ECONOMIC IMPACT ANALYSIS OF
ALTERNATIVE POLLUTION CONTROL
TECHNOLOGY FOR THE WET PROCESS
HARDBOARD AND INSULATION BOARD
SUBCATEGORIES OF
THE TIMBER PRODUCTS  INDUSTRY

report to
U.S.  ENVIRONMENTAL PROTECTION AGENCY
CONTRACT NO. 67-O1-4194
                     Arthur D Little, Inc

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                                                  DRAFT
       ECONOMIC IMPACT ANALYSIS OF
ALTERNATIVE POLLUTION CONTROL TECHNOLOGY
     FOR THE INSULATION BOARD AND
  WET PROCESS HAKDBOAKD SUBCATEGORIES
     OF THE TIMBER PRODUCTS  INDUSTRY
  U.S. ENVIRONMENTAL PROTECTION AGENCY
             NOVEMBER 1978
             Submitted by:
     Arthur D. Little, Incorporated
             Acorn Park
    Cambridge, Massachusetts   02140
         Contract No. 68-01-4194
                                               Arthur D Little Inc

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                                                                 DRAFT
                          TABLE OF CONTENTS
                                                                PAGE
  I   EXECUTIVE SUMMARY                                           1-1
 II.   INDUSTRY CHARACTERIZATION - INSULATION BOARD               II-l
      A.   INDUSTRY DEFINITION                                    II-l
      B.   TYPES OF FIRMS                                         II-l
          1.  Size of Firms                                      II-l
          2.  Integration/Diversification                        II-2
      C.   PRODUCT DESCRIPTION                                    II-4
          1.  Types of Products                                  II-4
          2.  Market Size and Future Growth                      II-5
      D.   PLANT CHARACTERISTICS OF THE EXISTING INDUSTRY         11-11
          1.  Process Technology                                 11-11
          2.  Size of Plants                                     11-13
          3.  Age Distribution                                   11-13
          A.  Location                                           11-13
          5.  Employment                                         11-16
      E.   CHARACTERISTICS OF NEW PLANTS                          11-16
      F.   COMPETITIVE STRUCTURE                                  11-16
          1.  Market Structure                                   11-16
          2.  Pricing Mechanism                                  11-18
          3.  Price Elasticity of Demand                         11-21
          4.  Barriers to Entry of New Firms                     11-23
          5.  Other Regulatory Factors                           11-23
      G.   FINANCIAL PROFILE                                      11-24
III.   INDUSTRY CHARACTERIZATION - WET PROCESS HARDBOARD          III-l
      A.   INDUSTRY DEFINITION                                    III-l
      B.   TYPES OF FIRMS                                         III-l
          1.  Size of Firm                                       III-l
          2.  Ownership/Integration/Product Diversification       III-3
      C.   PRODUCT DESCRIPTION                                    III-5
          1.  Types of Hardboard Products                        III-5
          2.  Market Size and Future Growth                      III-7
                                                                Arthur D Little Inc

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                                                                 DRAFT
                   TABLE OF CONTENTS (CONTINUED)

     D.   PLANT  CHARACTERISTICS OF THE EXISTING INDUSTRY
         1.   Process Technology
         2.   Size/Age/Location
         3.   Employment
     E.   CHARACTERISTICS OF NEW CAPACITY
         1.   Recent Capacity Additions
         2.   Process Economics of New Capacity
     F.   COMPETITIVE STRUCTURE
         1.   Market Structure
         2.   Pricing Mechanism
         3.   Price Elasticity of Demand
         4.   Barriers  to Entry of New Firms
         5.   Other Regulatory Factors
     G.   FINANCIAL PROFILE
IV.  COST OF COMPLIANCE WITH REVISED WATER EFFLUENT
     REGULATIONS
     A.   INTRODUCTION
     B.   CURRENT  EFFLUENT STATUS
     C.   POLLUTION CONTROL OPTIONS - EXISTING PLANTS
         1.   Cost Models
         2.   Costs of  Compliance
     D.   POLLUTION CONTROL OPTIONS - NEW SOURCES
         1.   Cost Models
         2.   Costs of  Compliance
 V.  ECONOMIC IMPACT OF COMPLIANCE WITH REVISED WATER
     EFFLUENT REGULATIONS
     A.   INTRODUCTION
     B.   PRICE INCREASES
         1.   Level of  Increases
         2.   Obtainability of Increase
     C.   FINANCIAL CONSIDERATION
  PAGE
III-ll
III-ll
111-15
111-17
111-17
111-17
111-18
111-20
111-20
111-20
111-23
111-25
111-25
111-25

 IV-1
 IV-1
 IV-1
 IV-3
 IV-3
 IV-5
 IV-5
 IV-5
 IV-7

  V-l
  V-l
  V-2
  V-2
  V-4
  V-7
                                ii
                                                              Arthur D Little, Inc

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                                                             DRAFT
                   TABLE OF CONTENTS (CONTINUED)
                                                              PAGE
     D.  PLANT CLOSURE                                         v~9
     E.  CAPACITY EXPANSION                                    V'11
     F.  MARKET STRUCTURE                                      v-12
     G.  EMPLOYMENT AND COMMUNITY IMPACTS                       V-12
APPENDIX A - Supplementary Data
APPENDIX B - EPA Financial 308  Survey
                               ill
                                                            Arthur D Little Inc

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                                                                  DRAFT
TABLE
 II-l
 II-2
 II-3

 II-4
 II-5
 II-6
 II-7
 II-8

 II-9
III-l
III-2
III-3

III-4

III-5
III-6
III-7

III-8
III-9
111-10
 IV-1

 IV-2
 IV-3

 IV-4

 IV-5
              LIST OF TABLES
                                                   PAGE
SALES BY INSULATION BOARD MANUFACTURERS            II-3
PRODUCTION OF INSULATION BOARD 1965-1976           II-6
INSULATION BOARD PLANTS  IN THE UNITED  STATES,
1977                                              II-14
AGE DISTRIBUTION OF INSULATION BOARD PLANTS        11-15
EMPLOYMENT LEVEL OF INSULATION BOARD PLANTS        11-15
CONCENTRATION IN THE INSULATION BOARD  INDUSTRY     11-17
PRICES OF SELECTED INSULATION  BOARD PRODUCTS       11-19
PRICE INDEXES FOR SELECTED INSULATION  BOARD
PRODUCTS                                          11-22
FINANCIAL PROFILES                                IT-25
1977 HARDBOARD PRODUCTION CAPACITY                III-2
1977 HARDBOARD SALES                             III-4
SHIPMENTS, IMPORTS, AND  APPARENT CONSUMPTION--
1964-1976                                        III-8
CAPACITY UTILIZATION BY  HARDBOARD INDUSTRY -
1967-1976                                        III-9
DISTRIBUTION OF HARDBOARD PLANTS BY PLANT AGE     111-16
EMPLOYMENT IN WET PROCESS HARDBOARD PLANTS        111-16
PROCESS ECONOMICS OF NEW WET PROCESS
HARDBOARD CAPACITY                               111-19
HARDBOARD INDUSTRY CAPACITY                      111-21
TEMPERED HARDBOARD PRICES                        111-22
FINANCIAL PROFILE                                111-27
INSULATION BOARD AND WET PROCESS HARDBOARD
CURRENT METHOD OF WATER  EFFLUENT DISPOSAL          IV-2
MODEL PLANT TREATMENT OPTIONS                      IV-4
COST OF COMPLIANCE FOR PLANTS  IMPACTED BY
REVISED EFFLUENT REGULATIONS                       IV-6
MODEL PLANTS FOR NEW SOURCE PERFORMANCE
STANDARDS-INSULATION BOARD AND WET PROCESS
HARDBOARD                                         IV-8
COST OF COMPLIANCE NEW INSULATION BOARD AND
WET PROCESS HARDBOARD MILLS                       IV-9
                                 iv
                                                                Arthur D Little. Inc

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                                                               DRAFT
                     LIST OF TABLES (CONTINUED)

TABLE                                                         PAGE

  V-l        REVENUE REQUIRED TO RECOVER THE COST OF
             COMPLYING WITH REVISED REGULATIONS FOR
             HARDBOARD PLANTS                                  V-3

  V-2        DISTRIBUTION OF HARDBOARD CAPACITY IMPACTED
             VS. NON-IMPACTED PLANTS - OPTION  3                 V-5

  V-3        COST OF NEW HARDBOARD CAPACITY-NEW MILL VERSUS
             INCREMENTAL EXPANSION                             V-13
                                                              Arthur D Little. Inc

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                                                                DRAFT
                           LIST OF FIGURES
FIGURE                                                         PAGE
 II-l        INSULATION BOARD PRODUCTION                        II-8
 II-2        INSULATION BOARD DEMAND, 1976-1982                 11-12
III-l        HARDBOARD CONSUMPTION AND CONSTRUCTION
             EXPENDITURES -  1964-1976                         111-12
III-2        TOTAL HARDBOARD DEMAND, 1976-1982                 111-13
  V-l        POST-COMPLIANCE PROFITABILITY WITH NO PRICE
             INCREASE                                           V-8
  V-2        INVESTMENT REQUIRED FOR COMPLIANCE WITH  REVISED
             EFFLUENT REGULATIONS COMPARED WITH PLANT CASH
             FLOW                                               V-10
                                 vi

                                                               Arthur D Little, Inc

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                                     DRAFT
     I   EXECUTIVE SUMMARY




(Not included in this Final Draft)
           1-1
                                    Arthur D Little; Inc

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                                                                  DRAFT
         II  INDUSTRY  CHARACTERIZATION - INSULATION BOARD
A.  INDUSTRY DEFINITION




    The insulation board industry  (a subset of the building board indus-




try, SIC 2261)  is comprised  of  establishments engaged in the production




of structural and decorative fiberboard products constructed from inter-




felted ligno-cellulosic fibers  and having a density of less than 31




pounds per cubic foot.








B.  TYPES OF FIRMS




1.  Size of Firms.




    Twelve companies,  one of which is privately held, operate the 17




insulation board plants in the  United States  (the plants are identified




in Table II-3).  Eleven of these companies are large diversified corpora-




tions, five have major interests in forest products and six have major




interests in other building  products.  There  are only two multi-plant




companies; Celotex, the largest producer operates four plants and




U.S. Gypsum operates three.








    The percentage of  sales  revenues contributed to each company by




insulation board products is quite variable.  Although they may hold




sizeable insulation board capacity, most of the companies are involved




in many other businesses and cannot be considered to have significant




capital committed to the industry  relative to their total businesb.




Annual sales of the 12 companies,  including sales from other operations
                                II-l
                                                                Arthur D Little, Inc

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                                                                  DRAFT
such as lumber,  plywood,  and non-wood products, range from $2 million to




over $3.6 billion as shown in Table  II-l.  This table also shows each




company's sales  derived from insulation board.









2.  Integration/Diversification.




    The major forest products firms  are normally fully integrated back




to timber ownership or control and forward to distribution systems.




Insulation board is usually manufactured  to  take advantage of the




volumes of locally available waste from other wood products mills and




to broaden the company's  product  line.




    Four of the  forest products firms  (Abitibi, Boise Cascade, Georgia




Pacific, and Weyerhaeuser) have major capital interests in various




segments of the  paper industry as well as a  full spectrum of building




products.  Temple Industries, a subsidiary of Time, Inc., is a producer




of a wide range  of solid  wood products.




    Five of the  building  products firms involved in the insulation




board industry (U.S. Gypsum, National, Kaiser Gypsum, Flintkote and




Celotex, a Division of Jim Walter Corporation) are highly diversified




into both residential and nonresidential building materials.  Armstrong




Cork has major interests  in both  residential and commercial interior




finishing materials including floor  coverings, wall coverings, and




furniture.  The  general building  products firms produce insulation board




to complement their product line. While  these firms are characterized




by well-developed captive distribution systems, they generally are not




integrated back  to timber control.   The remaining company, Huebert Fiber-




board, is privately held  and insulation board apparently constitutes the




major business of the company.




                                 II-2




                                                               Arthur D Little. Inc

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                             TABLE  II-l
               SALES BY INSULATION BOARD MANUFACTURERS
                          (1977; $ Million)
                                                                DRAFT
          Company
Abitibi Paper Co., Ltd.
Armstrong Cork
Boise Cascade
Celotex/Jim Walter1
Flintkote
Georgia Pacific
Huebert Fiberboard
Kaiser Gypsum
National Gypsum
Temple/Time Inc.
U.S. Gypsum
Weyerhaeuser
Total
Corporate
880
981
2316
525/1422
587
3675
2
212
748
340/1038
1177
3283
Insulation
Board2
12
31
16
59
16
16
2
12
15
17
21
23
        year ended August 31
2At 80% of capacity and $97/MSF, 1/2"
Source:  Dun and Bradstreet Directory,  1978
         Directory of Corporate Affiliates, 1978
                                II-3
                                                               Arthur D Little, Inc

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                                                                  DRAFT
C.  PRODUCT DESCRIPTION

1.  Types of Products.

    Insulation board is  known  in  the marketplace under many different

names including fiberboard,  sheathing board, backer board, and asphalt

board.  There are seven  principal types of insulation board products

that can be described as follows:

    1.  Building Board — general  purpose product for interior

        construction.

    2.  Insulating Roof  Deck — a  three-in-one component which

        provides roof deck,  insulation, and a finished interior

        ceiling surface.  Insulation board sheets are laminated

        together with waterproof  adhesives.

    3.  Roof Insulation  — insulation board designed for use on

        flat roof decks.

    4.  Ceiling Tile — insulation board embossed and decorated

        for interior use.  It  is  also valued for acoustical

        qualities.

    5.  Lay-in-Panel — a finished tile board used in suspended

        ceilings.

    6.  Sheathing — a board used  in exterior construction due to

        its insulative,  bracing strength, and noise control qualities

        and its low price.

    7.  Sound Deadening Insulation Board — a special product

        designed for use in buildings  to  control noise levels.

    The American Society for Testing  and Materials, American National

Standards  Institute, U.S. National Bureau of Standards, and other agencies

set standard specifications for  the above product categories and others.

                                 II-4
                                                                Arthur D Little Inc

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                                                                  DRAFT
2.  Market Size and Future  Growth.
    Since 1965,  total U.S.  production as reported by the Bureau of the




Census, has fluctuated between  a  low of 1.16 million tons (3.0 billion




square feet, 1/2" basis)  in 1970  to a high of 1.55 million tons (3.9




billion square feet)  in 1973.   (Table II-2).  In 1971 and 1972 it appeared




that the insulation board industry was slowly losing its market and




steadily becoming more unprofitable as plants continued to close.  Six




plants have closed since 1960 and operations at two more plants were




severely cut back in 1977.   Since 1975 per  capita consumption of insula-




tion board has fluctuated between 11.3 and  13.5 pounds per person while




total U.S. production in 1976 was still below the 1973 peak, as shown in




Table II-2.  While the future  trend  for Insulation board is a declining




one, the current (1978) high levels  of housing  construction and the




demand for insulation stabilized production levels.




    Currently, trade directories indicate  that  64% of  the world's insula-




tion board capacity is located in the United States.   Government data on




insulation board imports and exports are  unreliable;  the volumes are small




and offsetting hence data are not shown.   However, imports have generally




been less  than 2.5% of domestic production according  to U.S. Forest




Service  data.




    Interior products account for 30% of  the total production  (on a 1/2




inch basis) and are mainly prefinished building board and  ceiling tile.




Exterior products, principally sheathing board and roof Insulation board,




represent  58% of production.  The remaining 12% includes  insulation board




used in  industrial applications, principally trailer  (mobile home) board.
                                 II-5






                                                                 Arthur D Little. Inc

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                                                         DRAFT
                      TABLE 11-2

        PRODUCTION OF INSULATION BOARD  1965-1976
Year
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Total2
(OOP Tons)
1258
1155
1176
1133
1352
1219
1446
1529
1547
1295
1240
1450

Per Capita
(Pounds)
12.9
11.7
11.8
11.3
13.3
11.9
14.0
14.6
14.7
12.2
11.7
13.5
Production
Per $ Billion of
New Construction1
(000 Tons)
15.9
14.5
15.1
13.8
16.4
15.5
16.9
16.6
16.6
16.2
17.9
19.8
Constant 1967  dollars.
2Annual growth  rate 1.6%
Note:  Government import/export data are unreliable. The
       volumes  are generally offsetting and less than 2.5%
       of sales; therefore, the data are not shown.
Source:  "The Demand and Price Situation  for Forest
          Products 1976-1977"
          USDA,  Forest Service Miscellaneous
          Publication 1357
                          TI-6
                                                       Arthur I) Little,Inc

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                                                                 DRAFT
Production of insulation board  in  these  three product classes and housing




starts is shown in Figure II-l1.




    The largest of interior products market has traditionally been non-




acoustical ceiling tile and lay-in panels.  This particular market has




dropped from 530 million square feet in  1972 to 321 million square feet




in 1976, largely as a result of stricter flame spread requirements adopted




in building codes.  The product, which had been widely used in nonresiden-




tial construction, is now limited  to the residential repair and remodeling




market.  Improvements in some fire resistance qualities have helped the




acoustical tile market grow  from  172 million square feet to 201 million




square feet over the 1972-1976  period and kept regular tile products from




losing even more of their market.  Sound deadening board has suffered




heavy market losses with volume slipping from 114 million square feet to




46 million square feet over the same period.  The future of the interior




products markets is highly dependent on  the ability of the manufacturers




to develop a better fire resistant board.  Arthur D. Little forecasts




the interior products market will  decline 5-6% annually through 1982.




    The largest of the exterior products markets is sheathing.  In this




application, insulation board is frequently used as a backup to brick




veneer.  Sheathing volume decreased from 1,608 million square feet to




1,368 million square feet over  the period 1972 to 1976; however, it should




be noted that 1972 insulation board sheathing production was the highest




in the past nine years.  The availability of price-competitive products




and the fact that many building codes permit exterior wood sidings to
1
 For a more detailed breakdown,  see Appendix Table A-l.
                                II-7





                                                               Arthur DLittklnc

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                                                                                  DRAFT
6
-2 "«
1  §
 r
CO  O
     1800

     1600

     1400

     1200

•2 £ 1000

| |  800
"2 I
| t   600
g
j«     400

      200
                          Housing Starts
                                                      Total Production
                                                                          Exterior
                                                                          Products
                                                                          Interior
                                                                          Products
                                                                         I ndustrial
                                                                         Products
                                                         2400

                                                         2200

                                                         2000
                                                         1800  -
                                                                                        1600
                                                                                             5
                                                                                        1400 |
                                                         1200

                                                         1000
1969     1970
1971
                                       1972
1973
Year
                                                       T974    1975
                                      1976
                                                                              1977
                  — — — Housing Starts

          Source: U.S. Department of Commerce, Current Industrial Reports, M26A.


                          FIGURE 11-1   INSULATION BOARD PRODUCTION
                                           II-8
                                                                                   Arthur D Little, Inc

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                                                                  DRAFT
provide rack1 resistance,  previously provided by plywood sheathing or

brick, are acting to cut back the insulation board sheathing market.

Also, insulation board sheathing products have an R-value of approximately

2.64 (°F ft2. Btu/inch).  This is considerably lower than most true insu-

lation products like fiberglass and  foams.  Furthermore, the sheathing

panels are usually 1/2 inch thick with  a resulting R-value of only 1.32,

which is below what is being required in energy conserving construction.

    Gypsum sheathing is insulation board's  chief competitor in the

sheathing market.  The 1977-1978 housing boom, however, has caused a

shortage of gypsum with the result being more insulation board is currently

used than would otherwise  have been  the case.  Gypsum is a good example

of a preferred cost competitive product.  New products such as foil

backed structural foams are also competing  in the sheathing market.  On

the other hand, roof insulation board has made a recovery with production

going from a nine-year low of 261 million square feet in 1972 to 549

million square feet in 1976.   As a result,  the total exterior products

market volume has increased 1.6% over the 1972-1976 period.  The exterior

product demand will weaken as housing construction slows and as capacity

comes on stream from competing products (approximately 10 plywood mills

and at least two foam panel plants are  currently under construction).

In view of these downward  pressures  on  demand, Arthur D. Little forecasts

the exterior products market to drop by 2.5-3.0 percent annually through 1982.
lacking strength — the  ability  of  the structural unit to withstand shear
 and bending stresses resulting  from various building loads.
                                II-9
                                                                Arthur D Little Inc

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                                                                   DRAFT
    The industrial market for  insulation board has dropped from  a nine-




year high of 718 million square  feet  in 1972 to 418 million square feet




in 1976.  Most of this loss  is due  to a drop of 243 million square feet




over the 1972-1976 period in the trailer board market, which was largely




a result of flame spread requirements in mobile homes.  The use of




insulation board for expansion joint  strips has also  fallen off dramatically.




Arthur D. Little estimates that  the industrial market will decrease 7-8




percent annually through 1982.



    The insulation board industry is  indirectly affected by the level of




hardboard imports; should the hardboard demand growth require more domestic




capacity, existing insulation board capacity can,  in  specific cases, be




converted to produce hardboard.   A general conversion from hardboard to




insulation board capacity, although it is  not likely, may also occur on a




limited basis during periods of  weak  demand for hardboard.




    In evaluating the overall growth  rate, it should  be remembered that




most insulation board is used in remodeling or new construction and is



thus cyclical in demand.  Various historic growth  rates were calculated,




based on data in Table A-l,  using a least  squares  time trend line to




minimize the influence of cyclicality. The market for exterior insulation




board products grew at 0.74% per year over the 1969-1976 period while




interior and industrial products grew at  an annual rate of 0.55% and -1.6%




respectively.  The annual growth rate for  total production over the 1969-




1976 period was 0.35%.  At the same time, the economy  in general has expe-



rienced real growth of about  3.0% per year, which  reflects the fact that




insulation board has been losing market share  to  competitive products for
                                 11-10
                                                                Arthur D Little, Inc

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                                                                  DRAFT
a long time due to the reasons discussed earlier.  The factors which




have contributed to the current  favorable supply/demand balance for




insulation board are temporary;  a strong housing market combined with




the shortage of gypsum sheathing will not persist.  Further competition




from competing products will become more intense.  In view of these




considerations, the aggregated market for insulation board is projected




to decline at an average rate of 5% annually through 1982 as shown in




Figure II-2.  However, the cyclical nature of construction activity




will cause short-term growth and contraction in demand typical of most




building materials.








D.  PLANT CHARACTERISTICS OF THE EXISTING INDUSTRY




1.  Process Technology•



    The basic operating technology of the industry is very similar to




the fourdrinier paper process and has not changed substantially since




its inception.  A cylinder screen type of mat forming system is also




used and has had some impact on  the volume of process water required.




Some improvements have also taken place in the fiber refining stage of




the production process.




    Technical developments that  have a significant impact on the




industry will arise from the market in terms of product substitution




or requirements for changes in product characteristics rather than



minor production process improvements.
                                11-11





                                                               Arthur D Little Inc

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                                                               DRAFT
3800
2200 -
2000
   1976        1977       1978




    Source: Arthur D. Little, Inc..estimates.
1979
1980
1981
1982
               FIGURE 11-2  INSULATION BOARD DEMAND. 1976-1982
                               11-12
                                                                Arthur D Little. Inc

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                                                                 DRAF'
2.  Size of Plants.

    Table II-3 lists each  plant  in  the industry by owner, location and

capacity.  Existing  plant  capacities range from 54 million to 400 million

square feet (on a 1/2 inch thick basis).  The mix of structural

and tile products at a given mill can have a substantial impact on the

stated mill capacity figure; a mill that produces interlocking ceiling

tile will produce 20% less board than an identical mill producing sheathing

due to trim losses and product configuration.  Plants producing pre-

finished building board and lay-in  ceiling tile will also have trim

losses considerably  in excess of sheathing mills.  Stated capacity

figures must be considered with  this in mind.

3.  Age Distribution.

    Table 11-4 contains an age distribution of plants.1 Age is a factor

in overall plant efficiency.  Twelve of the plants are over 20 years old

and all but one are  over ten years  old.

4.  Location.

    Ten of the 17 plants are located in the South and the remainder are

in Maine, Michigan,  Minnesota, Pennsylvania, and Oregon.  This distribu-

tion developed because of  the availability of wood fiber close to the

market and insignificant competition for wood resources in the South at

the time the plants  were constructed.  The sites are evenly distributed

between rural, suburban, and urban  areas.
1§rhe Celotex plant  in Marrero is excluded from this analysis because  it
 does not use wood  fiber as a raw material but is included in the discus-
 sion in order to present a complete picture of the industry.
                                11-13

                                                                Arthur D Little. Inc

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                                 TABLE I1-3
             INSULATION BOARD PLANTS IN THE UNITED STATES. 1977
                                                                     DRAFT
      Company
       Location
Abitibi
Armstrong Cork
Boise Cascade
Celotex
Celotex
Celotex
Celotex
Flintkote
Georgia Pacific
Huebert Fiberboard
Kaiser Gypsum
National Gypsum
Temple Industries
U.S. Gypsum
U.S. Gypsum
U.S. Gypsum

Weyerhaeuser
Blountstown, FL3
Macon, GA
International Falls,  MN
Dubuque,  IA
Marrero,  LA1*
L'Anse, MI
Sunbury,  PA3
Meridan,  MS
Jarratt, VA
Boonville, MO
St. Helens, OR
Mobile, AL
Diboll, TX
Lisbon Falls, ME
Pilot Rock, OR
Greenville, MS
Broken Bow(Craig),  OK
                    Total
  Annual1
 Capacity
(MMSF-1/2")
    150
    4002
    210
    737

    200
    210
     50
    150
    192
    220


    271
    300
   3090
                                                                   Other
                                                                  Products
                                                                Manufactured
    Hardboard
    Hardboard(l978)
    Hardboard
    Hardboard
(all facilities)
    Hardboard
       are approximate capacities as they depend  upon product mi::.  Figures
 quoted are for mills operating 24 hours/day,  6-2/3  days/week, 50 weeks/year.
 Understated due to heavy tile production.   If operated as a sheathing mill,
 capacity would increase 20%.
 3No effluent.
 ''Not considered in this analysis
 Sources:  1976 Directory of the Forest Products Industry, American Board
          Products Association, and Arthur D.  Little, Inc. estimates.
                                    11-14
                                                                   Arthur D Little Inc

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                            TABLE II-4
                                                             DRAFT
             AGE DISTRIBUTION OF INSULATION BOARD PLANTS
             Age (Years)

                0-19
               20-29
               30+
                                Total
Number of Plants

        5
        5
       _7
       17
                            TABLE II-5
             EMPLOYMENT LEVEL OF INSULATION BOARD PLANTS

             Number of Employees       Number of Plants
                  0-199
                200-299
                300-399
                400+
                                Total
        5
        5
        3
      _4
      17
Source:  EPA financial  308 survey data
                               11-15
                                                             Arthur D Little Inc

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                                                                  DRAFT







    Wood resources that  are  owned or controlled under long-term contracts




typically supply 30-50%  of the plants' raw fiber needs.  The balance




of each plant's fiber requirement is made up by open market purchases.




Four of the mills are part of multi-plant forest products production




complexes and derive a substantial portion of their fiber requirements




from the waste of other operations.




5.  Employment.



    The 1972 Census of Manufactures indicates the industry supported




6,100 employees on a payroll of  $59 million. As shown in Table II-5




most of the plants operate with  over 200 employees; however, relative




to the more basic wood products, such  as lumber and plywood production,




it is one of the less labor-intensive  segments of the industry.








E.  CHARACTERISTICS OF NEW PLANTS



    In the past nine years,  only one new insulation board plant has




opened.  Since 1960, six plants  have shut down.  In 1976 and 1977 two




large plants announced major cutbacks  in their operations.  In 1978




Georgia Pacific is expected to  divert  some  of the wet process capacity




in Jarratt, Virginia from insulation board  to hardboard siding but will




operate both production lines.   No companies have announced any inten-




tions, plans, or desires to build additional insulation board capacity.








F.  COMPETITIVE STRUCTURE




1.  Market Structure.



    The  industry has become more concentrated since 1960 when 23 insula-




tion board plants were operated by 17  firms.  Currently, as Table II-6




shows,  the  top  three firms  control 47% of  industry  capacity and the  top




                                 11-16



                                                                Arthur D Little Inc

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                TABLE I1-6

CONCENTRATION IN THE  INSULATION BOARD INDUSTRY
                                                  DRAFT
     Firm
Celotex


Armstrong Cork


Weyerhaeuser


U.S. Gypsum


Temple


All Others (7)


Total
% Capacity

    24


    13


    10
    37
   100
Sources:   American Board Products Association,
          and Arthur D. Little, Inc.  estimates
                   11-17
                                                Arthur D I.ittklnc

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                                                                  DRAF'
five firms control 63%.  As product demand declines and plants close or




convert to other products, the industry is expected to become more




concentrated.




2.  Pricing Mechanism.




    The economic justification for construction of insulation board




plants was based on  the use of waste from other forest products mills




as the basic raw material supply.  While this raw material was initially



very inexpensive, increased competition for wood chips, as well as rising




energy, labor and pollution control  costs have increased insulation




board costs since 1972. Table II-7 exhibits the price history for




three insulation board  products  for the period 1965-1976.




    Insulation board prices are  usually quoted on a dollar per thousand




square feet basis,  f.o.b. shipping point with full freight allowed to the




destination.  Insulation board sheathing prices increased 57% between 1965




and 1976 with a 30%  increase  occurring since 1973.  The price of ceiling




tile has also increased 57% since 1965, but registered only a 15% increase




since 1973.  It should  be noted  that ceiling tile prices reflect the




higher value-added manufacturing steps and are more than double the price




of sheathing; therefore, while the percentage increases for the 1965-1976




period are equal, the absolute dollar price increases for ceiling tile




are more than double the price increases for sheathing.




    The major pricing constraint for insulation board is created by




price levels of substitute products rather than intra-industry competi-




tion.  The price comparisons  must be made on the basis of performance




value, not unit costs.   The  triple role of insulation board as a structural,








                                 11-18






                                                                Arthur D Little, Inc

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                                                           DRAFT
                       TABLE II-7
       PRICES OF SELECTED INSULATION  BOARD PRODUCTS1
Year
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
(dollars
1/2 Inch2
Sheathing
37.09
36.45
36.01
38.17
40.73
36.91
37.78
42.06
44.98
49.23
50.20
58.31
66.05
ir.) 74.87
per thousand square
Roof Insulation3
Board
63.78
65.15
65.02
64.17
65.15
67.16
66.06
66.19
67.56
84.59
100.13
107.80
N/A
N/A
feet)
Ceiling Tile1*
83.05
83.75
87.24
91.78
97.88
103.38
109.14
112.28
113.32
117.16
121.87
130.42
N/A
N/A
^.o.b. mill with  freight allowed to destination.
2standard density, 1/2" x2' x8' to 4'  x 9" with asphalt impregnation
 or water resistant  coating, manufacturer to wholesaler.
31" x 21 x 4",  asphalt treated, manufacturer to roofing contractor.
**l/2" x I1 x I1, 1x2', or 1 x 3', factory painted plain surface,
 beveled edges, manufacturer to wholesaler or  retailer.
Source:  U.S.  Bureau of Labor Statistics
                           11-19
                                                         Arthur D Little, Inc

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                                                                  DRAFT
decorative, and insulation  product make price comparisons particularly




difficult. To illustrate,  the March  1977 price for 1/2 inch insulation




board sheathing was $58.71  per thousand square feet, while the price of




1/2 inch plywood sheathing  was $190.  On this basis, the insulation




board appears to be a better value.  However, in use, a siding material




must be applied over the sheathing.  An alternative wall construction




is to use fiber glass insulation and a plywood or hardboard siding




product that provides both the strength of  the sheathing, a finished




outside wall, and a better R-value  for the  complete wall.  The construc-




tion costs of the fiber glass/siding wall are lower than a sheathing/




siding wall and the higher quality  insulation will result in lower long-




term heating costs.  Ultimately, what appeared to be a major price




advantage for insulation board becomes insignificant.  Gypsum sheathing




has been very competitive with insulation board on a price/utility basis




for years and has established itself as  the preferred sheathing material




in many areas.  Structural foams are also beginning to appear on  the




market and will also compete strongly on a  performance value basis with




insulation board.




    Commercial structures have used large quantities of insulation board




in the past for ceiling tile, lay-in panels, and roof deck insulation.




Fire code restrictions have severely cut back  the use of the material




in these applications.  The insulation board roof decking has also met




with strong competition from perlite and rigid fiber glass boards.  Until




a fire retardant insulation board ceiling  tile is on the market and




widely accepted in building codes,  the price of  insulation will not




stimulate demand and plastic or mineral board  substitutes will dominate




the nonresidential market.
                                  11-20
                                                                Arthur D Little Inc

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                                                                 DRAFT
3.  Price Elasticity of Demand.




    Price changes in insulation  board  from 1965-1976 have been moderate




compared to price changes of lumber, plywood, and other wood products




with which it competes.  Evidence of this situation, as shown in Table




II-8, appears in the fact that while the 1976 wholesale price index (WPI)




for insulation board products was 160.8, (1967=100) the WPI for all con-




struction products had risen to  187.7  but the general inflation index




was at 159.0.  Thus, while insulation  board  prices have lagged behind




those for other construction materials,  they have kept pace with general




inflation and thus have experienced no real  price increases.  There are




several factors that contribute  to this  situation.




    First, there is a cost-price relationship which may have allowed




the industry to maintain its accepted  level  of  profitability without




increasing prices due to improved plant efficiency and the resulting




lower costs.  However, given the recent history of wood costs, compe-




tition for fiber, and costs of finishing materials, it is not likely




that this will continue to be a  major  factor.




    Secondly, the industry may have absorbed the impact of lower margins




per unit by increasing production volumes with  added shifts at the same




facilities and low cost incremental investments to increase capacity.




The closure of six plants since  1960 while  production continued to




increase slightly is an indication this has  happened, to a limited degree,




in  the remaining plants.  This course  of action could, depending on




volume-price relationships, result in  level rates of return as a con-




sequence of lower per  unit margins on  greater volumes produced at  the




same facility.




                                  11-21
                                                                Arthur D Little Inc

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                                              TABLE II-8

                        PRICE INDEXES FOR SELECTED INSULATION BOARD PRODUCTS1'5
(1967 = 100)
All Construction
Materials Price 1/2 inch2
Year Index Sheathing


M
hH
1
N>
KJ










1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978 (March)
95.8
98.8
100.0
105.6
111.9
112.5
119.5
126.6
138.5
160.9
174.0
187.7
204.9
221.9
103.0
101.2
100.0
106.0
113.1
102.5
104.9
116.8
124.9
136.7
139.4
161.9
183.4
207.9
Roof Insulation3 Ceiling4
Board Tile
98.1
100.2
100.0
98.7
100.2
103.3
101.6
101.8
103.9
130.1
154.0
165.8
N/A
N/A
95.2
96.0
100.0
105.2
112.2
118.5
125.1
128.7
129.9
134.3
139.7
149.5
N/A
N/A
All
Insulation
Board
98.2
98.4
100.0
103.0
108.8
110.5
114.4
119.0
121.7
133.9
144.0
161.0
177.9
196.8
5See footnootes 1,2,3,  and 4 on Table 6
6Changes in composite index for all insulation
Source:  U.S. Bureau of Labor Statistics
board products
                                                                                         Percentage
                                                                                         Change Over
                                                                                        Previous Year
                                                                                             0.2
                                                                                             1.6
                                                                                             3.0
                                                                                             5.6
                                                                                             1.6
                                                                                             3.6
                                                                                             3.9
                                                                                             2.3
                                                                                            10.0
                                                                                             7.5
                                                                                            11.8
                                                                                            10.5
                                                                                            10.6
                                                             3

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                                                                 DRAFT
    Finally, there is a market-price relationship.  Insulation board may




have to keep down its prices  to meet competition from substitute products




such as gypsum and maintain its market shares.  While there is probably




some cross-elasticity of  demand between insulation board and competing




products, price is not the principal reason for utilizing insulation




board.



4.  Barriers to Entry of  New  Firms.



    Insulation board is  capital  intensive  compared with the production




of other solid wood products  such as plywood  and lumber.  Other than




capital requirements, significant barriers include securing a wood




source and, depending on the  product line, the scale of the required




marketing effort.  Tile products would require a larger sales effort




than sheathing because of the proprietary  nature of the product.




5.  Other Regulatory Factors.



    It should also be noted that a result  of  government timber policy




restricting the harvest of federal timber  on  the West Coast would be to




lower supplies and push up prices of  lumber and plywood.  This would




probably result in increasing demand  for  fiberboard and would allow sub-




stantial price increases.  An easing  of  government timber policy that




would allow a higher level of removals  from West  Coast  forests, which




is  equally  likely at this time, would have the opposite effect.
                                 11-23





                                                                Arthur D Little Inc

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                                                                 DRAFT
C.  FINANCIAL PROFILE




    The range of  sales and plant book values for insulation board plants




is shown in Table II-9, as well as the pro-forma cost  of  manufacture.




Plant sales vary  directly with production.  However, plant book values




differ for similar size plants due to plant age and other factors.




    While the distribution of manufacturing cost differs  by size of



plant, there appear to be significant differences in relative  cost due




to other factors.  A number of insulation board plants appear  to be




operating at a loss and operating margins overall are  small compared




with hardboard plants.  The future outlook for insulation board demand




indicates that the financial condition of some insulation board plants




will worsen as capacity utilization rates fall.  It is also likely that




insulation board  plants will shut down or convert to other products in



the face of falling demand.
                                 11-24




                                                               Arthur D Little Inc

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                                                              DRAFT
                          TABLE II-9

                       FINANCIAL PROFILES
                            ($000)
                              INSULATION
                                BOARD

SALES (1976)                     $8,500,000  (range $3-30 Million)

CAPACITY                        125 Million Square Feet

CAPACITY BASE                      1/2"


Pro-forma Cost  of Manufacture   Median Value       Range of Values

Sales                            100%                 100%

Cost of Sales

  Labor                           25                  15-31
  Materials                       35                  30-50
  Depreciation                      4                   2-8
  Other Expenses                   20                   2-44

Total Cost of Sales                84

Gross Margin                      16                   8-24


Selling G&A                       10                   7-18

Interest Expense


Profit Before Tax                   6                  <0-13

Tax                                3

Profit After Tax                    3%                 <0-7


Plant Book Value ($000)         7,000                500-25,000

 SOURCE:   EPA Financial 308 Survey data.
          Excludes plants producing  both insulation board  and hardboard.



                              11-25


                                                             Arthur DLittklnc

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                                                                  DRAFT
        III  INDUSTRY  CHARACTERIZATION - WET PROCESS HARDBOARD
A.  INDUSTRY DEFINITION

    In characterizing the wet  process segment of the hardboard industry,

it should be emphasized that wet  process mills are only one segment of

the hardboard production capacity.  The industry1 is composed of two

segments, wet process and dry  process, that serve the same markets with

similar products and are largely  operated by the same companies.  The

wet process hardboard industry is comprised of establishments producing

hardboard in densities generally  between 31-65 pounds per cubic foot

from inter-felted wood fiber  using a wet forming and either a wet or dry

pressing process.  The dry process segment of  the industry uses a dry

forming and pressing process  to manufacture hardboard.



B.  TYPES OF FIRMS

1.  Size of Firm.

    There are 15 producers operating  28 wet and dry process plants.

(These are identified in Table III-l)  The  industry is  composed of three

private  firms and several large corporations.  Seven of the 15 hardboard

producers operate more than one hardboard plant.  Wet process plants

represent 16 of  the  28 facilities and are operated by eleven producers;

four of  these producers operate more  than one  wet process plant.
 Standard  Industrial Classification 2499, "Wood Products  Not  Elsewhere
  Classified"  includes, among other industries, medium density fiber-
  board, wet process hardboard, and dry process hardboard.   SIC data
  does  not  distinguish among these three industries.

                                 III-l

                                                                 Arthur D Little: Inc

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                            TABLE III-l

                  1977 HARDBOARD PRODUCTION CAPACITY

                  (million  square feet - 1/8" basis)

                           WET-WET PLANTS1
                                       DRAFT
        Company
Abitibi2
Abitibi
Evans Products
Forest Fiber
Masonite
Masonite
Superior Fiber
Superwood
Superwood
Champion International
Abitibi2
Boise Cascade
Temple
Weyerhaeuser
U.S. Gypsum
U.S. Gypsum
U.S. Gypsum
     Location
Annual Capacity
Alpena, MI
Roaring River, NC
Corvallis, OR
Forest Grove, OR
Laurel, MS
Ukiah, CA
Superior, WI
Duluth, MN
N. Little Rock, AK
Dee, OR
                Subtotal

 WET-DRY PLANTS2

Alpena, MI
International Falls, MN
Diboll, TX
Craig, OK
Danville, VA
Pilot Rock, OR
Greenville, MS
                Subtotal
Total - Wet Process
      329
      700
      244
      175
      230
       86
      155
     1919
     5812
Boise Cascade
Celotex
Champion International
Champion International
Georgia Pacific
Georgia Pacific
Louisiana Pacific
Masonite
Publishers Forest Prods.
Superwood
Weyerhaeuser
Weyerhaeuser
                     Total
                     Total
   DRY PLANTS3

Phillips, WI
Paris, TN
Catawba, SC
Lebanon, OR
Convay, NC
Coos Bay, OR
Oroville, CA
Tovanda, PA
Anacortes, WA
Bemidji, MN
Doswell, VA
Klamath Falls, OR
Dry Process Capacity
Hardboard Capacity
       80
      195
      225
      107
      265
      201
      150
      490
       52
       90
      315
      290
     2460
     8272
     Masonite mills and the Abitibi mill in Alpena,  MI  use  combinations
 of  the wet-wet and wet-dry processes.

 2There are wet-wet and wet-dry operations at this  location.

 3Does not include medium density fiberboard (MDF)  plants  as  it  is a
 different product used in different applications.

 Sources:  1976 Directory of the Forest  Products Industry. American
          Board Products Association, and Arthur D.  Little,  Inc.
          estimates.
                                                                  Arthur 01 Jttklnc
                                 III-2

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                                                                  DRAFT
    The larger corporations involved  in  the wet process board industry




include Masonite, Champion International, Weyerhaeuser, and U.S. Gypsum.




In terms of production capacity,  the  largest private company, Superwood,




is the fourth ranked producer in  the  industry while the two remaining




private firms are among the smallest  producers.




    Available information shows that  total annual sales for companies in




the wet process segment of the hardboard industry, including sales from




operations such as lumber, plywood, paper, chemicals, and others, range




from $25 million to over $3.6 billion as shown in Table III-2.  The




relative importance of a particular plant to a particular firm is thus




a unique factor in each case, as  also shown in Table III-2.




2.  Ownership/Integration/Product Diversification.




    Twelve of the wet process hardboard  mills are owned by 8 publicly




held corporations; the four remaining mills are owned by three private




companies.




    The public corporations are frequently integrated back to raw




material sources as owners of woodlands  and they typically supply 35-45




percent of their raw material needs from these captive sources.  The




private companies are also likely to  own limited woodlands but do not




typically derive as large a percentage of their wood requirements from




these sources.




    Six of the parent companies operate  captive distribution systems




that handle a portion of their output.  The remaining producers sell




their products through independent wholesalers or through the captive




distribution systems of other companies.
                                  III-3
                                                                 Arthur D Littk Inc

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                                                               DRAFT
                           TABLE  III-2
                        1977 HARDBOARD SALES
(All Producers, $MM)
Company
Abitibi Paper Co. Ltd.
Boise Cascade
Celotex/Jim Walter1
Champion International
Evans Products
Forest Fiber
Georgia Pacific
Louisiana Pacific
Masonite2
Publishers/
Times Mirror Co.
Superior Fiber/
Carlson Companies Inc.
Superwood
Temple/Time Inc.
U.S. Gypsum
Weyerhaeuser
Total
Corporate
Sales*
800
2316
525/1422
3127
941
N/A
3675
794
445
NA/976
NA/650
N/A
340/1038
1177
3283
Total**
Hardboard
Sales
72
66
17
34
9
9
40
13
247
5
13
-
21
40
66
                                                     Wet Process**
                                                      Hardboard
                                                        Sales
                                                          72
                                                          60
                                                           7
                                                           9
                                                           9
                                                         206
                                                         13
                                                         44
                                                         21
                                                         40
                                                         15
fiscal year ends August  31
2Fiscal year ends October 31
Sources:   *Dun and Bradstreet Directory,  1978,
           Directory of  Corporate Affiliations, 1978
         **Arthur D. Little estimates,  based upon an operating
           rate of 100%  and the prices  shown in Table III-7.
                                III-4
Arthur D Little; Inc

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                                                                  DRAFT
    In addition to hardboard products, all of the parent companies are
involved in the production and distribution of a wide range of other
competing and non-competing wood products and various building
materials.  Many hardboard operations are parts of forest products
production complexes  that may produce various combinations of lumber,
plywood, particleboard,  fiberboard, pulp, or paper.  The parent com-
panies generally have a  strong orientation towards forest products (five
are involved in the  paper industry) and may produce other building
materials such as gypsum board.  Three of the firms are significantly
diversified beyond building materials businesses.


C.  PRODUCT DESCRIPTION
1.  Types of Hardboard Products.
    Hardboard products can be divided into five classes on the basis of
water resistance, modulus of rupture, and tensile strength.  The five
classes listed in order  of decreasing strength properties, include:
                               tempered
                               standard
                               service-tempered
                               service
                               industrial!te
    The hardboard products  described  serve four general markets:
interior  paneling, exterior  siding, industrial and do-it-yourself.
Most  of  the mills have fabricating facilities associated with  them to
produce prefinished paneling,  panel stock, siding, perforated  board,
embossed,  molded, and/or cut-to-size  products.
                                 111-5                          Arthur DLittklnc

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                                                                  DRAFT
    Hardboard serves a very  wide  range of end uses requiring an




estimated 800 different sets of specifications.  Marketing efforts




have usually been aimed at displacing traditional products such as




gypsum, plaster,  stucco, and plywood in  specific applications.




Hardboard is challenging and being challenged by these products and




others in various markets and applications.




    Interior paneling may be manufactured from any of the five classes




of hardboard in thicknesses  of 1/8 to 1/4 inch.  Panels up to 5 feet




wide and 12 feet long are available.  It is estimated that hardboard




was used as the substrate in 20-40% of the interior paneling sold in




1973, with its major competition  being inexpensive lauan plywood,




domestic hardwood plywood, and thin particleboard.  It is used for




both wood-grain prints and tileboard panels.  The surface of the panel




may be embossed to provide a surface  texture or pattern before the




desired finish is applied.  The hardboard manufacturer may produce and




sell prefinished paneling, unfinished paneling stock, or both.




    Siding is manufactured specifically  for exterior use.  Lap siding




is manufactured in thicknesses of 3/8 inch and greater, widths of 4 to




12 inches, and lengths up to 16 feet  in  two-foot increments.  Panel




siding is fabricated in sheets 4  feet wide, 4 to 12 feet long and is




usually 1/4 inch thick or thicker. Hardboard was introduced to the




siding market in the late 1940's  and now competes against PVC, aluminum,




brick, stucco, plywood, and other wood  siding materials.  Textures simu-




lating most other siding materials, as well as improved finishes, have




increased hardboard's market share in  residential siding and will probably
                                                                Arthur D Little Inc

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                                                                 DRAFT
continue to do so.   Hardboard  siding is now also gaining market share in




mobile home applications  and Arthur D. Little expects this trend to




continue.




    The industrial  market for  hardboard encompasses a very wide range of




end-user and OEM (original equipment manufacturer) applications




including:  displays,  furniture,  transportation, electronics, interior




construction, factory  equipment,  and toys.  The list of actual and




possible uses is extremely diversified.  Most industrial markets require




the hardboard manufacturer to  meet a unique set of specifications per-




taining to board characteristics  and/or fabrication requirements.  The




industrial market is so diversified that competition from substitute




products in any one segment has only minimal impact on the overall




hardboard market.




2.  Market Size and Future Growth.




    Recent economic trends have been generally favorable to the industry.




Per capita consumption has increased 3.7% annually since 1964.  Tables




III-3 and III-4 show production and consumption data for the years 1964-




1976.  Shipments from  domestic plants  totalled 7.1 billion square feet




in 1976 reflecting an  average  annual growth rate of 9.4% since 1964.




The industry slowdown  in  1974  and 1975 was followed by a strong




recovery in 1976.




    Import data from Table III-3  indicate that imports are very sensitive




to economic conditions.  It is apparent that imports suffered a severe




market share setback in 1974-1976 and  are only beginning to recover; in




1976 imports were only 6.5% of consumption.  Brazil is by far the largest
                                                                Arthur D Little Inc

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                                                          DRAFT
                          TABLE III-3




     SHIPMENTS, IMPORTS. AND APPARENT CONSUMPTION — 1964-1976

1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
(million
U.S. Shipments
2689
2921
3083
3038
3710
4247
4384
5225
5798
6475
6057
6238
7066
square feet
Imports
471
572
443
426
648
708
457
634
1070
1039
750
277
494
- 1/8" basis)
Apparent
Consumption
3160
3493
3526
3464
4358
4955
4841
5859
6868
7514
6807
6515
7560

Imports as a
% of Consumption
14.9
16.4
12.6
12.3
14.9
14.3
9.4
10.8
15.6
13.8
11.0
4.3
6.5
Source:  American Board Products Association
                             III-8
Arthur D Little, Inc

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                                                      DRAFT
                   TABLE




CAPACITY UTILIZATION BY HARDBOARD INDUSTRY - 1967-1976
(million square feet - 1/8" basis)

1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Annual
Capacity
4555
4648
5019
5335
6000
7791
77811
77711
7771
8272
U.S.
Shipments
3038
3710
4247
4384
5225
5798
6475
6057
6238
7066
Capacity
Utilization
(%)
67
80
85
82
87
74
83
78
80
85
Arthur D. Little, Inc.  estimates.
Source:  American Board Products Association
                                                   Arthur D Little. Inc

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                                                                  DRAF"
source of hardboard imported by  the United States; the USSR, Sweden,  and




Canada are also of significance  with Poland, Romania, Korea, and a




number of other countries  selling hardboard in U.S. markets in varying




quantities.  Reliable export data are unavailable but levels are believed




to be below 2% of domestic production.  The United States will remain a




net importer of hardboard, despite the recent drop in imports, due to




the relatively low cost of hardboard purchased from foreign sources.




    Operating rates for the domestic producers are shown in Table III-4.




Capacity utilization declined  significantly in 1972 due to a 30% increase




in capacity in that year,  and  again in 1974 due to market conditions.




Precise data on 1977/1978  are  unavailable but the industry is believed




to have operated at 85-95% rates.




    Historically, losses in one  market have been offset to a greater or




lesser extent by gains in  another.  For example, hardboard continues to




lose automotive markets; the  technological trend toward light automo-




biles has resulted in the  use  of lightweight plastics in applications




where hardboard was formerly  the dominant material.  On the other hand,




the minimal quantities of  petrochemical adhesives and relatively low




energy intensity required  in hardboard manufacture protect the industry




from what could be a severely  negative impact of increased resin costs




on plastics and other siding products such as brick and have helped to




stimulate demand for hardboard siding.




    In evaluating the overall  growth rate, it should be remembered that




roughly 60% of hardboard is used directly in construction or is affected
                                111-10                           Arthur D Little Inc

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                                                                  DRAFT
by construction demand,  while most of  the  remainder is used in indus-




trial applications.  Shipments of hardboard  do  follow the trends of the




construction industry but the volatility of  hardboard shipments is




dampened somewhat by its industrial market.   This relationship is shown




graphically in Figure III-l.   Analysis of  1964-1976 shipments and con-




sumption using a least squares linear-time trend results in annual




growth rates of 9.4% and 8.5%, (standard error  of estimates were 7% and




10%) respectively.  Growth rates in the 1972 to 1976 period for ship-




ments and consumption were roughly 4%  and  1.5%  respectively due to an




industry slowdown in 1974 and 1975. The slower growth rates for consump-




tion are a result of changes  in the level  of imports which vary widely




and have recently decreased substantially.




    The consumption growth rates indicate  that  hardboard's share of the




construction materials market has increased. The economy in general




experienced a growth rate of  about 3.0% per  year for the period, and




construction in 1976 remained below 1972 levels.  This market share




growth trend can be expected  to continue,  and long-term growth in con-




sumption will average 2.5-3.0% annually through 1982 with short-term




trends following the construction cycle (see Figure III-2).








D.  PLANT CHARACTERISTICS OF  THE EXISTING  INDUSTRY




1.  Process Technology.




    Wet process mills are those operations that use a pulping process




that requires large amounts of water and a wet  mat forming system similar




in some respects to the fourdrinier paper  forming process.  In wet-wet
                                111-11                          Arthur D Little Inc

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                                                                          DRAFT
     7500
.1 j  6500

s. r
     5500
s  I
f  I
     4500
CO =

=) E
     3500
                              Construction


                              Expenditures
                 y——
                                j	I
                                                   i    i     i    i
                                                       95




                                                       90


                                                           i

                                                       85  | _




                                                       80 ||
                                                       75 t  5
                                                          o  o
                                                          •£  -D
                                              70





                                              65




                                              60
                                                          •

                                                          C
                                                                                X

                                                                                LU
            1964
1966
1968
1970


Year
1972
1974
1976
         Source:  U.S. Department of Commerce, American Board Product Association.
    FIGURE 111-1  HARDBOARD CONSUMPTION AND CONSTRUCTION EXPENDITURES - 1964-1976
                                       111-12
                                                                           Arthur D Little. Inc

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                                                                 DRAFT
8°
                1977
1978
1979
1980
1981
1982
       Source: Arthur D. Little, Inc., forecasts.
                  FIGURE III-2  TOTAL HARDBOARD DEMAND, 1976-1982
                                  111-13
                                                                  Arthur D Little. Inc

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                                                                  DRAFT
mills, the wet mat is pressed between a  flat hot platen and a rigid




screen that will allow steam to  escape from the board.  The board pro-




duced in this manner is called an  SIS or screen back board.  In wet-dry




mills, the same mat described above is dried before pressing so it can




be pressed between two flat hot  platens  producing a board with a smooth




surface on both sides (S2S).  In dry process mills, the mat is formed




from dry fibers in an air inter-felting  process.  The dry mat is pressed




between two flat hot platens thus  producing an S2S board.  One mill uses




a dry-wet process in which the mat is dry formed, as described above,




then water is added and it is pressed between a flat hot platen and a




screen resulting in an SIS board.   Furthermore, insulation board capacity




may be converted to produce wet  process  hardboard  (and vice versa).




    Technical developments in wet  process hardboard have been limited




and slow.  As a result of design changes in caul plates used in wet




pressing operations, wet-wet mills can produce a S2S hardboard with




minimal sanding.  This development allows wet-wet mills to compete in




S2S markets against wet-dry and  dry-dry  mills.




    Developments that hold potential for lower costs are important to




this industry because of the product substitution possible in most




markets; likewise, adverse cost  developments are of equal significance.




The full impact of energy costs, for example, on energy-intensive




pulping processes (e.g., the explosion  process) may affect hardboard's




cost effectiveness relative to substitute products in  the future.




    There are no foreseeable technical  developments  that will have a




major  impact on the hardboard industry.   The  technology of  the wet
                                                                Arthur D Little Inc

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                                                                  DRAFT
process hardboard industry has  remained  generally static since the de-



velopment of dry process mills  eliminated many of the water pollution



problems facing the industry.   Dry  process  technology is a threat to the



wet process mills to the extent that  it  makes possible the manufacturing



of hardboard which competes with the  products of the wet process mills



without incurring water pollution abatement costs.  This problem will



be partially offset by air pollution  control expenditures that will be


required for dry process mills.  It is,  of  course,  theoretically possible



to convert a wet process mill to a  dry process mill; however, the


capital costs involved would make the operation both uneconomic and


uncompetitive; thus, conversion to  dry processes is an unlikely response



to revised effluent regulations.



2.  Size/Age/Location.


    A  typical wet process plant produces 230 million square  feet  (MMSF -


1/8 inch) annually, while individual  plant  capacities range  from 52-1850



MMSF.  (Table III-l)  Although the largest plant  is  also  the  oldest


(Masonite started operations in Laurel,  Mississippi in 1926), generally,



the older plants tend to be smaller.


    Table III-5 shows the age distribution  of wet process hardboard


plants.  Prior to 1948 only three hardboard plants  were  in operation in



the United States and they all used a wet process.  Of  the six plants


built  in the 1948-1957 period, five were wet process mills and one was


a dry  process mill.  The next decade brought six wet and five dry process


mills.  Since 1968  two wet process mills have been  built (both in 1970)



while  six dry process mills have started production.   Currently  there are
                                111-15                           A  ,    IAI  .  .
                                                                 Arthur D Little Inc

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                                                               DRAFT
                           TABLE III-5

            DISTRIBUTION OF HARDBOARD PLANTS BY PLANT AGE
            Year of  Start-up            Number of Plants
                                        Wet*       Dry**
            Prior to 1948                  3          0
            1948-1957                      5          1
            1958-1967                      6          5
            1968 to  present               _2         _£
                               Total      16         12
                            TABLE III-6

             EMPLOYMENT IN WET PROCESS HARDBOARD PLANTS
             Number of Employees      Number of Plants
                  0-199                       8
                200-399                       5
                400+                        _3
                                   Total     16
Source:   *EPA financial  308 survey.
        **Arthur D.  Little estimates
                               111-16                         .  .   _.  .  .
                                                              Arthur D Little Inc

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                                                                  DRAFT
sixteen wet process mills  (including seven wet-wet, six wet-dry, and




three operations using both processes) and twelve dry process mills in




the United States.   Additions  to existing mills did not necessarily




use the same process;  three mills are actually a combination of wet




forming and both dry and wet press  lines.  This gives these mills




additional flexibility in  meeting market demands by producing either




SIS or S2S hardboard.   Most of the  older plants have been continually




expanded and modernized so age is not a valid indication of efficiency.




    The first two plants were  constructed in Mississippi and used




roundwood as their fiber source.  Later expansion of the industry in




the North Central states depended on inexpensive hardwoods while mills




in the Pacific states  used wastes from softwood lumber and plywood




operations as fiber sources.   The fact that hardboard mills are evenly




spread throughout these regions is  indicative of the wide range of wood




species being used in  hardboard and the significance of low cost fiber




to the producer.  Most of  the  plants are located on rural sites but




several are in urban and suburban areas.




3.  Employment.



    Most plants employ between 100  and 300 workers and staff as shown



in Table III-6.  Employment  figures for each mill are dependent upon the




size and product mix of the  facility.








E.  CHARACTERISTICS OF NEW CAPACITY




1.  Recent Capacity Additions.



    No new wet hardboard plants have come on stream since 1970; however,



several locations have added substantial capacity.  In addition to large
                                 irl-17                          Arthur D Little Inc

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                                                                  DRAFT
capacity expansions  in  1972, Masonite completed a 175 MMSF expansion of




its wet process plant in Ukiah, California in 1977.  Abitibi also com-




pleted small expansions of  the Alpena and Roaring River facilities.  The




100 MMSF addition to the Weyerhaeuser plant in Doswell, Virginia was the




only dry process expansion.  Boise Cascade diverted some of the insulation




board capacity at International Falls, Minnesota, to add 100 MMSF to




its hardboard capacity.  At least five plants added incremental volumes




to their siding production  capacity.




    Announced plans  for capacity additions in 1979 include construction




of a 66 MMSF of 7/16 inch wet process hardboard siding mill at Georgia




Pacific's insulation board  plant in Jarratt, Virginia.  Temple Industries




has also announced a $21 million addition to its wet process facility to




produce hardboard siding.  No further information has been made public




about these projects or any others.




2.  Process Economics of New Capacity.




    It is extremely unlikely that anyone would build a wet process S2S




mill.  Capacity addition would most likely take the form of incremental




expansion of existing facilities or perhaps the conversion of insulation




board capacity.  However, process economic models were constructed for




greenfield expansion, conversion of an insulation board plant and incre-




mental expansion.




    Table III-7 contains the capital investment and the operating cost




for each of the wet process hardboard expansion methods.  The parameters




of any expansion or conversion are extremely variable and unique to




every case.  Thus the data shown in Table III-7 are not applicable to any




specific situation.   Incremental operating costs per thousand square feet
                                TI1-18                          Arthur D Little Inc

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                                                       TABLE  111-7
                                  PROCESS ECONOMICS OF NEW WET PROCESS HARDBOARD CAPACITY
M
           Design Production  (MMSF, 1/8")
           Capital Investment

           Operating Cost  ($ millions)
              Labor
              Wood
              Other Materials
              Energy
              Other Costs

           Operating Cost/MSF
           Investment/ MSF
                                                  Greenfield Mill
                                                         293
                                                     $50 million
    Conversion of
Insulation Board Mill
          234
  $25-28 million
Incremental Expansion
          117
    $15-20 million
10.2
4.2
4.2
3.6
2.0
24.2
$82.59
$170.65
9.0
3.4
3.4
3.2
1.6
20.6
$88.03
$113.70
3.7
1.7
1.7
1.3
0.8
9.2
$78.63
$149.57
            Source:  Arthur D. Little estimates.  See Appendix A-2 for assumptions underlying costs.
c
LT
(1
R
                                                                                                                        3

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                                                                 DRAFT
are lowest for capacity added  through  incremental expansion, followed




by that for a greenfield mill  and  insulation board plant conversion.




Investment cost per thousand square  feet are highest for a greenfield




plant and lowest for an insulation board plant conversion.









F.  COMPETITIVE STRUCTURE




1.  Market Structure.




    The five largest firms  control 70.5% of the total hardboard pro-




duction capacity.  Masonite Corporation, by far the largest firm in




the industry, controls 35.1% of  the  total hardboard capacity and 41.5%




of the wet process hardboard capacity, as shown in Table III-8.  Wet




process mills represent 70.3%  of the total U.S. hardboard capacity.




2.  Pricing Mechanism.




    Table III-9 exhibits the price history for tempered hardboard.  The




ability of the industry to  pass  increases in production costs on to the




marketplace is of major importance in  considering the question of whether




or not hardboard producers  will  be able to continue operations with the




burden of additional pollution control costs.




    Prices are quoted on a  dollars per thousand square feet basis and




are usually based on standard  units  and sizes.  Prices are generally f.o.b.




mill with full rail freight allowed  to the destination.  Due to the wide




range of end uses, prices,  and customer categories, hardboard prices are




set at a number of levels depending  on the class of trade of the purchaser.




Frequently specific hardboard  prices involve a complicated schedule of




discounts and extras dependent upon  the size of the load, packaging, style




of the product, degree of fabrication, quality, etc.
                                in-20                          Arthur D Little. Inc

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                                                            DRAFT
                            TABLE III-8
                    HARDBOARD INDUSTRY CAPACITY
                                           Wet Process
     Firm
Masonite
Abitibi
Weyerhaeuser
Boise Cascade
Superwood
U.S.  Gypsum
Champion
Temple
Superior Fiber
Evans
Forest Fiber
Percent of
Total Capacity
35.1
10.2
9.4
8.5
7.3
5.7
4.9
2.9
1.9
1.3
1.4
88. 61
Percent of
Capacity
41.5
14.5
3.0
12.0
8.8
8.1
1.3
4.2
2.7
1.9
2.0
100.0
Percent of Firm's
Hardboard Capacity
83.1
100.0
22.4
89.7
85.0
100.0
18.6
100.0
100.0
100.0
100.0
81. 72
1Four other firms are  operating only dry process mills.
^Average

Source:  American Board Products Association
                             IH-21
Arthur D Little Inc

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                                                            DRAFT
                            TABLE III-9
                    TEMPERED HARDBOARD PRICES

                                                         All
                                                     Construction
                                                      Materials
                                                     Price Index
                                                         93.6
                                                         94.7
                                                         95.8
                                                         98.8
                                                        100.0
                                                        105.6
                                                        111.9
                                                        112.5
                                                        119.5
                                                        126.6
                                                        138.5
                                                        160.9
                                                        174.0
                                                        187.7
                                                        204.9
                                                        221.9
*Manufacturers' price to jobber or wholesaler delivered to
 destination or f.o.b. mill with freight allowed
21967 =  100
Source:   U.S. Bureau of Labor Statistics, Wholesale Price Indices.
Year
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978(March)
Price1
MSF - 1/8"
61.956
61.001
60.941
60 ..822
59.688
58.633
59.969
61.001
60.345
'61.001
62.792
70.432
70.253
78.430
85.175
91.562
Percent Increase
Over Previous Year
—
1.6
0.1
(.2)
(1.9)
(1.8)
2.3
1.7
(1.1)
1.1
2.9
12.5
0.3
11.6
8.6
7.5
Price2
Index
103.8
102.2
102.1
101.9
100.0
98.3
99.8
102.2
101.1
102.2
105.2
118.0
117.0
131.4
142.7
153.4
                             111-22
Arthur D Little. Inc

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                                                                  DRAFT










    It should be noted  that  the  largest producer does exert some control



over product design trends,  frequency of price changes, and price leadership.




As explained earlier,  the  industry  serves a very wide range of end uses




requiring an estimated  800 different sets of specifications; this makes




direct competition between manufacturers selling to the industrial market




uncommon in practice and unlikely to occur in the future.  Hardboard




marketing efforts have  traditionally been aimed at displacing entrenched




products such as lumber and  plywood in specific applications using pricing




as an incentive; now,  hardboard  is  challenging and being challenged by




plastics and metals for various  applications.  Consequently, a major




pricing factor is the possibility of substitution of competitive materials




by and for hardboard.   Price competition can be a factor in sales to retail




yards handling large volumes of  hardboard.




3.  Price Elasticity of Demand.




    Price changes in hardboard from 1967 to 1976 have been far less




frequent and quite moderate  compared with price changes of lumber, ply-




wood, and other products with which it competes.  Evidence of this




situation appears in the fact that  while the wholesale price index for




construction materials  in  1976 was  187.7, the wholesale price index for




tempered hardboard was  only  131.4,  as shown in Table 111-9.  It should be




noted that the GNP deflator  for  1976 was 1.59 of the 1967 level which




shows hardboard prices  have  failed  to keep pace with general economic




conditions.  There are several factors that contribute to this situation.




    First, cost of production have  not increased as rapidly as general



inflation, which may have  allowed the industry to maintain its accepted
                                 in-23                          Arthur D Little he

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                                                                   DRAFT
level of profitability  without  increasing prices.  This situation will


probably not continue given  the likely real increases in wood costs and


increased competition for fiber in  the future.  However, the costs of


producing substitute materials  are  likely to increase even faster than



hardboard production costs.


    Secondly, the incremental additions  taking place in 1976, 1977 and


1978 suggest that the industry  may  have  absorbed  the anticipated impact


of lower margins per unit by adding shifts.  This course of action would


result in stabilized rates of return as  a consequence of lower per unit


margins on greater volumes produced at any  individual facility.


    Finally, there is a market-price relationship.  Hardboard producers


may have to keep down their prices  to meet  competition from substitute


products and maintain market shares. Price apparently varies somewhat


independently of consumption and in different magnitudes as shown in


the random pattern of price-consumption  correlations.  Obviously, demand


is not totally price inelastic, but within  reasonable bounds prices can


be adjusted without adverse impact  on overall demand.


    The ability of hardboard manufacturers  to pass  on the additional


costs of pollution abatement depends on  the amounts involved.  Any


increase in costs will  result in higher  levels of competition from


substitute products and a more  cautious  approach  to the commitment of


capital for capacity expansions.  Decreases in market share, if  they


occur, would be slow in industrial  applications,  since products  must be


redesigned, and relatively fast in  construction  applications.
                                 III-2A                           A ,    _.  .  .
                                                                 Arthur D Little Inc

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                                                                  DRAFT
4.  Barriers to Entry of New Firms.




     Relative to other solid wood products mills, hardboard is a




capital intensive industry.  The most significant barriers to the entry




of new firms, however, are  the market structure, the magnitude of the




sales effort required, and  securing a fiber source.  A new company would




have to develop new markets or "buy" market share from competitors;




given the recognition of  the existing producers in the marketplace, it




could be a costly and difficult task at best.  There is the alternative




of selling the production of a new producer through the existing pro-




ducers distribution systems, as is done in the case of other wood products.




This would be an undesirable position for a new producer for both produc-




tion and marketing reasons.




5.  Other Regulatory Factors.




     It should also be noted that a result of government policy restric-




ting the cut of federal timber on the West Coast will be to push prices




of lumber and plywood upward, thereby relieving some pressure against




hardboard price increases.  An easing of government timber policy that




would allow a higher level  of removals from West Coast forests, which is




equally likely, would have  the opposite effect.








G.  FINANCIAL PROFILE




    The range of sales and  plant book values for wet process hardboard




plants are shown in Table 111-10.  While sales vary directly with produc-




tion, plant book values will differ for plants of similar size, primarily




because of age of plant.
                                 111-25
                                                                Arthur D Little, Inc

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                                                                DRAFT
    The pro-forma costs of production for wet process  hardboard are


also shown  in Table 111-10.  There was no observable difference in the


distribution of costs between plants that will be required to undertake


pollution control expenditures for BAT-Toxic regulations and plants that


will be in  compliance.  Differences in the distribution of cost arise in


part from plant size differences and plant location (local cost) factors.
                                111-26                          A ,    r,.  .  .
                                                               ArthurDLittlelnc

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                                                                  DRAFT
                              TABLE 111-10

                           FINANCIAL PROFILE

                      WET PROCESS HARDBOARD PLANTS
 1976 SALES  ($000)

 1976 CAPACITY

CAPACITY BASE
WET PROCESS
 HARDBOARD

  $16,000        (range $6,000 - >$120,000^

  200 Million square feet

  1/8"
Pro-Forma Cost  of Manufacture

Sales

Cost of Sales

  Labor
  Materials
  Depreciation
  Other Expenses

Total Cost of Sales

Gross Margin


Selling G&A

Interest Expense


Profit Before Tax

Tax

Profit After Tax


Plant Book Value ($000)
Median Value

    100%



  .   20
     30
      5
     20

     75

     25


     11
     14

      7

      7


  10,000
  100%
 15-50
 19-50
  2-5
  5-28
 15-36


  7-25

  0-4


  8-24



  1-13


900 - >$40,000
Source:  Derived  from the EPA Financial 308  Survey.
                                  111-27
                          Arthur D Little Inc

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                                                                  DRAFT
                      IV  COST OF COMPLIANCE WITH
                  REVISED WATER EFFLUENT REGULATIONS
A.  INTRODUCTION
    The purpose of this chapter  is to describe the current water effluent
method of disposal used by insulation board and wet process hardboard
plants, and to summarize the cost of compliance developed by the tech-
nical contractor.  These data were used  to estimate the economic impact
of the revised water effluent regulations described in Chapter V.  Also
described are the control options for new sources and their associated
costs of compliance.


B.  CURRENT EFFLUENT STATUS
    Table IV-1 depicts the current method of water effluent disposal
used by wet process hardboard and insulation board plants.   Plants pro-
ducing both insulation board and wet process hardboard are classified
according to the predominant product volume and are referred to  through-
out as "combination" plants.
    Most (8) of  the wet process hardboard plants  discharge into  navigable
water, while two plants discharge into municipal  sewers and two  plants
recycle  their waste water.  The insulation board  plants are distributed
across all categories with three discharging  into navigable water,  five
into  municipal  sewers,  three  disposing on  site (e.g.,  spray irrigation)
and  two  recycling  their waste water.
                                 IV-1
                                                                 Arthur D Little. Inc

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                                                      TABLE  IV-1

                                                   INSULATION BOARD AND

                                                  WET PROCESS HARDBQARD

                                        CURRENT METHOD OF WATER EFFLUENT DISPOSAL
       Current Water
       Effluent
       Disposal	

       Navigable Water
                              Insulation Beard Only
                            Number of Plants   % Total

                                    2            16%
           Wet Process Hardboard Only
           Number of Plants   % Total
                   8
              66%
                              Combination
                        Number of Plants   % Total
                                 75
       Municipal Sewer
                                                 42
                                17
       No-Discharge
                                                 42
                                17
                                                                                                                25
 <
 to
         Total
                                   12
100%
        1 combination insulation board/hardboard plant.
12
100%
                                                                                                               100%
      **
        2 combination hardbcard/insulation board plants.
      SOURCE:  Derived from Financial 308 data.
c
cr
w
                                                                                                                        o
                                                                                                                        SO
                                                                                                                        3

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                                                                  DRAFT
C.  POLLUTION CONTROL OPTIONS  - EXISTING PLANTS

1.  Cost Models

    Many plants presently have pollution control equipment in place and

for several plants, current treatment will be sufficient to meet revised

effluent guidelines.1  However, six plants producing wet process hard-

board alone may be required to install new equipment to meet revised

water effluent regulations.

    Since there are so few plants  in the wet process hardboard sector

that must undertake compliance activities, costs of compliance were

generated by the technical contractor for each impacted plant.  The cost

estimation method was to use one or more of the plants that have higher

levels of water effluent treatment in place as models.  The cost of in-

stalling the model treatment process was then estimated for impacted

plants.  Table IV-2 depicts the relationship between the pollution con-

trol options and model treatment plant.  The plant indicated as a "special

case" in Table IV-2 has a pollution control system in the process of

construction, which may or may not be similar to the model treatment

plants.

    The wet process hardboard  control options represent different degrees

of stringency. Option 1, modelled  on plant 2099, calls for a screen,

first settling basin, an aerated lagoon, and second settling basin.

Option 2, modelled on plant 2006,  consists of two consecutive aerated

lagoons followed by a settling basin.  Option 3, modelled on plant 2010,

consists of a screen, an equilization basin, a primary clarifier, activated
 Economic Impact Analysis of Alternative  Pollution Control Technology
 for the Wood Preserving Subcategories of the Timber Products Industry,
 Draft Report to the U.S. Environmental Protection Agency, November 1978.

                                 IV-3
                                                                Arthur D Little, Inc

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                              TABLE IV-2
                      MODEL  PLANT TREATMENT OPTIONS
                                                               DRAFT
IMPACTED PLANT


WET PROCESS HARDBOARD

   Option 1

   Option 2

   Option 3

Plant 2002

Plant 2003

Plant 2004

Plant 2006

Plant 2013

Plant 2099
MODEL TREATMENT
    PLANT
    2099

    2006

    2010
  Special Case
 CURRENT
DISCHARGE
 METHOD
 Direct

 Direct
       *
 Direct

 Direct

 Indirect
       *
 Direct
PROPOSED
DISCHARGE
 METHOD
 Direct

 Direct

 Direct

 Direct

 Pretreatment

 Direct
 Some useable  treatment equipment  in place.
                                IV-4
                                                             Arthur D Little Inc

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                                                                  DRAFT
sludge removal,  a secondary clarifier, an aerated lagoon and a faculative




lagoon; in addition,  the  sludge is processed through an aerobic digester,




a sludge thickener and  a  vacuum filter, prior to disposal.




2.  Costs of Compliance




    As indicated in Table IV-3, the differences among the control option




costs for wet process hardboard plants are significant, and this appears




to be due to differences  in the size of facilities.  Plant 2013 is




currently in the process  of installing a pollution control system, and




it is shown as having equal cost under each option.  Under the least




stringent EPA option, only two plants  (2003 and 2004) would be impacted.




Under Option 2,  plant 2099 would be added to the list of impacted plants




while plants 2002 and 2006 would be added to the list under Option 3.









D.  POLLUTION CONTROL OPTIONS - NEW SOURCES




1.  Cost Models




    A candidate new source performance standard for insulation board




and wet process hardboard plants calls for zero discharge.  The control




technology is the same  for mechanical  refining insulation board, and




thermo-mechanical insulation board, while that for SIS wet process




hardboard and S2S wet process hardboard is similar.  It consists of




the following steps:1
                                 IV-5




                                                                 Arthur D Little Inc

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                                                              DRAFT
                             TABLE IV-3
                     COST OF COMPLIANCE FOR PLANTS
              IMPACTED BY REVISED EFFLUENT REGULATIONS
                               ($000)
Option 1
  Plant 2003
       2004
Investment
Total Land
$2,165.0
198.0
Other
Investment
$2,165.0
198.0
                                   Operating
                                     Costs
                                   $1,116.7
                                       87.1
Option 2
  Plant 2003
       2004
       2099
$2,307.8
   346.5
   373.5  $ 8.5
$2,307.8
   346.5
   365.0
$1,195.3
   144.2
    98.1
Option 3
  Plant 2002
        2003
        2004
        2006
        2099
$3,904.6  $25.0
 7,027.1   40.0
 2,674.7   25.0
 3,243.3   25.0
 2,773.9   25.0
$3,879.6
6,987.1
2,649.7
3,218.3
2,748.9
$ 884.6
2,102.2
469.0
642.7
517.7
                              IV-6
                                                            Art hurD Little Inc

-------
                                                                DRAFT
       •   Screening;




       •   Neutralization;




       •   Nutrient addition;



       •   Aerated lagoon (two aerated lagoons for hardboard);




       •   Faculative lagoon;  and




       •   Spray irrigation.



    The characteristics of the model insulation board and hardboard




plants are shown in Table IV-4.




2.  Costs  of Compliance




    The costs of compliance for new insulation board and wet process




hardboard  plants are summarized in Table IV-5.  The total investment




required includes the cost of land at about $2,200 per acre.
                                IV-7




                                                              Arthur DI jttlelnc

-------
                             TABLE IV-4
                     MODEL PLANTS FOR NEW SOURCE
                   PERFORMANCE STANDARDS INSULATION
                   BOARD AND WET PROCESS HAfiDBOARD
                                                                  DRAFT
   PLANT TYPE
  DESIGN
PRODUCTION
(tons/day)
  WASTEWATER
     FLOW
(OOP gal./day)
 RAW BOD
WASTELOAD
(Ibs./day)
                                                                 RAW TSS
                                                                WASTELOAD
                                                                (Ibs./day)
Mechanical Refining
 Insulation Board
   Plant 1
   Plant 2
   250
   600
     0.5
     1.2
   7,510
  18,000
 9,170
22,000
Thermo-mechanical
  Refining
 Insulation Board
   Plant 1
   Plant 2
   200
   400
     0.5
     1.0
  22,400
  44,800
 6,410
12,800
 SIS
 Wet Process Hardboard
   Plant 1
   Plant 2
   100
   300
     0.3
     0.8
   7,710
  23,100
 3,040
 9,110
 S2S
 Wet Process Hardboard
   Plant 1
   250
     1.5
  32,500
 7,510
                                  IV-8
                                                               Arthur D Little Inc

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                                                                 DRAFT
                             TABLE  IV-5
                          COST  OF COMPLIANCE
                       NEW INSULATION BOARD AND
                     WET PROCESS HARDBOARD MILLS
                               ($000)
    PLANT TYPE
Mechanical Refining
 Insulation Board
   Plant 1
   Plant 2
  TOTAL
INVESTMENT
 $2,336
  4,044
OPERATING
  COST
 $  690
  1,304
ACRES OF LAND
  REQUIRED
    245
    575
Thermo-me chani cal
  Refining
 Insulation Board
   Plant 1
   Plant 2
 $2,862
  5,491
 $1,366
  2,976
    245
    575
  SIS Wet
 Process Hardboard
   Plant 1              $1,953
   Plant 2               2,915
                  668
                  848
                  135
                  405
  S2S Wet
 Process Hardboard
   Plant 1
 $5,075
  2,005
    720
                                 IV-9
                                                              Arthur DLttlelnc

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                                                                  DRAFT
                   V  ECONOMIC IMPACT OF COMPLIANCE
                WITH REVISED WATER EFFLUENT REGULATIONS
A.  INTRODUCTION
    The cost of compliance estimates generated by the technical  con-
tractor (summarized in  Chapter IV) were combined with plant financial
profiles and economic characteristics of the industry (see Industry
Description, Chapter III)  to produce an estimate of the economic impact
of revised water effluent  regulations on the insulation board and wet
process hardboard sectors  of the  timber industry.
    Since there are so  few plants in the insulation board and wet process
hardboard sectors, and  only six wet process hardboard plants must incur
costs to comply with revised water effluent regulations, an analysis of
economic impact was performed  for each affected plant.  No combination
plants will incur costs.
    The potential economic impacts discussed in this chapter include:
              •  price  increases;
              •  demand shifts;
              •  financial considerations;
              •  plant  closure;
              •  capacity  expansion;
              •  market structure;
              •  employment  and  community impacts.
                                  V-l
                                                                ArthurDLittleJnc

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                                                                   DRAFT
B.  PRICE INCREASES


1.  Level of Increases

    Table V-l contains estimates  for each affected plant of the long-run


price increases required to recover the incremental costs of compliance


with revised regulations as well  as 1976 revenue and production for each


plant.  In most cases the 1977 price indicated in Table V-l represents


the average for wet process hardboard  as of year-end 1977.

    The price increase required to recover the cost of compliance varies


widely among wet process hardboard plants.  For the wet process hard-


board plants, Options 1 and 2 will produce a  substantially lower impact
                           >

upon costs than Option 3.  Since plant 2013 is currently in the process


of installing a pollution control system, its required revenue is the


same under all options.

    Plants 2003 and 2004 are required  to make expenditures for pollution


control under all three options.   The  required price increase to recover


costs for Option 3 is two times as high for plant 2003 and eight times


as high for plant 2004 than that for Option 1.

    The differences in required price  increase  from plant to plant for


a given model treatment can be explained by a combination of in-place


treatment, production scale or special circumstances.  Generally, smaller


plants and plants with less adequate  treatment  equipment will incur dis-


proportionate compliance costs for a  given model  treatment.  Plant 2013


is installing equipment appropriate for its  specific  situation.
                                  V-2
                                                                Arthur DLittklnc

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                                                      TABLE V-l

                                              REVENUE REQUIRED TO RECOVER

                                     THE COST OF COMPLYING WITH REVISED REGULATIONS

                                                  FOR HARDBOARD PLANTS
         Plant Type/Code
                                 (1)
                                 1976
                            Revenue  ($000)
                     1977
                     Price
                     /MSF
                Recovery of Compliance Cost
                 Required            % A 1977
              A Revenue/MSF            Price
3-
Option  1
Plant 2003
Plant 2004
'Plant 2013*

Option  2

Plant 2003
Plant 2004
Plant 2013*
Plant 2099

Option  3

Plant 2002
Plant 2003
Plant 2004
Plant 2006
Plant 2013*
Plant 2099
                                          $29,900
                                            8,400
                                           20,400
                                          $29,900
                                            8,400
                                           20,400
                                            5,500
$20,000
 29,900
  8,400
  9,400
 20,400
  5,500
                      $73
                       73
                       73
                      $73
                       73
                       73
                       73
$73
 73
 73
 73
 73
 73
                    3.80
                    1.10
                    6.10
                  $ 4.20
                    1.80
                    6.10
                    2.60
$ 7.30
  8.85
  9.60
 11.60
  6.10
 16.20
                      5%
                      2
                      8
                      6%
                      3
                      8
                      4
10%
12
13
16
 8
22
           *This plant is in the process of installing a pollution control system, and those specific costs
            were used in the analysis.

           SOURCE:  Arthur D. Little, Inc. estimates.

-------
                                                                  DRAFT
    The relative difference between  the highest cost and lowest cost




options also differs from plant  to plant.  This reflects the differences




in control equipment in place  from plant to plant.




2.  Obtainability of Increase



    Thus far, the discussion has focused on what long-run price increases




are necessary to recover the cost of compliance with revised water efflu-




ent regulations.  An important consideration in evaluating economic impact




is determining if and when price increases can be obtained.



    The first step in the evaluation of whether or not price increases




can be obtained was to compare the productive capacity in plants that




are required to make expenditures for revised regulations with those that




are not.  Table V-2 showed the capacity of plants impacted by Option 3




compared with that of plants  currently in compliance.  Wet process hard-




board plants impacted by revised regulations represent 27% of the 1976




total hardboard (wet and dry)  capacity and 28% of the total 1976 produc-




tion.  This fact alone would  indicate potential  difficulties  in obtaining




price increases.  However, wet process and other hardboard plants have




enjoyed high operating rates  from 1976 to 1978.  The total hardboard




segments had an operating rate of 92% in  1976 while the  impacted plants




operated at 95% of capacity.



    Under the less stringent  control options  for wet process hardboard,



fewer plants are impacted and thus  less  capacity  is controlled by im-




pacted plants.  The impacted plants  represent  14% of hardboard capacity



under Option 1, and 15% of capacity  under Option  2.
                                  V-4




                                                                 Arthur D Little Inc

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                                                                   DRAFT
                                TABLE V-2
                     DISTRIBUTION OF HARDBOARD CAPACITY
                      IMPACTED VS.  NON-IMPACTED PLANTS
                                 OPTION 3
WET PROCESS
Impacted Plants(6)
Plants in Complianc
'  Total Wet Process
DRY PROCESS 12
TOTAL HARDBOARD
1976
Capacity
(1/8" - MMSF)
1,650
[lO) 4.156
16) 5,812
2.460
8,272
% 1976 Production
Total
20%
^50
70%
30
100%
1/8" - MMSF
1,375
3.550
4,925
2f141
7,066
% Total
20%
-5J)
70
J1D
100%
1976
Capacity
Utilization
83%
8_5
85
87_
85%
 Includes  two combination plants.
SOURCE:  Derived from Financial 308 Letter data and Table  III-4.
                                    V-5
                                                                  Arthur D Little Inc

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                                                                  DRAFT
    While current operating rates are important, future growth in demand




and capacity expansion will indicate the probable supply/demand balance




likely at the time the plants  are required to make the pollution control




investments.  As discussed in  the industry description, hardboard demand




will continue to grow at an average rate of 5% a year, while fluctuating




with the business cycle for the construction industry.  Insulation board,




on the other hand, is a product in long-term decline.  By 1984, demand




for insulation board will be 65% of the 1976 level and the industry




operating rate would be at about 60% if all plants were in operation.




The demand for hardboard will  be about 25% higher in 1983 than in 1976




and an additional 1100-1200 MMSF of capacity will be required to meet




the demand.




    It is not contemplated that any greenfield plants will be constructed




to add to hardboard capacity.   The probable method of expansion is




incremental increases in capacity at existing plants and conversion of




insulation board capacity to hardboard capacity.  (Coincidentally, the




increased hardboard capacity required by 1984 is about the same in MMSF




as the slack insulation board  capacity that will exist by then (1,200 MMSF),




although only a small proportion of this capacity can practicably be con-




verted to hardboard.)  The total cost of production and derived selling




prices based upon long-run total cost indicate that the price of hardboard




must rise to a level substantially higher  than the levels indicated in




Table V-l.l
     Section F, CAPACITY EXPANSION.
                                  V-6





                                                                Arthur D Little Inc

-------
                                                                  DRAFT
    Since hardboard is  expected  to be in tight supply on average over




the next five to ten years,  and  the  cost of new capacity cannot be




supported by current market  prices,1 then prices can be expected to




eventually cover the increased costs of existing hardboard producers.




    The increases in hardboard price (measured in 1976 dollars) under




Options 1 and 2 will not be  sufficient to negate its competitive advan-




tage over plywood.   However, even when demand is price inelastic, some




reductions in demand can occur.  Under Option 3, while hardboard will




still be lower in cost  than  some substitutes, the price increases required




will be large enough so that some substitution could occur.








C.  FINANCIAL CONSIDERATION




    When an industry can recover cost increases through price increases




without impacting demand, the economic impact is less severe than would




otherwise be the case.   However, plants may suffer adverse economic




impact if price increases lag cost increases and if companies are unable




to finance the compliance investment.




    The profitability of wet process hardboard plants impacted by revised




regulations was analyzed as  if price increases did not occur and the




results of this evaluation are shown in Figure V-l.  In general,  plant




profitability will be reduced, but a plant will still cover its cash




costs and depreciation, assuming the 1976 operating results are repre-




sentative of cost conditions likely  to prevail in 1984.  Under Option 3




for wet process hardboard, two plants would just about break even as




shown in Figure V-l.
     Section F, CAPACITY EXPANSION.




                                  V-7




                                                                Arthur D Little. Inc

-------
    <
    CO
>
c
                                                    FIC.URE V-l

                                           POST-COMPLIANCE PROFITABILITY

                                               WITH NO PRICE INCREASE

                                               (1976 COST STRUCTURE)
22.0 -i
20.0 -
18.0 -
16.0 -

14.0 -
12.0 -
10.0 -
8.0 -
6.0 -
4.0 -
2.0 -
0.0 -









V
>

•



I






f
\



r











\






>





t






f






\



t








\




i
>



f




f \




i




r
f



(












\









                                        Option 1
Option 2
Option 3
                                                           Wet Process Hardboard
                          SOURCE:  Arthur D.  Little,  Inc.  estimates.
                                                                                                      Current
                                                                                                      Profitability
                                                                                                      Before Tax
                                                                                                      Post-Conpliance
                                                                                                      Profitability
                                                                                                      Before Tax

-------
                                                                  DRAFT
    Most of the insulation board and wet process hardboard plants are




parts of larger corporations which  generate cash flow in excess of the




required pollution control investment and which also have some ability




to generate external funds.  However, a parent company might be reluc-




tant to divert funds from other operations to hardboard plants.  For




this reason and the fact that  a few plants are part of smaller copora-




tions, it is advisable to examine  the relationship between plant cash




flow and the required compliance investment.




    For the impacted plants not currently in the process of installing




a pollution control system,  the investment required for revised effluent




regulations was divided by  cash flow  to construct the percentages shown




in Figure V-2.  For wet process hardboard plants, the investment associ-




ated with Options 1 and 2 are  less than or equal to 1976 cash  flow,




while the investment associated with  Option  3  is over three times cash




flow.




    The impacted wet process hardboard plants  will eventually  recover




the costs of compliance through higher prices  which will probably also




provide a sufficient rate of return on investment.  However, Option  3




will  cause a cash drain from other operations.









D.  PLANT CLOSURE




    The evaluation of whether or  not a plant will  close down as a




result of pollution control regulation  (or  any other event) is at best




an  imprecise estimate based upon  an external view  of a plant's situation.
                                  V-9




                                                                 Arthur D Little. Inc

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                                                       DRAFT
                       FIGURE V-2
                 INVESTMENT REQUIRED FOR
      COMPLIANCE  WITH REV-ISED EFFLUENT REGULATIONS
              COMPARED WITH PLANT CASH FLOW
     400  --
      300
% Annual
Cash Flow
      200  --
      100  - -
              Option 1
Option  2
Option  3
                        Wet Process Hardboard
  SOURCE:  Arthur D. Little, Inc.  estimates.
                          V-10
                                                         Arthur HI ittlp Inr

-------
                                                                  DRAFT
Of necessity, the evaluation  is based upon financial criteria without




knowledge and consideration of a  corporation's policies and goals.  To




illustrate, a corporation  nay decide to close or sell off an apparently



profitable plant if the plant's business does not meet its long-term




objectives.  On the other  hand, a corporation may elect to invest in




and operate a marginal plant  which provides a source of equipment or




materials for its other operations, to retain control over the source




of supply.



    Under Options 1 and 2, no plant closures are foreseen for the two




or three plants not presently installing a pollution control system.




Under Option 3, no closures are foreseen, provided the plants can obtain




external financing.








E.  CAPACITY EXPANSION




    In Chapters II and III, the discussion of the hardboard and insula-




board industry segments indicated that no greenfield mills are likely




to be built for either of  the two product types.  Insulation board




demand is facing a long-term  decline and faces significant excess capa-




city by the 1980's, and thus  no new capacity will be built.




    Capacity expansion for hardboard will most likely occur through in-




cremental expansion of existing hardboard mills and secondly from con-




version of insulation board capacity.  The reason for this is primarily




related to the high cost of new capacity compared with current market



prices, and while this relationship would be  exacerbated by pollution




control costs, they are of secondary importance.
                                 V-ll




                                                               Arthur D Little. Inc

-------
                                                                  DRAFT
    Table V-3 depicts  the  long-run price required to recover the incre-




mental pollution control cost  for a new mill, an insulation board plant




conversion and an incremental  expansion.  The required increment to



cover pollution control costs  does not differ for the new source compared




to conversion and expansion, under a  total recycle option.  However, the




baseline plant cost translates into a higher, long-run required price-




per-ton for a new facility.




    All expansion methods  shown in Table V-3 require a higher product




price than the current market  prices, suggesting that capacity increases




will lag demand growth such  that market price will rise to cover the costs




of new capacity.  The March  1978 market price was 91.56 per MSF; prices




must rise by 28% to support  an incremental expansion by the lowest cost




method.  This increase is  greater than that required by impacted hard-




board plants to recover costs  of pollution control costs under all of




the options studied.








F.  MARKET STRUCTURE



    The number and size of insulation board plants will be unaffected




by revised regulations. The number of hardboard plants will remain




unchanged as a result of revised regulations.  New capacity will be




built at existing plants and will not be influenced significantly by




revised regulations.








G.  EMPLOYMENT AND COMMUNITY IMPACTS




    No plant closures are  anticipated and  thus no unemployment will




result from revised regulations for insulation board and hardboard




segments.



                                V-12
                                                                Arthur D Little: Inc

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                                   TABLE V-3

                        COST  OF NEW HARDBOARD CAPACITY

                    NEW MILL VERSUS INCREMENTAL  EXPANSION
 1.  New Plant

    Baseline Plant

    Water Effluent Control
2.  Conversion  of
    Insulation  Board Plant

    Baseline Conversion
      Cost

    Water Effluent Central
      (Option 3)1
                                                       ANNUAL
                                        INCREMENTAL    OPERATING   LONG-RUN
                             CAPACITY    INVESTMENT      COSTS      PRICE
MMSF
 234
 ($000)
$27,000
 ($000)
$20,440
($/MSF)
293
$57,000
5,075
$24,300
2,005
$136
11
                                                                    $147
 $117
 7-11
                                   $124 - $128
3.  Incremental Expansion

    Baseline Expansion

    Water Effluent Control
       (Option  3)1
 117
$17,500
$ 8,370
 $106

 9-12
                                   $115  - $118
  1Based on range for similar size plants.
SOURCE:  Arthur D. Little, Inc. estimates.
                                      V-13
                                                                   Arthur I) Little Inc

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                              DRAFT
   APPENDIX A




SUPPLEMENTARY DATA
                             Arthur D Little Inc

-------
 PAGE NOT
AVAILABLE
DIGITALLY

-------
                                                                 DRAFT
                             TABLE  A-2

                       DERIVATION OF UNIT COST
                 WET PROCESS HARDBOARD NEW CAPACITY
LABOR HOURS
    1.  Greenfield Mill
                                        Manhours/Ton
                 Logging                    2.72
                 Manufacture                14.72
                 Transportation              2.08
                                           19.52
    2.  Conversion of Insulation Board to Hardboard
           Increase manhours  by 10%:  21.42 manhours/incremental ton

    3.  Incremental Expansion
           Decrease manhours  by 10%:  17.57 manhours/incremental ton

ENERGY REQUIREMENTS
    1.  Greenfield Mill                  Million BTU's
           Gross Manufacturing Requirements     21.551
           Energy Generated from Residue          .797
                                               20.754
    2.  Conversion of Insulation Board to Hardboard
           Increase BTU's by 10%:   22.829 million BTU's
    3.  Incremental Expansion
           Decrease BTU's by 10%:   18.679 million BTU's
WOOD  REQUIREMENTS
    300 tons of  chips/day = 107 MBF/day
                             .84 MSF/day
                                                                Arthur D Little Inc

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                                 DRAFT
     APPENDIX B




EPA FINANCIAL 308 SURVEY
                               Arthur D Little Inc

-------
                                                                         DRAFT
                             308 QUESTIONNAIRE
                             INSULATION BOARD
i.   Name of Plant
ii.   Address of Plant
                  Street
                  City

iii.  Name of Respondent*
State
        Zip
             Title
iv.  Address of Respondent
                        Street

v.   Telephone No. of Respondent
City
State
Zip
                                Area Code
             Number
vi.  Parent Company
vii.  Is this plant engaged in the manufacture of insulation board?

    Yes    D      Continue with Questionnaire
    No    D      Do not fill out the questionnaire  but return after completing this
                  page, through Question vii.

viii. To assert your claim of confidentiality, please check off the box corresponding to the
    questions that in the company's opinion require confidential treatment.
1 D 5
2 D 6
3D 7
4 D 8
NOTE: Upon receip
the questionnaire so
D 9 D
D 10 D
D 11 D
D 12 D
13 D
14 D
15 D
18 D
19 D
20 D
21 D
22 D
t by EPA, this page will be separated from the remainder of
that data processing and use is conducted on a coded basis.
For Use by EPA
Code Number




"Person to be contacted in case of questions.

-------
                                                                                 DRAFT
                                  308 QUESTIONNAIRE
                                  INSULATION BOARD
                                                  Company Code
                                                  (For EPA Use)
A.   GENERAL INFORMATION
1.   Is this insulation board (IB) plant a stand-alone operation or part of a multi-plant complex?
     Stand-Alone   D    Multi-plant Complex   D
     If part of a multi-plant complex, approximately what percentage of total complex sales revenue was
     represented by insulation board in the fiscal year ending 1976?	%
2.   Is this plant at an urban, suburban or rural location?	
     Urban  D     Suburban   D     Rural  D
3.   What year did the plant begin operation?	___
B.   SALES AND PRODUCT MIX
4.   What were total sales for this insulation board (IB) plant during 1976?
        Under
     $8 Million     $8-12 Million     $13-20 Million    $21-28 Million    Over $28 Million
         D             D              D              D                D
5.   Which of the following product types were produced at this IB plant during 1976?
Insulation Board
a.
b.
c.
Structural
Decorative
Other
Produced
At Plant

D
D
D
Approximate Percent of Sales
<10

D
D
D
10-30

D
D
D
31-50

D
D
D
51-70

D
D
D
71-90

D
D
D
>90

D
D
n
6.    Are any changes (other than normal business fluctuations) planned over the next five years in IB
     production process or product mix7
     Yes  D     No  D  Of no, go to Part C)
     If yes, please describe •	

-------
                                                                                  DRAFT
C.   PLANT CAPACITY AND PRODUCTION
 7.  Annual Capacity The amount or thousands of square feet of insulation board which could have been
     produced in this plant during 1976 if the IB plant was operated fully 6-2/3 days/week, 24 hours/day,
     (350 days or 8400 hours/yr.).

                                          Thousands of Square Feet


Insulation
Board
(1/2" Basis)


< 100,000
D

300,001-
350,000
D
100,000-
150,000
D

350,001-
400,000
D
150,001-
200.000
D

400.001-
450.000
D
200.001-
250,000
D

450,001-
500,000
D
250,001-
300,000
D


> 500,000
D
 8.  Actual Production in 1976: The amount of thousands of square feet of insulation board which were
     produced in this IB plant during 1976:
     Insulation Board (1/2" basis)
                                                          thousands of square feet
9. Did this IB plant have any unusual downtime during 1976, e.g., labor strikes, accidents, et cetera?
Number of Weeks of Unusual Downtime
No D (Go to 10)
Yes D
<1
D
1 0. Average number of employees during

Production Workers
Other Employees
11. a. Typical number of p
<25
D
D
iroduction (
1-2
D
1976:
26-50
D
D
lays per we
3-4
D

51-75
D
D
ek:
5-6
D

76-100
D
D

7-8
D

101-150
a
D

>8
a

>150
D
D

     b.



     (1)
     (2)
     (3)
     (4)
     (5)
1-4  D    5  D    6 D    7  D

Please state number of weeks at each shift level (the total should add to 52 weeks)

No. of Weeks

	     at 0 shifts (shut down or no insulation board production)

	     at 1 shift
	     at 2 shifts

	     at 3 shifts
	     at 4 shifts
          52 weeks  Total [(1) + (2) + (3) + (4) + (5)]

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                                                                                DRAFT
D.  REVENUES AND EXPENSES

12.  Income Statement

    Please  check the box which most closely approximates your costs as a percentage of sales. (Use an
    approximate allocation of data are available at the plant level.)
                                               Approximate Percent of Sales
    a.  Direct Wages, Salaries
       and Related
    b.  Materials (logs, wood,
       other materials,
       inventory charges)
    c.  Depreciation
    d.  Other Plant Expenses
       (Including rent, fuel
       and energy)
    e.  Operating Margin
    f.  Selling, General and
       Administration
       (Including allocation
       from Parent)
    g.  Interest Expense

    h.  Other Income (Expense)


    \.  Profit Before Tax


    j.  Taxes


    k.  Profit After Tax
< 16
D
<40.0
D
< 1
D
< 1
D
< 10
D
< 8
D
0
D
D
< 3
D
<1
a
<2
a
16-20
a
41-45
a
1-2
a
1-2
a
10.0-20.0
a
8-10
a
1-2
D
D
3-9
D
2-3
a
2-4
n
21-25
a
46-50
D
3-4
a
34
D
26-30
a
51-55
D
4-5
a
4-5
a
21.0-25.0
a
11-13
D
3-4
a
a
10-12
D
4-5
a
5-10
a



5-6
a
a
13-15
a
6-7
a
11-15
a
31-35
D
5640
a
6-7
a
6-7
a
25.1-30.0
D
>14
D
7-8
a
D
16-17
a
8-9
a
>15
D
>35
a
>60
a
> 7
a
> 7
a
>30
a


>8
D
a
>17
a
>9
a



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                                                                                        DRAFT
13. How representative is 1976 profit before tax compared to the 1971-1975 period:

    Much Better than Average           D
    Better than Average                D
    About the Same                   D
    Worse than Average                D
    Much Worse than Average           D

14. What Depreciation Method is used?
    a.   Book Basis:  Straight-Line
                    Double-declining Balance
                    Sum or Year's Digits
                    Other:
    b.  Tax Basis:
      (Please Specify)
Straight Line
Double-declining Balance
Sum of Year's Digits
Other:
                          (Please Specify)
    c.   Pollution Control Expenditures:
                    Accelerated Over 5 Years
                    Same as Other Equipment
Equipment
    D
    D
    D
    D

    D
    D
    D
    D
                                          D
                                          D
Buildings
   D
   D
   D
   D

   D
   D
   D
   D
                        D
                        D
IS. Annual Cost of Pollution Control and other Regulations Affecting Insulation Board Production Process
    and Costs at this IB Plant:
                                                Don't
                                                Know
                                      None
                                                     Fiscal Year Ending
             1976
      1977"
    a.   Direct Costs
        (1)  Water Pollution Regulations:
            (a)  Annual Operating Costs**
            (b)  Annual Depreciation Charges**
            (c)  Obligations to Municipalities

        (2)  Air Pollution Regulations:
            (a)  Annual Operating Costs
            (b)  Annual Depreciation Charges
                              D
                              D
                              D


                              D
                              D
 D
 D
 D


 D
 D
 •Please estimate the 1977 value if unknown at this time.
"Include the cost associated with shared facilities, including Industrial Waste Recovery Systems.

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                                                                                         DRAFT
         (3)  Solid Waste Disposal (Total,
             including waste water sludge
             and wood waste):
             (a) Annual Operating Costs
             (b) Annual Depreciation Charges
         (4)  Other Regulations Affecting Pro-
             duction Processes and Produc-
             tion Costs (Please Specify)	
Don't
Know
D
D
D
None
D
D
D
                                                                       Fiscal Year Ending
                                                        D
                                                        D
             (a)  Annual Operating Costs          D
             (b)  Annual Depreciation Charges     D
     b.   Indirect Costs (e.g., environ-
         mental research, consultants,
         litigation)                              D       D
16.   How does this plant discharge of process waste water?
     a.   Discharge into navigable water                     D
     b.   Discharge into municipal sewer                    D
     c.   Disposed on plant site                            D
     d.   Disposed off plant site                            D
     e.   Process waste is recycled (no discharge)             D
     f.   Other   D    Please specify 	
                                                                   1976
                                                                                      1977"
17a.  If you do not discharge process  waste water into a municipal sewer, do you have the option to
     connect?
     Yes   D      No   D
                              Don't Know   D
     b.  If you do have the  option to connect to a  municipal sewer, what is the initial capital invest-
         ment cost?
         S 	               Don't Know  D
     c.  If you discharge any  wood  treating process waste water into a sewer system, on what basis
         are your sewer charges made?
         Flat annual fee           D
         Gallon of effluent        D
         Other   D  Please specify	
•Please estimate the 1977 value if unknown at this time.

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                                                                                     DRAFT
     d.   If you discharge into a municipal sewer, what were your total sewer charges in 1976?

         $	

     e.   If you discharge  process waste water  into navigable waters, do you have an NPDES permit"!

         Yes  D       No  D     Don't Know D

     f.   Do you own or have available for purchase about one acre of land at or adjacent to this facility
         that could be used for an effluent treatment system?

         Yes  D      No  D

         If yes, what is the current market value  per acre?   $	

18.   Unusual Production Costs

     Are there  any circumstances  peculiar to this plant which result in unusual production costs (other
     than unusual downtime described in Q. 9)?

     Yes  D       No  D

     If Yes, please describe:		
19.  Distribution of Corporate Assets and Liabilities

     a.   What was the value of the company's total assets at the end
         of the 1976 fiscal year?                                          $

     b.   What was the value of the company's total liabilities and net
         worth at the end of the 1976 fiscal year (accounts payable,
         debt due within the year, etc.)?                                   $

     c.   What was the value of debt maturing in one year?                    S
     b.   Accumulated depreciation

     c.   Net Fixed Assets (Gross Fixed Assets less cumulative
         depreciation = Current Book Value)

     d.   Total Assets: Net Fixed Assets, Cash Receivables,
         inventory, other costs)
     d.  What was the corporation's debt/equity ratio?                      	: 1

20   Value of Assets for this Insulation Board Plant

     a.  Gross Fixed Assets: Original Cost (Book Value) of plant
         and equipment dedicated to insulation board                       $  	

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                                                                                      DRAFT
21.   Capital Investment Criteria for IB Plant

     a.   What basis is used to evaluate the IB plant's profitability (return on investment)!

         D  Total Assets (As above, 20.d) less current liabilities

         D  Book Value of Net Fixed Assets (As above, 20.c)

         D  Replacement Cost

         D  Salvage Value

         D  Other (Specify)

     b.   What is the target internal pre-tax rate of return on capital required for investment in this plant?
         	% At what ROI would you consider closing the plant?	%

     c.   If rate of return criteria  are not used, what is the required payback period for investment?
         	Years or      D   Useful Life.  At what payback period would you consider clos-
         ing the plant?	Years

22.  Capital Investment for IB Plant (including capitalized maintenance)

                               (1)              (2)              (3)                (4)
                                         Plant Capitalized     Water       Other  Environmental
                             Total        Maintenance of      Pollution     Regulation Impacting
                           Investment    Major Expansion     Control     Production  Processes
     Planned 1977

     Total Actual 1972-76

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                                                                       DRAFT
                             308 QUESTIONNAIRE
                         WET PROCESS HARDBOARD
i.    Name of Plant
ii.   Address of Plant.
                   Street
                  City                  State                  Zip
iii.   Name of Respondent*	  Title	
iv.   Address of Respondent	
                        Street           City            State         Zip
v.   Telephone No. of Respondent	
                                Area Code            Number
vi.  Parent Company	
vii.   Is this plant engaged in the manufacture of wet process hardboard?
     Yes    D      Continue with Questionnaire
     No    D      Do not fill out the questionnaire but return after completing this
                  page through Question vii.
viii.  To assert your claim of confidentiality, please check off the box corresponding to the
     questions that in the company's opinion require confidential treatment.
     ID        5D         9D        13   D        19    D
     2    D        6    D        10    D        14   D        20    D
     3D        7    D        11    D        15   D        21    D
     4    D        8    D        12    D        18   D        22    D
     NOTE:  Upon receipt by EPA, this page will be separated from the remainder of
     the questionnaire so that data processing and use is conducted on a coded basis.
                                For Use by EPA
                         Code Number  	
'Person to be contacted in case of questions.

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                                                                                    DRAFT
    PLANT CAPACITY AND PRODUCTION
7.  Annual Capacity: The amount of thousands of square feet of the product which could have been
    produced in this plant during 1976 if the plant was operated fully 6-2/3 days/week, 24 hours/day
    (350 days or 8400 hours/yr.).
                                         Thousands of Square Feet
Wet Process
Hardboard
(1/8" Basis)
< 100,000
D
300,001-
350,000
D
100,000-
150,000
D
350.001-
400.000
D
150,001-
200,000
D
400,001-
450,000
D
200,001-
250,000
D
450,001-
500,000
D
250,001-
300,000
D
> 500,000
D
 8.  Actual Production in 1976: The amount of thousands of square feet of the product which were
    produced in this plant during 1976:
    Wet Process Hardboard (1/8" basis).
. thousands of square feet
 9.   Did  this  WPH  plant have  any unusual downtime during 1976, e.g., labor strikes, accidents, etc?
                                    Number of Weeks of Unusual Downtime
     No  D     (Go to 10)    <1        1-2        34
     Yes  D                 D         D        D
10.   Average number of employees during 1976:
                            < 25      26-50     51-75
     Production Workers
     Other Employees
                                                          5-6
                                                           D

                                                         76-100
D
D
D
D
D
D
D
D
  101-150
    D
    D
 >8
 D

>150
 D
 D
11.   a.  Typical number of production days per week:
        1-4  D     5  D     6  D     7  D
     b.  Please state number of weeks at each shift level (the total should add to 52 weeks):
        No. of Weeks
     (1) 	   at 0 shifts (shut down or no wet process hardboard production)
     (2) 	   at 1 shift
     (3) 	   at 2 shifts
     (4) 	   at 3 shifts
     (5) 	   at 4 shifts
        52 Weeks   Total [(1) + (2) + (3) + (4) + (5)]

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                             DRAFT
  308 QUESTIONNAIRE
WET PROCESS HARDBOARD
A. GENERAL INFORMATION
1 . Is this wet process hardboard (WPH)
Stand- Alone Q Multi-plant C
If part of a complex, approximately
process hardboard in the 1976 fiscal >
2. Is this plant at an urban, suburban or
Urban D Suburban D I
3. What year did the plant begin operatii
B. SALES AND PRODUCT MIX
4. What were total sales (net f.o.b.) for t
Under $5 Million $5-10 Million
Company Code
(For EPA Use)
plant a stand-alone operation or part of
'omplex D
' what percentage of total sales at this
-ear? %


a multi-plant complex?
complex was from wet
rural location?
tural D
in?
his wet process hardboard (WPH) plant during 1976?
More than
$1 1-20 Million $21-30 Million $30 Million
D D D D
5. Which of the following product types were produced at this WPH plant during
Produced
SIS Products At Plant
a. Siding
b. Panelling
c. Industrial Board
d. Other SIS
S2S Products
e. Siding
d. Panelling
g. Industrial Board
h. Other S2S
D
D
D
D
D
D
D
D
1 976?
D
Approximate Percent of Safes
<10
D
D
D
D
D
D
D
D
10-30
D
D
D
D
D
D
D
D
31-50
D
n
D
D
D
D
D
D
6. Are any changes (other than normal business fluctuations) planned
duction process or product mix at this WPH plant?
Yes D No D
If yes, please describe
(If no, go
to Part C)


51-70
a
a
a
a
a
a
a
D
over the

70-90
D
D
D
D
D
D
D
D
next five

>90
D
D
D
D
D
D
D
D
years in pro-


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                                                                                  DRAFT
D.  REVENUES AND EXPENSES

12.  Income Statement

    Please  check the  box which most closely approximates your costs as a percentage of sales. (Use an
    approximate allocation if data are unavailable at the plant level.)

                                    This WPH Plant's Cost as an Approximate Percent of Sales
    a.  Direct Wages, Salaries
       and Related
    b.  Materials (logs, wood,
       other materials plus
       inventory charges)
    c.  Depreciation
    A.  Other Plant Expenses
       (Including rent, fuel
       and energy)
    e.  Operating Margin
    f.  Selling General and
       Admin. (Including
       Allocation from
       Parent)
    g.   Interest Expense

    h.   Other Income (expense)


    i.   Profit Before Tax


    j.   Taxes


    k.   Pro fit After Tax
<16
D
<20
D
<1
D
<1
D
<30
D
<5
D
0
D
D
<10
D
<4
D
<4
a
17-19
D
21-27
a
1-2
a
1-2
a
31-35
a
6-7
a
1-2
a
D
11-14
a
5-6
a
54
a
20-23
D
28-33
a
34
a
3-4
a
3640
a
8-10
D
34
a
a
15-19
a
7-9
G
7-9
a
24-26
a
3440
a
4-5
a
4-5
a
4145
a
11-12
a
5-6
a
a
19-24
D
10-12
a
10-12
a
27-29
a
4147
a
6-7
D
5-6
a
46-50
a
13-15
a
>6
a
a
25-30
a
13-15
D
13-15
a
>29
a
>47
a
>7
a
>7
a
>50
D
>15
a










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                                                                                        DRAFT
13.  How representative is 1976 profit before tax compared to the 1971-1975 period:
    Much Better than Average           D
    Better than Average                D
    About the Same                   D
    Worse than Average                D
    Much Worse than Average           D

14.  What depreciation method is used?
    a.   Book Basis:  Straight-Line
                    Double-declining Balance
                    Sum of Year's Digits
                    Other.
    b.  Tax Basis
      (Please Specify)
Straight Line
Double-declining Balance
Sum of Year's Digits
Other.
                          (Please Specify)
    c.   Pollution Control Expenditures:
                    Accelerated Over 5 Years
                    Same as Other Equipment/Bldgs.
                                                     Equipment
                                                         D
                                                         D
                                                         D
                                                         D

                                                         D
                                                         D
                                                         D
                                                         D
                                          D
                                          D
Buildings
   D
   D
   D
   D

   D
   D
   D
   D
                                                                             D
                                                                             D
IS  Annual  Cost  of Pollution Control  and other Regulations Affecting WPH Production  Process and
    Production at this Plant:
a.   Direct Costs
    (1) Water Pollution Regulations:
        (a)  Annual Operating Costs**
        (b)  Annual Depreciation Charges*
        (c)  Obligations to municipalities

    (2) Air Pollution Regulations
        (a)  Annual Operating Costs
        (b)  Annual Depreciation Charges
                                                 Don't
                                                 Know
                                                  D
                                                  D
                                                  D


                                                  D
                                                  D
                                                     Fiscal Year Ending
                                      None
                                       D
                                       D
                                       D


                                       D
                                       D
                                                                  1976
      1977*
  * Please estimate 1977 expenditures if they are not known.
 *'Include the cost associated with shared facilities, including Industrial Waste Recovery Systems.

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                                                                                        DRAFT
         (3) Solid Waste Disposal (Total,
            including waste water sludge
            and wood waste):

            (a)  Annual Operating Costs
            (b)  Annual Depreciation Charges

         (4) Other Regulations Affecting Pro-
            duction Processes and Produc-
            tion Costs (Please Specify):	
                                             Don't
                                             Know
D

D
D
                        Fiscal Year Ending
             (a)  Annual Operating Costs          D
             (b)  Annual Depreciation Charges     D

     b.   Indirect/Overhead Costs (Environ-
         mental research, consulting fees,
         litigation, etc.)                         D

16.   How does this plant dispose of process waste water!

     a.   Discharge into navigable water
     b.   Discharge into municipal sewer
     c.   Disposed on plant site
     d.   Disposed off plant site
     e.   Process waste water is recycled (no discharge)
     f.   Other   D   Please specify	
None


  D
  D
  n
                    1976
1977*
         D
         D
         n
         D
         n
         n
         n
         n
17 a If you do not discharge process waste water into a municipal sewer, do you  have the option to
     connect?

     Yes   D      No   D      Don't Know   D

     b.  If you do have the option to connect to  a municipal sewer, what is the initial capital invest-
         ment cost?

         S             	               Don't Know  D
     c.  If you discharge any process waste water into a sewer system, on what  basis are your sewer
         charges made7

         Flat annual fee           D
         Gallon of effluent        D
         Other   D   Please specify	
•Please estimate the 1977 value if unknown at this time

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                                                                                        DRAFT
     d.  If you discharge into a municipal sewer, what were your total sewer charges in 1976?

         $	

     e.  If you discharge process  waste water into navigable waters, do you have an NPDES Permit1*.

         Yes  D      No  D    Don't Know  D

     f.  Do you own or have available for purchase about one acre of land at or adjacent to this facility
         that could be used for an effluent treatment system?

         Yes  D      No  D

         If yes, what is the current market value per acre?    $	

18.   Unusual Production Costs

     Are there any circumstances peculiar to this plant which result in unusual production costs (other
     than unusual downtime described in Q. 9)?

     Yes   D       No  D

     If Yes, please describe:	
19.  Distribution of Corporate Assets and Liabilities

     a.  What is the value of the corporation's total accounts receivable?    S

     b.  What is the value of the corporation's total current liabilities
         (accounts payable, debt due within the year, etc.)?               $
     c.  What is the value of debt maturing in the current fiscal year?      S '_
     d.  What is the corporate debt/equity ratio?                          	:1

20.  Value of Assets (Wet Process Hardboard Plant):

     a.  Gross Fixed Assets •  Original Cost (Book Value) of plant
         equipment dedicated to wet process hardboard                  S	
     b.  Accumulated depreciation

     c.  Net Fixed Assets (Gross Fixed Assets less cumulative
         depreciation—Cunent Book Value)                             $ .

     d.  Total A ssets: Net Fixed Assets, Cash Receivables,
         inventory, other costs)                                       $ .

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                                                                                       DRAFT
21.  Capital Investment Criteria for WPH Plant

     a.  What basis is used to evaluate the plant's profitability (return on investment)?

         D  Net Assets (Total Assets, as above in 20.d, less Current Liabilities)

         O  Book Value or Net Fixed Assets (as above in 20.c)

         D  Replacement Cost

         D  Salvage Value

         D  Other (Specify)	
     b.  What is the target internal pre-tax rate of return on capital required for investment in this plant?
         	%  At what ROI would you consider closing the plant?	%

     c.  If rate of return criteria are not used, what is the required payback period for investment?
         	Years or     D  Useful Life

22.  Capital Investment for WPH Plant (including capitalized maintenance)

                              (D              (2)             (3)               (4)
                                         Plant Capitalized      Water       Other  Environmental
                             Total        Maintenance of     Pollution      Regulation Impacting
                           Investment     Major Expansion     Control      Production  Processes
     Planned 1977

     Total Actual 1972-76

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                                                         DRAFT
             RESPONSES TO EPA FINANCIAL SURVEY
Questionnaires Mailed to 18 Companies;
       19  Wet Process Hardboard
       16  Insulation Board

Response Rate:      100%
Applicable Responses:
        17 Wet Process Hardboard
        16 Insulation Board
                                                        Arthur D Little, Inc

-------