank truck, the  "heel,"  or  what is left in the tank after draining the  previous haul,
must be steamcleaned out  and perhaps  handled as a hazardous waste.   Small trucking
companies usually have these cleaning functions performed by outside services.

     The principal environmental  regulations that  will affect the interstate trucking
industry during the  period  1988-1992  are those  intended to  secure the  underground
storage of fuel and correct any damage caused  by leaks.  These regulations will apply
only to those firms that store petroleum fuels on  their  premises or store waste oils
in USTs.   These  are  generally   only  the  larger  trucking  companies.    The  other
environmental regulations  that will affect the  interstate  trucking industry will do so
indirectly, increasing the price of  trucks, fuel, or waste disposal.

     Because  the most  costly regulations will affect  only the larger firms, interstate
trucking  companies  should  be  able  to manage  the  costs  of the  environmental
regulations  included  in this study.  The costs of approximately  $3,200  per year for
UST  and  waste-oil  regulations represent  about  7%  of  the  annual  profits  of the
smallest companies likely to be affected by  the regulations.  The required  investment
of $3,000 to upgrade  each UST represents about 2%  of their net worth.

     Trucking companies that find that their USTs have been leaking  will face much
higher  costs, however, possibly  exceeding $100,000.    EPA's  experience  to  date
indicates that 15 percent  to 20 percent of the USTs may be leaking.  Some of these
firms with leaking USTs may be unable to afford the  required corrective actions.
Gasoline Service Stations

      Environmental concerns at gasoline service stations include potential  spills and
leaks from  USTs containing gasoline, diesel fuel, and/or used oil, and vapor emissions
from the handling of gasoline.   Waste disposal  problems at  retail  gasoline  outlets
involve used oil and spent cleaning solvents.

      The principal environmental  regulations that will affect gasoline service stations
between  1988 and 1992  are  the  technical standards for USTs, and  the  financial
responsibility  requirements for the  owners  and  operators of USTs.   In  addition,
gasoline service  stations  in certain areas that are  not  attaining air quality standards
(e.g., St.  Louis)  will  be  required  to install air emission controls on the  nozzles of
their gasoline pump  hoses.  Other  EPA regulations that may affect retail gasoline
outlets include regulations pertaining to generators of small quantities of  hazardous
waste.
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     The  major  impact of  the  environmental  regulations  upon  gasoline  service
stations will depend mostly upon  the  status of the stations' USTs.  The cleanup of
even small releases  could place  the average  station in a poor or distressed financial
condition.  The cleanup of large plume  releases could result in  the  average station's
failure.  Fortunately, not all  firms will incur corrective actions,  and some  states may
use state  funds to  aid  small  firms  in meeting the costs of corrective  action.   The
capital  investments  required  by the environmental regulations  can  be  sustained by
most small  firms  if they are allowed several years  to  make the expenditures.  If,
however,  all  capital expenditures under all regulations must be met in  a two-  to
three-year period,  only the strongest firms are likely to survive.


Dry Cleaning

     Most of  the  environmental problems in the dry cleaning industry are related  to
dry cleaning solvents.  Over the years there has been a pronounced  trend  away from
the use of petroleum-based solvents and toward the use of perchloroethylene  (perc).
Over 84% of all dry cleaning facilities use  perchloroethylene.  Most  of the remaining
facilities  use   a   petroleum-based  solvent,  and  a   small  percentage  use  either
fluorocarbon  or  trichloromethane.    Environmental  problems  are  created  by the
evaporation of  these solvents and by the presence of these solvents  in wastewaters
and solid wastes.  Spent solvents and wastes contaminated by  solvents are  considered
hazardous.   Dry  cleaners  that use  petroleum-based  solvents generally store  these
solvents in underground  storage tanks, with the  consequent   environmental  risks
associated with spills and leaks.

     The principal environmental  regulations that will affect dry cleaners  during the
1988-1992 period will be those that control the evaporation of perchloroethylene from
perc dry  cleaning machines,  restrict the handling and disposal  of hazardous wastes,
and require the reporting of  toxic chemicals  stored on  premises.  Dry  cleaners that
use petroleum  solvents  will  not  be  subject  to  the  perchloroethylene  air emission
standards,* but  may be  subject to EPA's requirements for underground storage tanks.
Dry cleaners also  will be affected indirectly by a series  of EPA  regulations that will
impose  stricter  standards on  waste disposal  in general, and hazardous waste disposal
in particular.

     The most  expensive  regulations  will apply  to selected dry cleaners  -- namely,
perc dry cleaners that  have no  emission  controls (about  50%) and  petroleum dry
cleaners with  regulated underground storage tanks.   Unfortunately, the status  of
these two important regulations is  still  uncertain.

     Businesses in  the  dry cleaning industry are among the smallest  of  the  small.
Most dry cleaners have fewer than five employees, and average sales per employee
that are  less than  half the  national  average.   The median dry  cleaner  with 1-9
employees in  1983 had  profits of less than  $10,000 and equity  of less  than $40,000.
While  their  rate  of  return  on  equity  was  high,  the profit  available  to  absorb
additional costs is low.   Dry cleaners at the  lowest quartile  of  profitability in this
size category in 1983 had net  profits of only $5,000 and equity  of  only $8,000.
      * Air  emission  standards  for  petroleum solvents  may be  established during the
 1988-92 period, but for now EPA has deferred making this decision.
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     Should perc emission controls  be required of the smallest dry cleaners, current
estimates show they may have to invest $6,000 or more for the perc controls plus an
additional $4,300 for SARA and  RCRA and will face additional annual costs of up to
$2,800 to meet all of the regulatory requirements.  These costs amount  to about  35%
of the median annual net profits and about 33% of the median equity of dry cleaners
with  1-9 employees.  Dry cleaners  at the lower quartile level of this  smallest  size
category will have  to spend  about 60% of their annual net  profits and over 150% of
their  equity.  These figures  suggest that some  of the smallest  dry cleaners may have
difficulty  installing perc   emission  controls   in  addition  to  meeting the  other
environmental requirements.  The perc regulation is still under formulation with many
options under study, however, so that actual costs  for perc emission controls may be
much different than preliminary estimates.

     Dry  cleaners  with  regulated  underground storage  tanks will  have to  invest
approximately $7,300 to upgrade their tanks* and meet the  additional first-year costs
and will face additional annual  costs of approximately $3,700.   These costs amount to
about 40% and 19%, respectively, of the median annual net profits and  equity of dry
cleaners in the smallest  size category.  Dry cleaners at  the lower quartile level of
this size category will have to spend about 80% of  their annual net profits and about
100% of their  equity.  These figures suggest that  many of the smallest dry cleaners
will have difficulty meeting UST standards.  If their underground storage  tanks are
found to  be leaking, these dry  cleaners will face  much larger costs to complete the
required corrective actions.  These costs  could average  over  $50,000  and at times
could  exceed $100,000.  Such   costs  would exceed  the equity of the  average  dry
cleaner even in the 10-19 employee size category.  Many small dry  cleaners will not
have  the resources to pay for such large corrective action costs.
Photofinishing Laboratories

     There are  five  major  chemical  processing  steps that  are  generally used  in
processing color film or paper: developing, stopping development,  bleaching, fixing,
and stabilizing.   The developing solutions  contain silver, a  hazardous but  also  a
valuable material.  Some of the other solutions used in photofinishing processes, such
as  ferrocyanide  bleach, are also hazardous.   The  silver and hazardous  solutions are
potential sources of  environmental problems,  if  they are  allowed to contaminate
wastewaters or other wastes.

     Because  silver is a valuable metal, photofinishers recycle  and reclaim the silver
so  that they generate little or  no silver-containing wastes.  Small  photofinishers also
avoid  generating hazardous wastes by using nonhazardous  bleaching  solutions, such as
iron EDTA.  Finally,  photofinishers that process  1,600  square feet of film  or  less
each day are  exempt from EPA's effluent limitations for  wastewaters.  Consequently,
most small photofinishers  have no substantial  environmental problems and will not be
affected directly by any of the environmental  regulations covered in this study.
       These costs assume that  USTs  containing  petroleum solvents are regulated as
 petroleum USTs.   If they  are  regulated, instead,  as chemical  USTs, dry  cleaners'
 upgrade costs will be greater.
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Water Supply

     The water supply industry consists of both publicly owned and privately owned
water supplies.   Publicly  owned  water supplies are  predominantly owned by  local
municipal  governments,  although a  sizable  number  are  owned  by  the  federal
government.   Privately  owned  systems that serve  large  populations  are  usually
investor-owned entities.  Privately owned systems that serve smaller populations tend
to be owned  by  real estate  developers, homeowners associations,  or mobile  home
parks.

     Unlike  most industries  that EPA  regulates,  water supply  companies  do not
discharge   pollutants or   produce hazardous substances.    Instead,  water  supply
companies  produce  a product, drinking water,  that is itself considered to be  an
element of the  environment.   Consequently, EPA's regulations  for water  supply
companies  are similar to product specifications. Instead of establishing standards for
the  maximum  discharge   of  pollutants,  most drinking water regulations establish
standards  for the maximum level of contaminants permitted in  the water that  these
systems supply to their customers.

     Water supply systems are regulated under the  1974  Safe  Drinking  Water Act
(SDWA) and the  1986 Amendments to the Act.  Under the  1986 Amendments, EPA is
required to promulgate National Primary Drinking Water Regulations (NPDWRs) for 83
specific  contaminants.     The  SDWA  requires   that  regulations for  these  83
contaminants, as  well as  other regulations  discussed below, must be adopted  on a
very stringent schedule -- by June 19,  1989.  In addition to the tight EPA regulatory
schedule, NPDWRs must officially take effect at the state  level  within 18 months of
promulgation, assuming the state fulfills primacy requirements.

     Three other provisions of the SDWA are likely to have significant impacts on
the  drinking  water  industry.   EPA is required  to specify  conditions under  which
public water systems served by surface water sources are required to install filtration
as  a treatment   technique.   EPA  is  also  required  to  promulgate NPDWRs  for
disinfection  as  a treatment technique  for  all public  water  systems.  Further, the
SDWA  mandates  EPA  to publish regulations that  require public  water  systems  to
monitor for a  number  of "unregulated" contaminants at least once every  five years.
To help small systems comply with the disinfection requirement and the "unregulated"
contaminants monitoring  requirement,  the SDWA  authorizes  funds for EPA and  the
states  to  provide  assistance  to small  systems.    These  funds have  not  been
appropriated.

     Although the  environmental requirements  for water  supply systems  will be
expensive, compliance costs ultimately will be reflected in increased rates and borne
by  customers.    Due to  often  inadequate rate  bases,  small  systems  ~ particularly
those that  serve  fewer  than 2,500 people -- and  their customers  face the greatest
difficulty  in financing the necessary compliance activities.

     Water supply systems will have to monitor their water for a  greater  number of
contaminants than is currently required and install appropriate treatment equipment
if contaminants  exist at  unsafe levels.   Some small systems  will most likely have a
significant number of violations until adequate treatment is in place; therefore, public
notification of violations  will be an additional expense.

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     Recognizing that small systems may be limited  in  their ability to comply with
the new regulations, EPA is attempting to minimize  the  economic impact on small
systems where possible without reducing the protection of  public health.  The SDWA
provides an exemption procedure  that allows water supply companies additional time
to meet the new standards,  provided that the water being delivered in the interim
does not  present  an unreasonable  risk to health.   It  is expected that  exemption
procedures will  be used  primarily  to assist small supplies in achieving compliance.
Water  supply  systems serving  less  than  500  service  connections,  or  approximately
1,500 people,  are  eligible  for extendible two-year  exemptions.    These  extendible
exemptions  may  be granted based  upon  the  need for  "financial  assistance for the
necessary improvements,"  unless there is  an unreasonable risk to health.
CONCLUSION

     Although the list of  EPA's 85  regulations appears to be  foreboding,  a  closer
examination  reveals that seventy percent of the 3.5 million  small  businesses in the
United  States  are  in  sectors of  the  economy that produce  little  or  no pollution--
wholesale and retail  trade, finance, and services.  Most of these businesses  will not
be affected directly by any of the 85  regulations.  Small businesses that  contribute
to environmental problems  will incur  additional costs to comply  with the regulations,
however, and in some industries the costs may be high.

     This study examined the effects  of environmental regulations on small businesses
in nine  industries judged  likely  to  experience  high compliance  costs.  The study
found that  costs may  be  high  for  small businesses  in three  of the industries--
electroplating, wood  preserving, and  pesticide formulating and  packaging.  If costs
prove to be  as high as  estimated and cannot be passed on to consumers, some small
businesses  in these industries may  be forced  to  discontinue part of their  operations
or to close.  Some small dry cleaners  that have underground storage tanks or require
substantial  perchloroethylene  emissions controls may  also  have difficulty meeting
environmental requirements.   In addition,  certain  gas stations, trucking firms, and
farm supply stores with leaking underground storage tanks may face corrective action
costs beyond their financial  means.  Small private water supply companies  are  in  a
unique position, in that they operate as utilities and generally  can pass costs on  to
their customers.  While  these firms  would not be expected  to  go out of  business,
high environmental costs for water supply  companies that fail to meet new  drinking
water  standards  may  necessitate   large  increases  in  household  usage   fees.
Environmental costs  for one of the industries studied -- photofinishing laboratories-
- were found to be negligible.

      While some small businesses will incur additional costs  because of environmental
regulations,  those  small businesses that help  to solve  environmental  problems will.
experience an increased demand for their services.   Small  businesses that provide
analytical,  engineering, or construction services, for  example, might  be included  in
 this category.  The potentially stimulating  effects of environmental regulations  have
not been included in this study.

      The  regulations that  appear to  be most often responsible for  high costs in the
 industries studied are those  covering the handling and reporting of toxic chemicals;
 the handling, treatment,  and  disposal of  hazardous  wastes; and  the operation  of

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underground storage  tanks.  Although costs estimates are available for only some of
these  regulations,  those that are available  indicate that  the regulations will affect a
large  number of  firms  in many industries  and  may entail  costs in  the $5,000 to
$10,000 range.   Although  these costs  may  be managed easily by  small businesses of
moderate  size,  they present  difficulties for the smallest of the small businesses.  It
is these very small businesses that comprise  the majority of U.S. businesses.

     This   relationship   between   environmental  damage  and   pollution  control
expenditures is  an  important  element  that  must  be  included  in  this discussion.
Environmental regulations are  created to  reduce  the risk to  human health, welfare,
and the environment from pollution and  hazardous substances.  Any discussion of the
adverse impacts of these regulations must be balanced by a discussion of  the benefits
that are  generated  by these same  regulations.   Cleaning up sites contaminated by
hazardous waste disposal or leaking underground storage tanks reduces the exposure
of individuals to carcinogens, reclaims and  prevents further contamination of drinking
water   supplies,   and  restores  property  values.    Controlling   the  emissions  of
perchloroethylene from dry cleaning machines reduces both ambient and  occupational
exposure  to a  carcinogen.   All  of  the  industries studied  that  will experience
significant  adverse  impacts  because of environmental regulations are industries  that
produce  substantial  environmental risk.   To   the  extent  permitted  by  law,  the
regulatory process at EPA includes balancing the costs and impacts of environmental
regulations with the benefits produced by reducing these  environmental risks.
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                                    Chapter 4


                                 AGRICULTURE
     Environmental regulations  affect U.S. farms in many ways.  Traditionally, the
most important of these  regulations have been those that  restrict,  and in some cases
prohibit,  the  use  of certain pesticides.  Pesticides will continue to be the subject of
the  most  important  environmental  regulations for  agriculture,  not  only of  the
traditional  registration  and  use  regulations,  but also  of  new regulations  requiring
health and  safety precautions for  farmworkers using pesticides, controls on the use
of  pesticides  in areas with  vulnerable groundwater or near targeted estuaries,  and
restrictions  on  the use of  pesticides that  threaten endangered species.   In addition,
other proposed and forthcoming environmental  programs  affect  agriculture.   These
include the banning of  lead in  the gasoline used in  farm vehicles, the control of
stormwater  and other runoff  from agricultural lands, restrictions  on agricultural
burning,  standards for  the operation  and  repair  of underground  storage  tanks
containing petroleum and chemicals, and the reporting of toxic chemical use.

     This study examined the cumulative  impact of recent and proposed future EPA
actions  on  the financial condition  of  farms  in  the United  States.   The actions
included  in  the analysis  are those that  have been  promulgated  since  1982  or are
anticipated  to take place by 1992, and have a direct  impact on agriculture.   The
primary  goal  of  the  study  is  not to  determine the  aggregate  total  cost of  EPA
actions  on   agriculture,  but to  examine the  impact   of  these  actions  on  the
profitability  and  survivability of  U.S.  farms.   Because  of  the complexity of  the
agricultural  sector  and  the many  uncertainties   that  still  accompany  the  new
environmental  programs, . this ' study  has   had  to   limit  its   focus   to  a   few
"representative" farm  types and  has had  to  make  many  assumptions  about  future
environmental requirements and other factors that  will affect farms, such as farm
support programs  under  the  Food  Security Act.  Accordingly, the study  cannot be
considered to  cover all potential agricultural impacts or to present  the final word on
future environmental programs.  It  does, however, describe the kinds of effects that
may occur and estimates the range  of potential impacts upon a group of farms that
are likely to  experience  relatively  large  environmental costs.  The study  does  not
address  the   yield and  quality  increases  associated  with  environmental  quality
improvements.
       The  Agriculture Sjectpr  Studv:  Impacts  of Environmental  Regulations  on
Agriculture: prepared for the U.S. Environmental Protection Agency, Office of Policy,
Planning and Evaluation by  Terry Dinan of EPA, and  Craig Simons and Roger Lloyd
of Development Planning and Research Associates, Inc.;  September 1988.

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AGRICULTURE AND ENVIRONMENTAL REGULATIONS

     There are a number of environmental and health hazards that may be associated
with agricultural production.  These include:

           1.   Surface Water Pollution

               Water running off  farmlands may carry soil particles,
               fertilizers,  pesticides,  and  animal  wastes into  the
               surface waters.

           2.   Groundwater Pollution

               Pesticides and sewage  sludge applied to  fields  and
               crops,  as  well   as petroleum  and chemicals  from
               leaking underground storage tanks,  may seep into the
               groundwater.

           3.   Air Pollution

               Air  pollution problems  may result from  agricultural
               burning practices and from the use of leaded gasoline-
               powered trucks, tractors, and combines.   In  addition,
               increases  in  tropospheric  ozone  can  decrease  crop
               yields.

           4.   Worker Exposure

               Farmworkers  who handle pesticides may be exposed to
               the harmful effects of these chemicals.

           5.   Endangered Species

               Endangered species may  be exposed to  the  harmful
               effects of  pesticides applied  to  fields and crops in
               their habitat.  Another threat is  a reduction  in  their
               habitat caused by agricultural expansion.

           6.   Dietary Risk

               Pesticide  residues may  remain on agricultural products
               that reach the consumer.

     Pesticides play a role  in most of  these hazard pathways  and are a  critical focus
of  the  environmental regulations  that affect agriculture.  Every pesticide  must be
registered with EPA's Office of Pesticide Programs (OPP).  OPP reviews the health,
safety,  and environmental  effects of these pesticides  and, from time to time, issues
regulations  that  restrict  or prohibit the use of certain pesticides that are judged to
present  an  unreasonable  adverse  effect.   As  mentioned  above,  EPA  also issues
regulations  controlling the runoff of  waters from agricultural  lands, the operation
and repair of underground storage tanks, and many other agricultural activities that
may present environmental  hazards.

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     These  regulations affect both  large  and  small farms  in the  United States.
Restrictions on  the  use of certain  pesticides  may  require  the  substitution  of  more
expensive pesticides  and/or may  reduce  crop yields.  Other environmental regulations
may impose  extra operating costs  or  may require additional  investments  in  land
preparation or farm  equipment.

     The ability of farms to comply with these environmental  regulations will depend
not only on the costs of each regulation and the effects  of  the required activities on
agricultural yields,  but also  on  the financial condition of each farm, the market
conditions  at  the  time the regulations  become effective, and the  number  of farms
that are covered.    While  some  environmental regulations apply to  all farms, most
apply to only a portion of  all farms, such as those that use a certain pesticide or
have underground storage tanks.

     Although the average net farm income  in  1984 was identical to that in 1971 —
$12,000  in  constant  1986  dollars  --  the financial condition  of  U.S. farms  has
fluctuated  dramatically over the  past two  decades.  Higher prices, expanding exports,
and low real  interest  rates combined  in the early  1970s to produce not only record
farm incomes ($25,300 average in 1973), but  also a rapid expansion  in agricultural
production.   Unfortunately,  these  trends  all reversed  in  the  early  1980s.   Prices
declined, exports  decreased, and real  interest rates  rose at  an unprecedented rate.
Average net  farm income  fell to a low of $10,200 in 1981 and did  not surpass the
$12,000  level  until  1985.  Declining incomes  led  to  declining  farmland values  and
increasing  debt-asset ratios.   Recently,  this trend  has begun to change.  Decreased
production expenses, increased government payments, and  lower interest  rates have
allowed  net incomes to rise  to an average of  $14,000 and have  slowed the decline in
farmland values.  The average debt-asset level in  1987 is expected  to show a decline
from 1986.

     Trends  for the average farm may  belie  significant  differences within farm size
categories  and  types.   During  the 1982-1985  period,  farms producing  vegetables,
melons,  and  other  specialty  crops enjoyed   average incomes of  $60,000  per  year.
These farms, however, account for  only  a small  portion  of all   farms.   Farms
producing  cash grain, tobacco,  cattle-sheep-and-hogs, general livestock, and animal
specialties  all had  average incomes  of less  than $10,000 per  year.   These farms
account for 70% of all farms and nearly 50% of farm marketings.

      The  financial  condition of a  farm, and  hence  its ability to  comply with
environmental regulations, may  vary dramatically, even within size categories and
types of farms.  For  example, a study  of the financial  characteristics of  U.S. farms
in  1985-1986 showed  55% of all commercial farms were  in a favorable  financial
situation, while 39% were in a marginal situation, and 3% were financially vulnerable.


STUDY METHODOLOGY AND LIMITATIONS

Study Methodology

      This  study consists of  an  in-depth  examination of the cumulative impact of
environmental regulations on selected livestock, major field crop, and specialty crop
producers.  The approach of  examining only a limited  set of  producers was chosen
because the primary goal of determining the cumulative impact of EPA actions on the

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financial condition of producers requires an extensive  amount of data collection and
analysis. The approach followed in this study is summarized as follows:

        1.  Select  a  subset  of livestock, major field crop,  and specialty crop
           production to study.

        2.  Define alternative scenarios of EPA policies.

        3.  Estimate  price  changes resulting  from  EPA actions (under each
           scenario) for each of the selected crops and livestock.

        4.  Examine the  change in the financial condition of "representative"
           producers of  each of the selected crops and livestock under each
           scenario.

     Crop and Livestock  Selection

     A crucial step  was  determining which farms to study.  An effort was made to
include those farms that were likely  to experience relatively large  impacts under the
alternative EPA policy scenarios considered.  The  cases examined,  therefore, provide
a variety of impact levels,  but include worst-case examples.  For livestock and  major
field crops, three specific farm types were examined:

                     * an Illinois  corn soybean farm,
                     * a Mississippi cotton soybean farm, and
                     * a Kansas cattle wheat farm.

     Through  discussions  with staff  at EPA's  Office of  Pesticide Programs, the
following set of specialty crops was selected:
                      * apples,
                      * tomatoes,
                      * potatoes.
                      * peas,
                      * caneberries (e.g., raspberries, blackberries, etc.),
                      * peanuts.
                     * peanuts,

There proved to  be insufficient information to complete the analysis for caneberries
and  peanuts,  however, so that results are available  only for apples, tomatoes, peas,
and  potatoes.  The  difficulty  in  obtaining  information about producers of specialty
crops was itself a significant finding of the study.

     Definition of Policy Scenarios

     Because it is difficult to predict  future EPA decisions  for many regulations, the
study examined  three alternative  scenarios corresponding  to a  range of potential
policies. The scenarios can be  summarized as follows:

        SCENARIO 1:     Past and current EPA actions,
        (conservative)      plus a conservative (low-cost)
                           set   of   assumptions  about
                           future actions.

                                        4-4

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        SCENARIO 2:      Past and current EPA actions,
        (intermediate)      plus  an  intermediate  (mid-
                           cost)   set  of   assumptions
                           about future actions.

        SCENARIO 3:      Past and current EPA actions,
        (expansive)        plus an expansive (high-cost)
                           set   of   assumptions   about
                           future actions.

     Actions that EPA has taken in the past five years or plans to take in the very
near future were included in all three scenarios.   These include the cancellation of
toxaphene, dinoseb, and chlorodimeform used for yield enhancement;  restrictions on
the use of alachlor;  farmworker  protection standards;  regulations under Title  III of
the Superfund Amendments and Reauthorization Act; and leaking underground storage
tank regulations.   In addition,  the three  scenarios include  alternative assumptions
about  EPA actions in the following  areas:  fungicides,  corn rootworm insecticides,
broad spectrum organophosphates, grain fumigants, pesticides in groundwater strategy,
and  lead  in gasoline restrictions.  In general, the higher-cost  scenarios include more
pesticide  restrictions  and cancellations  than the lower-cost scenarios.   Scenario  3
includes the elimination of lead from gasoline  for agricultural use, while scenarios 1
and 2 do not.

     Because several of the environmental regulations  studied  will not affect  all of
the  farms in any  category  equally,  the  study examined two variations  for each
scenario:
          *  Average  Impact  Case:    This  case  assumes  that  the
             producer  experiences  the  average  impact of producers of
             that  type -  e.g., if  10 percent of Illinois corn  producers
             would experience a  cost  of  $1,000, the average  affected
             producer would  experience a $100 cost ($1,000 x 0.1).

          *  Maximum  Impact   Case:   This  case  assumes  that the
             producer  must  meet  all  of the  requirements  of every
             regulation that may possibly affect producers of that type.

     Estimation of Price Changes

     The next step  in the analysis  was to translate  the  effects of  the  regulatory
scenarios on crop production costs and  yields  into  commodity price changes.  In
general, when  production costs  increase due to  the  costs of meeting environmental
regulations and yields  decline due  to restrictions on pesticide  use, commodity  prices
will rise.  Failure  to account for these price increases  would result in overestimating
the impacts of EPA actions on producers that  are  directly affected by those actions
and would overlook  the  potential  gain to those producers  who are  not directly
affected by the regulations.

     To predict  the price changes  on livestock and  major field crop producers, the
study  used a  regional  econometric-simulation model, AGSIM.   A much more limited
price-quantity  model  was used  to predict  price  changes for  specialty crops.   The
specialty crop model does not  account for variations in impacts  among different
regions or for the impact that EPA actions might have on substitute crops.

                                       4-5

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     Impacts on Producers' Financial Conditions

     Because  the  information  available  on  producers  of  major  field  crops  and
livestock was more extensive than that available for producers of specialty crops, the
study  used  different  methodologies  to  estimate  the  impacts  of  environmental
regulations on producers' financial conditions. The study of the impacts on specialty
crop producers was necessarily much more limited than that for the major field crop
and livestock producers.

     To  examine the impact of EPA  policies on  producers  of major field crops and
livestock, the  study used a whole farm financial  simulation model  of representative
producers, REPFARM, developed  for each  of  the selected  producers by  the  U.S.
Department of Agriculture.  Producers' financial  conditions were simulated  for the
1987-1996  period  under  a  base  case  (assuming no EPA actions  over the next ten
years)  and  under each  of the policy scenarios  and  impact cases  described above.
(Note that although EPA actions  occurring  over the period  1982-1992  were  included
in this study,  the forecast  period  of 1987-1996  was chosen to illustrate both the
effect  that past  actions  have  on producers' income  and how the  effect of actions
that are taken change  over time.)  For each type of producer, the study simulated
the impacts on farms in  two different financial  situations: (1) farms in the  average
financial condition of all farms of the type/region considered --e.g.,  the  average  of
all Illinois corn soybean farms, and  (2) farms in the average financial condition of  all
"vulnerable" farms of the type/region considered.  Vulnerable farms were defined  as
farms  with a debt to asset  ratio of greater  than 0.4 and a negative  net cash  income.
The  impact of EPA policies on these producers'  income and their ability to survive
was  determined by  examining changes in net cash farm income* and debt  to asset
ratios.   It was assumed that a producer would go out of business whenever  its  debt
to asset ratio reached one — i.e., its level of debt became equal to its assets.

     The impact  of EPA  actions  on specialty   crop  producers  was estimated  by
examining the  change in net returns  per acre for  producers in different production
regions.  Net returns per acre, as  used in this study, are equal to farm income minus
all  farm  expenses  on a  per  acre  basis,  with the  exception of  land and non-hired
labor.   Net returns  per  acre, therefore,  is  a measure  of  the  returns to land and
farmer-supplied labor.   Budget information was  collected  for  each of the  selected
specialty  crop producers in  several  different  production regions  to  establish   a
baseline  level of net returns.  The  specialty crop  budgets for each  region were then
projected over the 1987-1996  period, using  the average and maximum impacts for
each  region under each policy  scenario,  along  with  the scenario-specific prices
(determined by the national price-quantity model).

Study Limitations

     As  explained above, the  complexity of  the agricultural sector, the uncertainty
associated with many environmental regulations,  and the lack of  information on the
financial conditions of producers of some crops resulted in the  study's being limited
to representative  farm types and  having to  rely on  many simplifying assumptions.
Each of  the study's major limitations is discussed in more detail below.
       Net cash farm income is defined as cash farm income minus cash farm expenses.
It does not include depreciation of machinery or  off-farm income.

                                       4-6

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     Examination of a Limited Number of Commodities

     Producers  of  crops  not considered  in  this report will  experience  levels  of
impacts that are  different from those reported.   An effort was made, however, to
include in this  study farms that are  expected to  experience relatively large impacts.


     Limited Information About Producers* Financial Conditions

     The  initial financial condition of a farm is  a crucial factor in determining the
effect that  EPA actions will have on the farm's financial health.  For livestock and
major  field crop producers,  the  study examined  two alternative  financial positions.
Only limited  information  was  available, however,  on  the  financial  conditions of
specialty  crop  producers.    This made it difficult  to  determine whether the  EPA
actions assumed in  the alternative  scenarios would actually cause any  specialty crop
producers to go out  of business.

     Uncertainty About Environmental Regulations

     As discussed  previously,  this  study  does not  presume  to accurately predict
future  EPA  actions.   Rather,  it  attempts  to   define  a  range  of  impacts  that
correspond  to plausible  alternative policy scenarios.  In addition, this study does not
account for possible indirect impacts  on agricultural producers (through regulation of
agricultural input  industries),  nor does it  account for  actions  taken at the  state
level.

      Uncertainty About the Incidence and Magnitude of Impacts

      Predicting which producers will  be required to comply with which environmental
regulations requires an extensive amount of information.  For example,  if a particular
pesticide  is  to be  canceled,  detailed  usage data  are  required  to  predict  which
producers will  be affected.  Pesticide  usage data based  on statistically valid samples
for  major field crops are  available at state and  multi-state  production region  levels.
However, data  that are  not based on statistically valid samples  had  to  be used for
the  county-level usage estimates  necessary  to model  the  effects of  pesticides in
groundwater.

      Predicting the incidence  of EPA actions  on specialty  crops  was especially
difficult, because there is less information about pesticide usage on these crops  than
for  major  field crops.  Much  of the specialty crop data used in this analysis were
derived from  private agencies  that do not  provide  information  on the  sampling
techniques  used.   This  lack of  reliable  information  most  be  kept  in  mind  when
viewing the results  for specialty crops.

      In addition to knowing what types of producers are likely to  be  affected by
each EPA  action,  it is important to determine the extent  of the impact.   For a
pesticide cancellation, this requires knowing what alternative will be used in  place of
the  cancelled pesticide and what cost and/or yield variations the user will experience
with this alternative.   These efficacy data  are  not always readily available.   This
increases the uncertainty  associated with predicting  the  yield effects of EPA actions.
Furthermore, there  was  not sufficient information  to  fully  account  for changes in
quality (e.g.,'size, shape) brought about by restrictions in pesticides.

                                        4-7

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     Finally,  impacts of  pesticide cancellations  are  projected  to dissipate  evenly over
a seven-year  period,  as  users  adjust their  practices  and  as  new pest control products
become available.   The  use of  an  arbitrary assumption  of  this type was necessitated
by  the lack  of a  reliable method  for  predicting  the development  of  substitute pest
control products and  the  adjustment  of  agricultural  practices over  time.   Clearly,  this
assumption  may  overestimate  the  adjustment  process  for  some  cancellations  and
underestimate  it for others.   Some  commodities, such  as  apples and  oranges,  are  less
able  to  adjust  to  pesticide  cancellations   through  the  use  of  more   pest resistant
species due   to  the  long  term  structural   adjustment problems  associated  with tree
removal and replacement.

     Model Assumptions

     In  addition  to assumptions  about  the incidence   and magnitude of impacts,  the
models themselves   use   assumptions  that   affect  the  results.    For   example,  the
assumptions about  how  producers  respond  to  changes  in  production costs  and how
consumers  respond  to changes in food  prices  are  crucial  in determining  the extent to
which  EPA impacts are  passed  on  to consumers in the  form  of  higher  prices.  For
livestock   and   major  field  crops,   numerous  assumptions   about  future   prices,
government policies,  interest  rates,   and  cost   and  yield  trends   affect  the  baseline
projections  of  net cash  farm  income  and  debt  to   asset  ratios  obtained  from  the
REPFARM models.   If  these assumptions  result  in  an  overestimate  of  the financial
strength  of the representative farms in  the baseline,  then we  will  overestimate  the
ability  of  producers  to  survive  in  the face  of  EPA  actions.   Likewise, if these
assumptions result  in an   underestimate  of  the  financial  strength  of the  farms, then
we  will underestimate the ability of producers to bear the  costs of EPA actions.
IMPACTS ON LIVESTOCK AND MAJOR FIELD CROPS

     This  study  examined  the  impact  of EPA  actions  on  an  Illinois  corn  soybean
farm,  a  Mississippi  cotton  soybean  farm,  and  a  Kansas  wheat  cattle  farm.    The
modeling   of  three  regulatory  scenarios,  two  regulatory  impact   cases,  and  two
financial  conditions  for  each  of these  representative farms  resulted in  18  sets  of
output  for  each  farm  type.    This summary  presents the  results first  for farms in
average  financial  condition  experiencing  average  environmental  impacts,  then  for
farms   experiencing  maximum  environmental   impacts,  and  finally   for  farms  in  a
vulnerable financial  condition  experiencing average  environmental impacts.   Only  the
results  of Scenarios  1   and  3  (the  conservative  and expansive  regulatory  scenarios)
are  presented,  illustrating a  range  of  financial  effects  predicted based  on the  full
range of policy scenarios considered in this study.
                                                                                     i
Farms in Average Financial Condition

     Tables  4-1 and 4-2 present the results  of  the  modeling  effort  for  farms  in an
average  financial  condition   and  expected  to experience  the  average  environmental
costs and yield reductions  for their  farm type.   Table  4-1  presents  the estimated
changes  in  net  cash  farm  income   (NCFI)  and  Table  4-2  presents the  estimated
percentage changes in debt to asset ratios (D/A) for farms.
                                          4-8

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     As  can  be  seen  from  these  tables,   the  estimated  impacts  of  environmental
regulations  vary depending on  the  type of  farm,  but  in  general  are small  for  the
average  impact  cases.    Under  Scenario  1,  the  average  impacted  farms  experience
mean annual decreases in net cash farm income (NCFI) ranging  from less  than 1%  for
the  Illinois  corn soybean  farm  to  3%  for  the  Mississippi cotton  soybean  farm  and
Kansas wheat cattle farm.

     A  reduction  in  farm  income  due  to  EPA  policies  may  result  in   increases  in
farmers' debt  to asset ratios in  two  ways:  (1) it  decreases the  return  to  land and,
therefore,  the  value  of land (which  is  the primary  component of  farm assets), and (2)
it  may  cause  farmers  to  borrow  funds  if  they  are  put  into  a  position  of  negative
cash flow.   As  shown in Table  4-2, none of  the  changes in income brought  about by
EPA  actions under  the  average  impact case  are  large enough  to result  in  significant
changes  in  the representative  farms1   debt  to asset  ratios.    In  all  of   the average
impact cases, the change in the debt to asset ratio is less than l%.

     Under  Scenario  3  (the  expansive  regulatory  scenario)  for  the  average  impact
case,  the  cash  income  of  the  Mississippi  cotton  soybean farm  decreases  less  than
under  Scenario 1,  and  for  the  Illinois  corn  soybean farm and the Kansas  wheat cattle
farm,  the net  cash  farm incomes actually  increase.   This occurs  because  the  larger
cost and yield  changes  incurred  by the affected  farms  result  in  reduced production
levels  overall  and lead  to  higher  prices.   These higher  prices  more  than  offset  the
average  cost and  yield impacts  experienced by  farms.    Higher  prices  come about,
however, due to decreases in the production of the commodities of interest.

     Although  the  average  impact  cases result  in  minor  losses  or  even  increases  in
NCFI,  farms  that experience  the  maximum  environmental  costs  and  yield  reductions
would be  adversely  affected.   In the  maximum  impact cases,  the  study  assumed that
the  farms  would  experience  the   cost  increases  and yield  decreases  associated  with
each  environmental  regulation   that  could  possibly  affect producers  of  their type.
The maximum impact  cases  include,  for  example,  costs  for  the underground  storage
tank  regulations.  The  potential  costs  associated  with this regulation are  substantial,
yet  only a  small  percentage of farmers are  affected.*    The  maximum  impact cases
also  include  the  yield  decreases  associated  with   pesticide   cancellations,  such  as
dinoseb  and toxaphene for  Mississippi  cotton soybean farms.   While  few  farms will
experience  the impacts of  all  regulations,  the  study  examined  these  cases to put an
upper bound on environmental costs and impacts.

     Under  the  maximum  impact  case of  Scenario  1,   farms  in average  financial
condition experience  mean annual  decreases in net  cash farm income ranging  from 8%
for  the  Illinois  corn  soybean farm to   18% for the  Mississippi  cotton  soybean  farm to
24% for the  Kansas  wheat cattle farm.   Under  Scenario  3,  these figures  are even
larger: 26%, 24%,  and 84% respectively.  The average increases  (1987-1996) in debt to
asset ratios  are also several  times larger  in the  maximum impact  cases  than in  the
average  impact cases.   Under  Scenario  3,  the increases range  from  2% for  the Illinois
corn  soybean  farm  to 6% for  the Mississippi cotton soybean  farm  to  22%  for  the
      * Farmers  having  a petroleum  underground storage  tank (>1,100  gallons)  were
assumed  to incur  a $2,500/yr.  insurance  cost  (1988-1996) and a $500 charge in  1991
and 1994  for  a tank  tightness  test.   No  costs  were  included  for  remedial action,  and
it was not assumed that any farmers would remove their USTs.

                                         4-9

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                                 Table 4-1

               MAJOR FIELD CROP AND LIVESTOCK FARMS
     AVERAGE CHANGE IN NET CASH FARM INCOME (NCFI) (1987-1996)
                                  ($1986)

                              Average Impact Case
                           Average NCFI
                    Estimated Change in NCFI
Tvoe of Farm
IL
MS
KS
Corn Soybean
Cotton Soybean
Wheat Cattle
w/o
$
$
$
Regulations
35,400
58,900
11,600
Scenario 1
$ -270
(-.7%)
$
$
-1,720
(-3%)
-380
(-3%)
Scenario 3
$ +4,800
(+14%)
$
$
-1,300
(-20/0)
+310
(+3%)
                                 Table 4-2

                MAJOR FIELD CROP AND LIVESTOCK FARMS
       AVERAGE CHANGE IN DEBT/ASSETS (D/A) RATIOS (1987-1996)'

                            Average Impact Case
Type of Farm
Average D/A Ratios
 w/o Regulations
Estimated Change in D/A
Scenario 1     Scenario 3
IL Corn Soybean

MS Cotton Soybean

KS Wheat Cattle
       .26

       .28

       .26
   .6%

   .3%
.3%

.5%

.6%
*   Note  that increases in the debt to asset ratio  appear  as a  positive percentage
change in this table, but represent a worsening of a farm's financial condition.
                                    4-10

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Kansas wheat cattle farm.  Even in the maximum impact cases, however, none of the
farms in average financial  condition were predicted to go out of business  under any
of the regulatory scenarios.

     Sensitivity analysis  reveals that assumptions about crop  yields and future crop
prices have a large effect on these results.  For  example, upper  and lower sensitivity
runs were  made  assuming that  prices  were 15%  higher and  lower respectively in the
years 1991-1996.  The resultant  NCFIs  in  the  upper sensitivity  runs  were double
those in the lower sensitivity runs.   This  analysis  illustrates the  sensitivity of the
results of this  study  to critical assumptions, and helps to place the magnitude of the
predicted effects in  perspective relative to the other factors  that influence farms'
financial health.

Farms in Vulnerable Financial Condition

     The initial financial condition of  farms is an important factor  in determining
the impact of EPA actions.  Farms in vulnerable financial condition are characterized
by high  debt to asset ratios and negative net cash  income.  Further losses caused by
EPA  actions may force  these  farms  to borrow additional  money  and,  therefore,
worsen  their debt to  asset ratios.  In addition,  these losses lower  the value of their
primary asset,  their  land.  The REPFARM model assumes  that farms  go out of
business when  the debt to asset ratios reach one.

     The percentage  of each of the three farm types that are  classified as vulnerable
is indicated in  Table 4-3.  The Kansas wheat cattle farm in  vulnerable financial
condition  was  predicted  to go out  of  business  in 1993  in the base  run of  the
REPFARM model, even without the added burden of environmental regulations. This
farm is  predicted  to  go  out of business one year  earlier  due  to the income  losses
caused by  environmental regulations under the maximum impact case  for  Scenario 1.
Under all  other sets  of  assumptions,  the Kansas wheat  cattle farm does  not go  out
of business any earlier due to  environmental  regulations.  The vulnerable Illinois corn
soybean  farm  and the vulnerable Mississippi cotton soybean farm were not predicted
go out of business in  the REPFARM runs under any of the scenarios with or without
environmental  regulations.

                                    Table 4-3

                      FARMS CLASSIFIED AS VULNERABLE

                                   Total Number           Percent
     Farm Type	              of Farms             Vulnerable

     Illinois Corn Soybean             30,837                10%
     Mississippi  Cotton Soybean         1,798                14%
     Kansas Wheat Cattle             19,966                 7%

     Although environmental regulations are not expected  to generate larger income
losses for  farms in vulnerable financial condition  than  for those  who are in better
condition,  vulnerable  farms are more sensitive to income changes and  are more  likely
to feel  the  results of EPA  actions on their  financial standing.  For  example,  under
the  maximum  impact case  for  Scenario 3, both the Illinois corn soybean farm  in
average  financial condition and that in vulnerable financial condition experience  a

                                       4-11

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decrease in NCFI  of approximately $9,000.   The  1987-1996 average  debt to asset  ratio
of  the  farm  in  average  financial  condition  increases  only  2%  due  to  this  loss,
however, while the debt to asset ratio of the vulnerable farm increases  24%.
IMPACTS ON SPECIALTY CROPS

     The study  included  complete  analyses  of four  specialty  crops:  apples,  potatoes,
tomatoes, and  green  peas.   Because less  information was available  for specialty  crop
farms  than  for  the  major  crop and livestock  farms,  the  impacts  were  measured  in
terms  of the net  returns  per acre,  rather than  changes  in  net cash  farm  income  or
debt  to  asset  ratios.   Net returns  per  acre  measure  the  returns  to both  land and
farmer-provided  labor.   Furthermore, the  analysis was not able  to distinguish between
farms  in average financial  condition  and farms  in vulnerable  financial  condition.  The
analysis  was carried  out  for  the  same  three regulatory scenarios  used  for  the major
crop  and  livestock  farms,  and  for  both  the  average  and  maximum impact cases.
Because  the economics of  specialty crop  farming  vary  by  region,  the  analysis  was
carried out for each of the major regions growing the specialty crops studied.

     The original  study plan  included  caneberries and  peanuts.   However, major  data
problems prevented  this part  of  the analysis.   For  caneberries,  the  primary  limitation
was  the  lack  of  information  regarding  pesticide use  and  the  efficacy  of  pesticide
alternatives.   The  analysis  of  peanuts was  prevented  by  unreliable  cost  and  yield
estimates associated  with  various  environmental  regulations  and  the  lack  of  critical
crop  production  parameters (e.g.,  supply  elasticities).    Lack of  accurate usage  data,
efficacy   data,  and   crop  production  parameters  are  problems  that  are  commonly
encountered  when  trying  to  examine  the  effects  of  environmental  regulations  on
specialty crops.

Average  Impact Cases

     The results  of  the   analysis  for  specialty crop  farms  experiencing  average  cost
and  yield  impacts  are  presented  in  Table  4-4.    The changes  in  net  returns  per  acre
under  Scenario  1   are less  than  one  percent  for  most regions  and  less   than six
percent  for  all  crops and all regions.   The changes  in  net returns  per acre under
Scenario  3 are much greater,  particularly for  apple  farms in New York and  Michigan.
Regional differences in impacts are apparent especially under Scenario  3.

     Apple  producers in  all  three  study  regions  (Washington,  New  York,  Michigan)
experience similar  decreases in  net returns  per acre  under Scenario  1  — from $2.40
to  $3.58 per  acre   —   but  these  decreases  are higher on  a  percentage   basis  in
Michigan,  because  of the  state's lower  average returns  per  acre.    The large  impacts
under  Scenario   3  and the substantial difference among regions  is  due  to  proposed
restrictions  on the  use of fungicides in  1990.    These  restrictions would substantially
affect  New  York and Michigan  apple production  (e.g.,  17%  and  12%  yield  reductions,
respectively,   in   the   average  impact  case)   but   have  no   effect  on  production
Washington.*   The  slight  rise  in   Washington  producers'  net  returns is  due  to  the
increase  in  price above  the base year  caused by  the national  decline  in apple  supply.
     *  The  fungicide restrictions  considered under  Scenario 3  are  the cancellation  of
all EBDCs and chlorothalonil.

                                         4-12

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                                  Table 4-4
                          SPECIALTY CROP FARMS
      AVERAGE CHANGE IN NET RETURNS PER ACRE (NR/A) (1997-1996
                                   ($1986)

                             Average Impact Case
                            Average NR/A*     Estimated Chance in NR/A
Type of Farm/Region        w/o Regulations     Scenario 1     Scenario 3

     Apples

     WA                        $ 330             -0.7%          + .2%
     NY                        $ 220              -2%           -60%
     MI                         $  80              -4%           -84%

     Tomatoes

     CA                        $ 660             -0.2%            -1%
     FL                        $1,500             <0.1%           -14%

     Potatoes

     WA/ID                     $ 600             <0.1%           +3%
     MN/ND                    $ 240             -0.8%            -5%
     ME                        $ 130             -0.8%           -10%
     WI                         $ 200             -0.6%          <0.1%
     WA                        $ 80              -4%            -4%
* Net  returns per acre without the added environmental regulations are based on
regional  budget  information  and are assumed  constant over the period 1987-1996.
Net returns per acre reflect returns to land and farmer-provided labor.
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These  price increases  offset  any initial yield losses and production cost increases
that the  Washington  apple  growers  incur  under  the  average  impact  case.   The
decreases  in net returns for Michigan  and New York apple  farms under  Scenario 3
are dramatic (84%  and 60%,respectively) and  may bring about substantial structural
changes.  The  discussion  of  these  possibilities  is  beyond the scope of this study,
however.

     Decreases in  net  returns per acre are very small (.2% or less) for both  Florida
and California tomato  producers under Scenario 1.  Losses increase substantially for
Florida producers  under Scenario 3,  because of estimated yield losses of 20% due to
fungicide restrictions.   Because 98% of Florida  tomato  farms would be affected by
these restrictions,  as opposed to only 25%  of  California  tomato  farms,  the losses in
the average impact case are greater  under this scenario in Florida than in California.
The impact  estimates  for  tomatoes under  Scenario 3  must be  viewed  with  some
caution, however.   Yield declines  and cost  increases were based  on  information
provided by pesticide registrants and have not been thoroughly reviewed by EPA.

     The changes  in net returns per acre for  potato  farms under Scenario 1  are less
than 1% for all regions.   Under Scenario 3, however, the impacts are dominated  by
the  1990  proposed restrictions  on organophosphate use.   These  restrictions result in
8% reductions  in yield on affected  acreage, as well as  increases in production costs.
The magnitude of  the impacts  in Scenario 3  are  projected to result in potato  price
increases.  In  Washington-Idaho this increase in  price  should offset the decline in
yield so that net returns actually increase.  In the other  regions, the net returns per
acre are estimated to decrease from 5%  to 10%.

     The impacts  on   green  pea  farms  are  relatively  small under  both regulatory
scenarios,  with the farms  in  Washington experiencing  about a  4%  decrease in net
returns, as compared with a negligible change in Wisconsin.

Maximum Impact Cases

     Under the maximum impact case, net  returns per  acre decrease  substantially
more than under the average impact case for  many crops and regions.  There are no
dramatic shifts in  relative impacts  among crops, however, and the conclusions stated
above for the average impact  case  remain generally the same.   As with the major
field  crop and livestock  farms, it  is important to  note that the maximum impact
cases represent very unlikely worst cases.

      For apple farms, the maximum impact case  approximately  doubles  the  decrease
 in net returns per acre under  Scenario 1 for  all regions.  In Michigan, for example,
 the decrease is approximately  7%, as  compared with 4%  in  the  average  impact  case.
 Under Scenario 3, net returns decrease by approximately  74% in New York and over
 182%  in  Michigan  (losses  of  greater  than  100%  indicate  that  net  returns are
 negative).  As mentioned above, these dramatic  reductions in net  returns  per  acre
 could have a significant effect  upon the industry.

      The  maximum  impact  case  for  tomato farms reduces  the large differential
 between impacts in California  and  Florida under  the strictest regulatory assumptions.
 Under Scenario 1, the estimated decreases in net returns per acre are greater in  the
 maximum impact case than in  the average impact case, but remain under 1%. Under
 Scenario 3,  however,  the estimated decrease  for  Florida remains  at about  the  same

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level as under  the average impact case (16% vs. 14%),  but  the impact  for California
increases from  about 1%  to about 20%.  As mentioned above, these impact  estimates
for  tomatoes  under  Scenario  3  were  based  on  information  that   has  not  been
thoroughly reviewed by EPA, however, and must be regarded as tentative.

     For potato farms, the largest  percentage  change  in  the maximum  impact case
under Scenario 1 occurs in Maine, where net returns per acre decrease by nearly 8%,
as compared with  a decrease  of less than  1%  in  the  average impact  case.  The
maximum impact estimates are considerably larger than the average impact  estimates
because of such regulations as the EDB cancellation in 1984,  the dinoseb  cancellation
in 1987, and the groundwater regulations in 1990.  While the  combined cost and  yield
effects of these regulations are significant, only a small percentage of producers are
likely  to be affected  by all  of these regulations.  Under  Scenario 3, the  estimated
decreases in net returns per acre range from 8% in Washington-Idaho to 20% and 22%
in Maine and Minnesota-North Dakota, respectively.

     The  maximum  impact case for green  pea  farms results  in  no dramatic changes.
Estimated decreases  in  net returns per acre remain under 1%  for Wisconsin farms and
increase from about  4% to about 6%  for Washington farms under both Scenarios.


CONCLUSION

     This   study  examined   the  impacts  of  recent  and  proposed  environmental
regulations  on  three different types of livestock and major field crop farms  in both
average and vulnerable financial situations under a variety of regulatory  scenarios.
For  the  three  types of farms studied, the financial model predicted  no closings of
the representative farms  in average financial  condition under any  of  the regulatory
scenarios.   The  representative Kansas  wheat cattle  farm  in  vulnerable  financial
condition was  predicted to go out of  business, even in the absence of environmental
regulations.  The representative Illinois corn  soybean farm and Mississippi cotton
soybean  farm  in  vulnerable  financial  condition  were not  predicted to go  out of
business, however,  even under  the most costly regulatory  scenarios.   Out of  the six
representative  farms examined, none of  the regulatory scenarios led to the closing of
farms that would not have closed otherwise.

     For two of the three types of  major  field crop and livestock farms studied, the
financial  condition of  the farms that experience the average cost and yield  impacts
actually  improved under  the  more stringent regulatory scenario.  This  occurs  because
the  larger   cost and yield changes  incurred by affected  farmers reduce production
levels  and  raise commodity prices.   These higher  prices  more  than   offset the cost
and  yield impacts experienced by the average impacted  farmer.

     Farms that would have to bear the maximum  environmental costs and  yield
changes  were  found to experience  reductions  in  net  cash income many times that
experienced by the  average farms.   Although  none of the regulatory scenarios was
found  to result in  the  closings of even  these maximally affected farms that  were in
an average financial   condition, their average  debt  to asset  ratios   were  found to
deteriorate  by  up to 23%.  Maximally  affected farms were  those that were assumed to
incur all  of the cost and yield impacts that  were possible for that type  of farm. It
must be  emphasized  that  the maximum  impact scenarios  included  in this study
represent extremely unlikely worst-case events.

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      Because of  limited  data  availability,  the  study did  not  forecast changes in  the
financial  condition  of  the  specialty crop  farms.   Instead, it examined changes in  net
returns per  acre  (which  reflect  returns  to land  and  farmer  provided labor).    Under
the  least  costly  regulatory  scenario,  the  changes  were  generally  less  than  1% for  the
average farm  and  less than 8%  for  even  the maximally  affected  farm.   Under  the
most costly  regulatory scenario,  however,  losses  of  the average  impacted  producers
increased  substantially,  particularly  for  apple  producers  in  New  York  and  Michigan,
where predicted losses  were  60% and  84%,  respectively.   These dramatic  decreases  in
net  returns  may  bring  about  substantial  structural changes  in  the  production  and
markets for  the crops  affected.   Large  differences  in  the  impact of EPA regulations
on   crops  grown   in  different  regions   occurred  because  some   of   the  proposed
restrictions involve  pesticides that are  used in  some regions  and not  in  others.   Even
though  the  results  of  this  study must be  considered  preliminary,  these  figures  show
that EPA actions  could  create  economic  problems  for  some specialty crop farms  and
suggest that the Agency  exercise  considerable caution in this area.

      Limitations in  the  necessary data  and  models  must  be considered  when viewing
the  results  presented in  this  study.    These  limitations are  most severe  for  specialty
crops, where reliable  pesticide  usage  data often  do  not  exist, and few models  are
available  to  predict  commodity  crop  price  impacts  and  farm-level  financial  effects.
Reliable  pesticide  usage  data,  efficacy  data,  national  price-quantity  models, and  farm-
level models  are   important in  order  to  mitigate  the  potential  environmental  and
health hazards  associated  with   agriculture  in  a cost effective  way.   Such  needs  are
likely  to  become  increasingly  important  in  the  future,  as EPA  tries  to deal  with
environmental  concerns  (such as pesticide  damage  to endangered species  and  pesticide
contamination  of  groundwater)  that   may  necessitate   very  localized  restrictions   in
pesticide use.
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                                    Chapter 5


                           POLICY  CONSIDERATIONS
     The  three  sector studies  summarized  in  this report have taken  a first look at
the  potential  effects  of  recent  and  forthcoming  environmental  regulations  on
municipalities, small  business, and  agriculture.   Although  these  studies  must  be
considered as preliminary efforts to  shed some light on  very complex questions, they
have  proved  useful  in  describing the kinds  of effects  that are possible and  in
suggesting areas of potential policy initiatives and/or of further study.

     In response to the  findings of these  sector studies, several areas for  potential
policy initiatives have been suggested.  While none  has  been  endorsed by the Sector
Study  Steering  Committee, they  are  presented below  to  illustrate  the  kinds  of
activities  that might be considered and to promote further discussion.
MUNICIPALITIES

     Two  of the  findings  of the  municipal sector  study are  that  there  will  be
significant increases in household payments for improved environmental services as a
percentage of household income in the coming decade, and that many small and some
large communities  may have difficulty raising the capital needed for investments in
new environmental infrastructure.  The burden is most severe  for small communities
because  of their  lower income  levels and higher costs  for environmental services.
The financial difficulties are partly due to the  timing of the needs — a  large new
set of investments in  a  fairly short  time period —  and partly due  to  constraints
placed on new revenue potential by existing demands on municipal services.

     A number of activities  have  been implemented by EPA and other initiatives have
been  suggested to  support  these  small  communities'  compliance with  environmental
regulations.  These include establishing public dialogues on the issues,  and extending
technical and financial assistance  programs,  as  well  as several  others.   The study
also points to several areas  where  information from additional research would help
identify  which  activities supported  by EPA  and states would be most effective in
assisting communities as they seek to comply with  environmental requirements.

Public Education Initiatives

     Public education has two purposes.  First, making people  aware of the potential
net benefits  to be  gained  by investing in  environmental  protection  should provide a
better forum  for  assessing the   merits  of  the  project.     Second,  where  the

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environmental  benefits are diffuse and it is difficult to assign benefits  to  specific
groups  of payers  (e.g.,  long-distance  air  pollution), moral suasion  may  improve
compliance  as  people become aware of  the  larger  cooperative  undertaking  that  is
being proposed.  Public notification requirements,  and efforts to better communicate
information  on pollution risks, are  but  a few of  the  methods  at the  disposal of
federal,   state   and   local  governments   to   include  the   public  in  establishing
environmental  programs and setting priorities.

Technical Assistance  Initiatives

     Operations Assistance

     In  many   cases, small  communities do  not  need  full-time  personnel in  all
specialties or  service areas.   Provision  (for a  fee) of such  services  by a  central
authority,  either  the federal government or  state  governments,  could  allow small
communities to gain from economies of scale and scope.

     Such technical  assistance programs  could  take the form  of  either guidance--
such  as sharing  scientific,  technical,  or management  information -- or  technical
services  --  such  as  supplying  laboratory  or   engineering  services.   In  addition,
educational institutions  (technical and  academic) can continue  to  play an important
role in working with  local communities in need of their particular levels of expertise.

     Public Partnerships

     Partnerships provide an informal mechanism  for communities to share expertise,
to purchase  services  and  goods in  larger volumes  for discounts, and, more  formally,
to raise capital in larger more  cost-effective  blocks.  Partnerships between unequal
entities could be encouraged  by providing incentives to the larger (wealthier) partner.
Potential partners include large cities and small  cities, well-to-do cities and poor
cities, and urban cities and rural cities.

     Regionalization

     Regionalization  is a more structured form of partnership, in which two or more
communities create a joint venture for a particular purpose, such as construction  of
a  water supply system.   This action allows a variety of efficiency gains,  including
economies of  scale  and  scope, and large-volume  purchase  discounts.   The use of
regionalized services  may be more suitable for  some environmental services, but not
necessarily for all  services.   For  example,  in  those instances  where  regionalization
may lead to a waste  disposal service collecting and concentrating  pollution risks, the
merits  of this approach  versus de-centralized treatment  and disposal operations must
be examined.

Financial Initiatives

      Reform of Existing Rate Structures

      In cases  where  the  basic management structure is  in place,  rate  reform may be
necessary to insure the financial viability of the environmental service.  Rate reform
may  include  raising the  level of  rates  (increasing revenue)  or  changing  the rate
structure  (e.g., instituting marginal  cost  pricing,  including  peak  load pricing when

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appropriate).  Communities can  examine current rate structures to insure that rates
are generating revenues equal  to  the  full cost of services.  Current  provisions for
obtaining federal  grants include this element,  and efforts  are  underway  to  evaluate
whether communities have been establishing suitable rate structures.

     Development Taxes

     Special taxes may be levied in areas  undergoing rapid growth and development.
These assessments could be earmarked  for  the improvement of environmental services
and  could  be  levied  on developers directly or  on  property owners who expect  to
profit  from development.   Since environmental  improvements  often affect  property
values, a  similar approach might be used even in relatively low-growth areas.  Many
specific  versions  of  development  taxes have  been  devised.   A  few  of the  more
common are:

         ad valorem on property;

         exactions from developers  (in  kind or cash); and

         tax  incremental  financing  (tax  rates  are  not  changed,  but  as
         property values rise,  property  tax  revenues above a  baseline are
         devoted  to  special  uses,  such  as sewage  system  construction  or
         road building).

     Special Revenue  Districts

     Certain geographic areas, within one political jurisdiction or including several
jurisdictions,  are  created  for the purpose of  raising revenue  from residents  in the
area to be  used for specified purposes.   Examples include  road  districts, sewer and
water districts, or other types of local service districts.

     Enterprise Fund  Management

     Utilities  or  enterprise  fund  management  systems  are  used to  ensure  that
revenues  raised from  certain groups of payers  are used for the intended purpose and
are  managed according to sound  financial principles.  Organizations  of these types
can  help to  balance  costs and revenues  by improving financial  management  and,
therefore, can improve access to capital markets.

     Direct Financial Assistance

     Direct financial assistance  may  be appropriate  for low-income  communities
where  it  is  agreed  that  the  environmental protection  services should  be  made
available to  all citizens,  regardless of  ability  to pay.   It may be  appropriate  to
provide  assistance only to those  communities that fail  an "income" or other "ability
to  pay"  test.   Such  assistance could  be  from the  state  governments, which would
need to consider adopting appropriate  tests  for directing  financial assistance, and
utilizing  them in a consistent manner across the  agency.   Direct financial assistance
could  be  in the form of  either  grants  for communities that  cannot afford the
services  in  the  long run or  loans for communities that are experiencing a short-term
cash-flow problem.


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Other Actions

     Compliance Schedules

     If certain environmental regulations do not seem reasonable for a specific group
of people, or if the timing of the compliance schedule is not reasonable, then a delay
of the regulation or a permanent exemption may be appropriate. Such actions should
only be allowed  subject to  certain constraints, such as that no "unreasonable risk to
health"  would  be  created.   In  all  instances,  the  ability to grant  exemptions  is
dictated by existing legislation.  Several existing laws allow for exemptions, but the
rules  are  not  consistent, and do not dictate  what measures  should  be considered
when allowing for an  exemption.  The EPA  does not have an internally consistent
method for determining when the costs of a requirement are unaffordable, either to
the household,  or for purposes of evaluating impacts on municipal finances.  Neither
does  EPA  have criteria for evaluating  the  cumulative  economic  impacts of  its
programs.  Efforts  are  underway within EPA to  resolve existing inconsistencies, and
establish a protocol for  granting exemptions where allowed for by law.

     Privatization

     Communities can explore methods of working  with private companies to assist in
the provision of environmental services.  Several aspects of privatization include:

         - Private   sector  ownership,  construction  and/or  operation  of  facilities
           (reduce  cost  of  services by   taking   advantage   of   economic  and/or
           administrative efficiencies),

         - Private  financing of  new capital  formation, or  refinancing  existing
           financial obligations  (reduce financial obligations of community).

Private companies have  been  involved in the provision  of  several  environmental
activities, particularly solid waste and drinking water services, and a growing number
of companies are expressing interests in wastewater treatment services.

      Despite  the potential  advantages of public/private  partnerships,  the  current
supply  of  private  firms  is  relatively   small.     Private   involvement  in  many
environmental services can be affected by federal  and state tax requirements, several
of  which have undergone significant revisions in  recent years. Some of the revisions
have reduced the tax advantages of public/private ownership.  In addition, decisions
to  use private  companies  require  considerable   effort  in  establishing contractual
arrangements and  liability responsibilities in cases of damages or permit violations.
EPA is currently investigating this  issue in greater depth, and plans to  hold several
conferences with experts  in the field and interested parties in the coming months.

Additional Research

      An  important  finding of the municipal  sector study is that not all  communities
are expected  to face financial  difficulties.   This fact suggests that further analysis
should be  conducted  in order  to  identify  the  characteristics  of small  and large
communities that make  them more  likely to experience difficulty  in  financing and
affording new environmental protection.  For example, does a problem typically arise
in  communities that are:

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         -  very  small  or sparsely populated  (lack  economies  of  scale  and
           scope),

         -  poorly managed (have poor access to financial markets),

         -  low income (are unable  to afford environmental protection),

         -  rural  (have poor access to technical services), or

         -  uninformed  (lack   understanding  of   the  importance  of
           environmental protection),

         -  facing significant environmental burdens (are currently investing an above
           average amount of resources to combat existing  pollution problems),

         -  located in a  particular  state (are some states more aggressive in assisting
           their  financially constrained communities)?

If EPA can  better  identify those characteristics  of communities that most  inhibit
compliance with  environmental  regulations, then it can  improve upon  its  current
efforts  to  design and implement programs that  are  targeted at the sources  of the
problem.


SMALL BUSINESS

     The  small business sector  study  has provided  a  number  of insights into the
potential impacts of EPA's  regulations on small  businesses.   While EPA's primary
mission is to reduce the risks posed by environmental damage, the Agency also seeks
to minimize  the  unnecessary  adverse social and economic impacts of its regulations
whenever appropriate.  In this context, the results of this study suggest a number of
policy initiatives as well as areas for further study.

Policy Initiatives

     Because many  of the  new  environmental programs  cut  across many industries
and affect thousands of small businesses, new compliance strategies may be needed to
supplement  EPA's traditional  enforcement  efforts.   Many  of the policy  initiatives
suggested below  will  help  small businesses  learn about  and comply with the  new
environmental  regulations.  This in  turn  will assist the Agency  in  achieving higher
rates of compliance among small businesses.

     These policy initiatives  are not necessarily  new to  EPA.  The Agency's Small
Business Ombudsman already operates several programs to assist small businesses and
the Office of  Research and Development  (OR&D) is engaged in developing several
new technologies for pollution control.  The problem areas  highlighted by this study
provide specific focuses for existing and new programs alike.
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     Environmental Technology

     It  may  be  possible  to reduce  environmental  costs  to  small  businesses by
developing lower-cost  control technologies or  standardizing existing  technologies so
that they can be made available at affordable prices.

     The  results  of  this study suggest many areas in which new technologies  might
help solve the special problems of small businesses.  Potential projects might include
new ways to  control stormwater drainage from wood preservers'  storage yards, for
example,  or  new processes  for  dealing  with  soil that  has been  contaminated  by
leaking  underground storage tanks.

     Even when  appropriate  technology exists,  the  required equipment  may  be
available  only on a  customized basis.  By working with  the regulated community of
small businesses and informing manufacturers  of the potential market, EPA  might be
able to bring down the costs of existing technologies.

     Environmental  Services

     In  some  cases, required environmental   services  are  not  available  to   small
businesses or  are available  only  at  restrictive  prices.   Many  wood preservers, for
example,  have no disposal facilities available for some  of their hazardous  wastes.
Electroplaters and dry  cleaners are also concerned about  the availability of disposal
alternatives  for their  hazardous  wastes.  Similarly,  many  small businesses  that  own
underground storage tanks are finding that no companies will sell them  the required
environmental  insurance.    EPA  might  work with  the  regulated  community  and
potential service providers  to expand the options available to small businesses.

     Exemplary Programs

     For  some  of the new environmental  regulations,  thousands of  similar  small
businesses may  have to prepare  almost  identical responses.   Their costs  might be
reduced considerably,  if exemplary programs  or responses could be  made  available.
Paperwork costs might  be  reduced, for example, by examples for answers that will be
the same  for most businesses in a category.  Exemplary emergency response programs
and employee training programs might be developed as well.

     Education and  Training

     Sometimes,  simply learning  how to comply with environmental requirements can
be  an expensive and  time-consuming task for small business  owners and  operators.
Education programs and packages could  help  to reduce this expense.  Such programs
could include  seminars, response lines,  pamphlets and other written materials, and
video training programs.

     Joint Programs

     Policy initiatives  such  as those suggested above can  be undertaken by EPA on
its own or  can  be  carried  out  with the help of other government agencies.   New
environmental control technologies, for example, could be developed by and for small
businesses  through  the  EPA's  Small  Business  Innovative Research  grants,  with
research targeting problem areas identified in  this study.  Educational programs could

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 be developed with  the  U.S.  Department of  Commerce.   State and local governments
 could be enlisted in the effort as well.

      For  many  programs,  it  might  be desirable  to  obtain  the  cooperation  of  the
 industries   affected.      Joint  programs  could   be  developed   with   industry   trade
 associations,  for  example.   Alternatively, EPA  development  efforts  could be  supported
 by small business advisory teams.

 Continued Analysis

      This  study has  pointed to  several  potential  problem  areas  for  small  businesses.
 Additional  research  might  provide  more  insight  into  these problems  or might  show
 that the  problems  will  not  be as  large  as  this  preliminary  study  has  suggested.   This
 study  also  has  highlighted  the  value of  detailed  small  business  analysis.    EPA  can
 improve  the  quality  of  its  analyses  by  maintaining a  current data base of  financial
 statistics on small businesses.

      Small Business Analyses

      By   focusing   on   industries   dominated   by   small  businesses  and  by  paying
 particular   attention  to  the  smallest  businesses  in  these   industries,  this  study   has
 shown  how   detailed  analysis   can  be  especially  useful  in   determining  whether
 environmental regulations will have  significant  impacts  on  small  businesses.    Under
 the Regulatory Flexibility Act, EPA  has  a mandate to conduct such analyses for  each
 of its regulations.

      The  detailed  analysis of  small   businesses  was  made possible through  the use  of
 the  Fin/Stat  data  base  provided  by  the  SB A.    Because SB A discontinued  this  data
 base  in  1983, the data  used was slightly  out  of date.   Nevertheless, it provided  useful
 information on the financial capabilities of small businesses.

      EPA  could  improve  the quality  of its  small business  analyses  by obtaining  a
 current data  base  of  financial  statistics.    Research would  be  necessary  to determine
 the best  source  of  such a  data  base and  the  best format  for its  maintenance.   The
 SBA  could be  helpful in preparing  the data base,  and with  other  regulatory  agencies
 such  as  the  Occupational  Safety  and  Health  Administration,  might  be  interested  in
 sharing the  data base with EPA.

      Multi-Regulation Impact Analyses

      This  study  has  identified  several industries  for  which the  combined  effects  of
 several  environmental  regulations  will  result  in  considerably  more impact  than   the
 effects  of  any   one  regulation  taken  alone.    Continued   analysis  of  the  combined
 effects  of  all of  EPA's  regulations  on those industries  identified  as being subject  to
 many  regulations  will help  the  Agency maintain  a broader perspective   of  regulatory
 impacts and will  put the impacts of new regulations in a more accurate perspective.

     Regulatory  Analyses

     This  study  has  pointed  to  a number  of  potential  problem  areas  associated  with
individual  regulations.   Continued  analysis of  these regulations will not  only  provide
better  information  on  the  actual  economic impacts  of this  regulations,  but  will  also

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provide insights into how the regulations might be improved.

     A  good  example of  a regulations that might bear further analysis are those
promulgated  under Title III of SARA.  The cost for an "average small business" to
comply  with  emissions reporting requirements under Section 313 of Title III has been
estimated to  be approximately $9,000 per  year, a  cost that  appears  to  be prohibitive
for many of the small businesses included in this  study.  Cost estimates for Section
313 have been prepared, however, using assumptions of an average number of toxic
chemicals reported and  an average level of analysis.  Furthermore, the  estimates do
not consider  that  many  small businesses will be able to take advantage of  the range-
reporting option that EPA has developed to reduce their reporting costs.  Thus, many
small businesses included in this  study  may be able to comply with Section 313  at a
cost that is considerably lower  than  that estimated.  Continued analysis of how small
businesses  actually comply with  these  regulations will  enable EPA to  better assess
not only the  impacts but also the efficacy of the regulations.
AGRICULTURE

     The agriculture sector study illustrates the advantages of examining  the impacts
of environmental regulations at the farm  level as well as at the aggregate national
level.  While national analyses  provide useful information concerning the total losses
incurred by different aggregate types of farmers  (e.g., corn farmers as a  whole),  the
impact of environmental  regulations on farms' financial conditions depends on  the
distribution of  those losses among farmers and on the initial financial conditions of
the  affected  farms.   In order to  determine  the  affect  of EPA  regulations on  the
ability of farms to survive, both aggregate and farm level  analyses are necessary.

     This  study  highlights  the  data  and  analytical  requirements  necessary  to
determine the impacts of EPA actions on agriculture.  Such requirements include:

     1.   Accurate pesticide usage data,

     2.   Accurate pesticide efficacy data,

     3.   Improved information on how initial pesticide
          cancelation affects change over time,

     4.   Accurate incidence data for non-pesticide related
          impacts  (e.g., underground storage tanks),

     5.   Improved national price-quantity models  to predict commodity price
          changes due to EPA actions, and

     6.   Better   information   on  the   initial  financial  and   production
          conditions  of  agricultural producers and  farm level  models for
          estimating changes in  these over time.

     The need  for better  data  and modeling capability is greatest for specialty crops,
 where reliable  pesticide  usage  and  efficacy   data  often  do  not   exist,  limited
 information is  available on producers' initial  financial condition, and few models are
 available.  EPA currently is  compiling  a directory of  all specialty crop models

                                        5-8

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available  for use in economic analyses and  is funding the development of additional
specialty  crop  models.   Improvements  in  pesticide usage data might  be obtained by
increased  cooperation and cost sharing with  USDA  and  states to fund additional
pesticide  usage surveys or t add  pesticide usage  questions to surveys designed  for
other purposes.  In addition, registrants  of pesticides  might be  required  to provide
usage information.  The importance of using farm level models  and improving  data
and  modeling  capabilities is likely  to  increase in  the  future  as EPA tries to cost-
effectively reduce environmental risks associated with agriculture.
                                        5-9

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                           Appendix
ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES

-------
                                         Appendix

         ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title

    Air

 1.  Rural Fugitive Dust


 2.  Stratospheric Ozone

 3.  Municipal Waste
      Combustors


 4.  TSDF Air Standards


 5.  Diesel Fuel Standards

 6.  Diesel Particulate
      Standards


 7.  Fuel Volatility


 8.  Gas Marketing


 9.  Lead Phasedown


10.  NAAQS: Lead

11.  NAAQS: Particulate
       Matter

12.  NESHAP: Chromium

13.  NESHAP: Perc  Dry
      Cleaning

14.  NSPS: Small Boilers

15.  NSPS: Industrial
      Boilers

16.  NSPS: Woodstove
Legislative Title
CAA Section  110, 165, 169 / Agricultural
                             Burning

Stratospheric Ozone Protection Strategy

NSPS: Municipal Waste Combustors
(Assessment of Municipal Waste Combustor
Emissions Under the Clean Air Act)

Treatment, Storage, and Disposal Facility
Area Source Air Emissions - RCRA Standards

Diesel Fuel Modification

Nonconformance Penalties for 1991 through
1994 Model Year Emission Standards for
Heavy-Duty Vehicles and Engines

Control of Excess Evaporative Emissions/
Fuel Volatility

Decision on Air Pollution Regulatory
Strategies for the Gasoline Marketing Industry

Removal of Lead from EPA Certification and
Test Fuels (Revision)

NAAQS: Lead

NAAQS for Particulate Matter (Revision)
NESHAP: Chromium—Electroplating

NESHAP: Perchloroethylene Dry Cleaning


NSPS: Small Boilers

NSPS: Industrial Boilers


NSPS: Residential Wood Combustion

           A-l
Promulgation



undetermined


     8/88

    12/90



     9/90


     7/89

     3/89



     1/89


     1/89


     1/88


     3/90

undetermined


     3/91

undetermined


     9/90

    12/87


     2/88

-------
                                       Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Proeram/Short Title

    Radiation

17. Radon

18. Radiofrequency
      Guidance
19. Low Level
      Radioactive Waste

20. High Level
      Radioactive Wastes
Legislative Title
Federal Radiation Protection Guidance:
Proposed Alternatives for Controlling
Public Exposure to Radiofrequency Radiation

Environmental Protection Standards for
Low-Level Radioactive Waste

Environmental Standards for the Management
and Disposal of Spent Nuclear Fuel,  High-
Level and Transuranic Radioactive Wastes
Promulgation



undetermined

     7/89



     5/89


undetermined
    Pesticides

21. Inerts

22. Farmworkers
23. Pesticides in
      Groundwater

24. Large Volume
      Pesticides

25. Data Requirements
26. Reregistration of
      Pesticides
Worker Protection Standards for
Agricultural Pesticides (Revision)
Comprehensive Revision of Pesticide
Registration and  Classification
Procedures (Revision)
undetermined

     3/89


     2/89


undetermined


     5/88



undetermined
                                          A-2

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                                       Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title

    Toxic Substances

27. Asbestos Ban and
      Phasedown

28. Asbestos in Schools

29. Chlorinated Solvents
30. PCBs: Electrical
      Equipment
31. PCBs: Electrical
      Transformers

32. Premanufacture
      Review Program

    SARA

33. Title III of SARA
Legislative Title
    RCRA

34. Subtitle C Location
      Standards

35. Subtitle D Criteria

36. Liner and Leachate
      Collection
37. Corrective Action
      at SWMUs
38. Hazardous Waste
      Burning
Action Concerning Commercial and
Industrial Use of Asbestos

Asbestos Reinspection Rule

Regulatory Investigation of Chlorinated
Solvents

Polychlorinated Biphenyls/Manufacturing,
Processing, Distribution in Commerce and
Use Prohibitions: Use in Electrical Equipment

Polychlorinated Biphenyls in Electrical
Transformers: Final Rule
Promulgation



     1/89


    10/87

     6/89


     9/88



     7/88


undetermined
Emergency and Hazardous Chemical Inventory          9/89
Forms and Community Right-To-Know Reporting
Requirements, and
SARA Section 313 Toxic Chemical Release             6/89
Reporting Rule
Location Standards for Hazardous Waste               12/88
Facilities

Solid Waste Disposal Facility Criteria                  12/88

Double Liner and Leachate Collection                  9/88
Systems for Hazardous Waste Land
Disposal Units

Corrective Action for  Solid Waste                     11/88
Management Units (SWMUs) at Hazardous
Waste Management Facilities

Burning of Hazardous Waste in Boilers                10/88
and Industrial Furnaces
                                          A-3

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                                       Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title

    RCRA (cont.)

39. Municipal Ash

40. Land Ban   First
       Thirds

41. Land Ban - Soil
       and Debris

42. Land Ban - Dioxin


43. Land Ban   Cal. List
44.  UST Financial
       Responsibility
45. UST Technical
       Standards
Legislative Title
46. Hazardous Waste Tank
       Standards

47. Toxicity
       Characteristics
48. Small Quantity
       Generator

49. Waste Oil Management

    CERCLA

50. National Contingency
       Plan

51. CERCLA Settlement
      Policy
Municipal Waste Combustor Ash Management

Land Disposal Restrictions for First
Third of Scheduled Wastes

Land Disposal Restrictions for Soil and
Debris Containing Hazardous Wastes

Restrictions on Land Disposal of
Specified Solvent Dioxin Wastes

Land Disposal Restrictions for Certain
Hazardous Wastes - California List

Underground Storage Tanks Containing
Petroleum - Financial Responsibility
Requirements

Underground Storage Tanks - Technical
Requirements / Technical Standards and
Corrective Action Requirements for Design
& Operation of USTs Containing Petroleum
and Hazardous Substances

Hazardous Waste Tank Standards
Identification of Hazardous Wastes by
Toxicity Characteristics and Listing of
Additional Organic Toxicants

RCRA Small Quantity Generator Rule
Management of Used Oil
National Oil and Hazardous Substances
Pollution Contingency Plan (NCP)
Promulgation



    12/89

     8/88


    10/91


undetermined


     7/87


     5/88



     5/88
undetermined


     8/88



     3/86


undetermined



    11/89


undetermined
                                          A-4

-------
                                      Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title
Legislative Title
Promulgation
    Drinking Water

52. Total Coliform Rule
53. Surface Water Treatment
      Filtration

54. VOCs in Drinking Water
55. SOCs in Drinking Water

56. Inorganics in Drinking
      Water

57. Fluoride in Drinking
      Water

58. Lead MCL and
      Corrosion Control

59. Lead Ban
60.  34 MCLs

61.  Radionuclides

62.  Disinfection
63.  Public Notification
      Rule
National Primary Drinking Water Regulations
(NPDWR): Microbials and Filtration of
Surface Drinking Water Supplies
NPDWR: MCLs for Volatile Organic
Chemicals Found in Drinking Water
NPDWR: Inorganic and Organic Compounds
Public Water System Supervision Program:
Ban on Lead in Plumbing
NPDWR: Radionuclides

NPDWR: Disinfection, Disinfectants and
Disinfection By-Products (Revision)
undetermined



undetermined


     6/87


undetermined

undetermined


undetermined


undetermined


     6/86


undetermined

undetermined

undetermined


     10/87
                                          A-5

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                                      Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title

    Groundwater

64. Well-head Protection

65. Class I Underground
      Injection Wells
66. Class II Underground
      Injection Wells

67. Class V Underground
      Injection Wells

    Surface Water

68. Construction Grants
      Program

69. Secondary Treatment
      Waivers

70. Municipal Sewage
     Sludge

71. State Sludge
      Management
72. Pretreatment
73. Stormwater
74. Nonpoint Sources
75. Wetlands

76. National Estuary
      Program
Legislative Title
Underground Injection Control Program /
Hazardous Waste Disposal Injection
Restriction for Class I Hazardous Waste
Injection Wells
Comprehensive Construction Grant
Regulation Revision

CWA Section 301(h) Revisions
Sewage Sludge Use and Disposal
Regulations

National Pollutant Discharge Elimination
System Sewage Sludge Permit Regulations;
State Sludge Management Program Requirements

Final Revisions to General Pretreatment
Regulations for Existing and New Sources

NPDES Regulations: Stormwater Application
Requirements (Revision)

Section 319 of the Clean Water Act /
Nonpoint Source  Guidance

404(c) Regulations / Actions
Promulgation



    12/87

undetermined
                                              undetermined
                                              undetermined
     5/89


undetermined


    12/89


     2/89



undetermined


    11/89


undetermined


undetermined

undetermined
                                          A-6

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                                      Appendix (cont.)

          ENVIRONMENTAL REGULATIONS INCLUDED IN THE SECTOR STUDIES
    Program/Short Title

    Surface Water (cont.)

77. Toxic Water
      Pollutants

78. Ocean Dumping


79. ELG: Foundries
Legislative Title
80. ELG: Placer Gold
      Mining

81. ELG: Machinery
      Manufacturing and
      Rebuilding

82. ELG: Oil and Gas
83. ELG: Organic Chemicals
84. ELG: Pesticides
85. ELG: Pulp and Paper
Section 304(1) of the Clean Water Act
Regulations

Comprehensive Revisions to Ocean Dumping
Regulations

Metal Molding and Casting Industry Point
Source Category Effluent Limitations
Guidelines, Pretreatment Standards and
Nonpoint Source Performance Standards

Effluent Limitations Guidelines for the
Placer Gold Mining Industry

Effluent Limitations Guidelines for the
Equipment Manufacturing and Rebuilding
Industry

Effluent Guidelines for Offshore Oil
and Gas Extraction Industry (Revision)

Effluent Guidelines for Organic  Chemicals
and Plastics and Synthetic Fibers

Effluent Guidelines for Pesticides
Chemicals

Effluent Guidelines for Pulp, Paper
and Paperboard
Promulgation
     8/89


    10/85
undetermined


undetermined



     3/90


    12/87


     9/91


     5/88
                                          A-7

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