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Regulatory Impact Analysis for the Final
Reclassification of Major Sources as
Area Sources under Section 112 of the
Clean Air Act
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EPA-452/R-20-005
September 2020
Regulatory Impact Analysis for the
Final Reclassification of Major Sources
as Area Sources under Section 112 of the
Clean Air Act
Final Report
Larry Sorrels
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Economics Group
109 TW Alexander Drive
Research Triangle Park, NC 27711
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Health and Environmental Impacts Division
Research Triangle Park, NC 27711
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CONTACT INFORMATION
This document has been prepared by staff from several divisions of the Office of Air Quality
Planning and Standards, U.S. Environmental Protection Agency. Questions related to this
document should be addressed to Larry Sorrels, U.S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research Triangle Park, North Carolina 27711 (email:
Sorrels.Larry@epa.gov).
ACKNOWLEDGMENTS
Personnel from RTI International and Kapur Energy Environment Economics, LLC contributed
significant data, analysis, and writing to this document under contract number EP-W-11-029. In
addition, Eastern Research Group (ERG) contributed analyses of cost savings and emissions
changes to this document.
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TABLE OF CONTENTS
Section 1. Executive Summary 1
1.1 Summary 1
1.2 Summary of Approach for the Analysis 3
1.2.1 Baseline 5
1.2.2 Analytical Approach for Identifying Affected Sources and
Calculating Cost Savings 5
1.2.3 Economic Impact Estimation Approach 12
1.2.4 Benefits/Disbenefits Analysis 13
1.3 Avoided Costs of the Final MM2A Rule 13
1.4 Results 16
1.4.1 Administrative Cost Savings 16
1.4.2 Economic Impact Findings for the Primary Scenario 16
1.4.3 Findings for Alternative Scenario 1 18
1.4.4 Findings for Alternative Scenario 2 19
1.5 Comparison of the Percentile Results for Each Scenario 20
1.5.1 Reclassification Considerations 22
1.6 Limitations and Uncertainties of the Analysis 22
1.7 Organization of this Report 24
Section 2. Baseline Description, Regulatory Scenarios, and Affected Entities 26
2.1 Basic Steps for the Analysis Under the Primary Scenario 26
2.2 Basic Steps Under Alternative Scenario 1 29
2.3 B asi c Step s Under Alternative S cenari o 2 30
Section 3. Regulatory Relief or Avoided Burden Costs 33
3.1 Year 1 Avoided Costs for Sources Affected by the Final MM2A Rule 34
3.2 Year 5 Avoided Cost for Sources Affected by the Final MM2A Rule 77
3.3 Present Value and Equivalent Annualized Value Costs 103
Section 4. Illustrative Emissions Impacts and Potential Control Cost Impacts 106
4.1 Estimating Number of Facilities per Source Category and the Fraction
That Could Potentially Obtain Area Source Status 106
4.1.1 Findings 108
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4.2 Determining Source Categories for the Emissions Assessment 109
4.3 Characterization of Affected Industries 110
4.4 Characterizing Potential Emission Impacts for Remaining Source
Categories in the MM2A Database 114
4.5 Illustrative Source Category Cost Analyses for Alternative Scenario 2 137
4.6 Source Categories Included in Analysis 138
4.7 Illustrative Potential Cost Analysis Approach 140
4.8 Availability of HAP Control Technologies/Practices 143
4.9 Cost-Effectiveness Estimate Derivation for Source Categories 144
4.10 Results for Potential Cost Impact Analysis Considering the Illustrative
Emissions Analysis 145
4.11 Limitations of This Analysis 147
Section 5. Benefits/Disbenefits 149
5.1 Introduction 149
5.2 PM2.5 Benefits/Disbenefits 149
5.2.1 PM2.5 Health Effects 150
5.2.2 Visibility Effects 151
5.3 Ozone Effects 151
5.3.1 Ozone Health Effects 152
5.3.2 Ozone Vegetation Effects 152
5.3.3 Ozone Climate Effects 153
5.4 N02 Health Effects 153
5.5 S02 Health Effects 154
5.6 NO2 and SO2 Health Co-Benefits/Co-Disbenefits 154
5.7 Hazardous Air Pollutant (HAP) Health Impacts 155
5.7.1 Benzene 156
5.7.2 Ethylbenzene 157
5.7.3 Toluene 157
5.7.4 Vinyl Chloride 158
5.7.5 Other Air Toxics 159
Section 6. Impacts of Regulatory Relief 161
6.1 Method for Analyzing Avoided Small Entity Impacts 161
6.1.1 Identifying Affected Sectors and Entities 163
6.1.2 Data Used to Characterize Affected Entities by Size 163
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6.2 Developing Economic and Small Entity Regulatory Relief Impact
Measures 200
6.3 Implementing the Sales Test to Measure Impacts on Industrial,
Commercial and Other Sources under the Primary Scenario 201
6.4 Implementing the Sales Test to Measure Impacts on Industrial,
Commercial and Other Sources under Alternative Scenario 1 229
6.5 Implementing the Sales Test to Measure Impacts on Industrial,
Commercial and Other Sources under Alternative Scenario 2 254
6.6 Comparison of the Percentile Results for Each Scenario 279
Section 7. Limitations and Uncertainties 281
7.1 Avoided Cost Estimate Limitations and Uncertainties 282
7.1.1 Uncertainties in Estimates of Affected Sources 282
7.1.2 Uncertainties in Facility Estimates 282
7.1.3 Uncertainties in Permitting and Supporting Statement Costs 282
7.2 Economic Impact Data and Analysis Limitations and Uncertainties 283
7.3 Sales Test Data Limitations and Uncertainties 283
7.4 Benefits Limitations and Uncertainties 286
Section 8. References 288
Attachments
A Sectors and Source Categories Affected by the Final MM2A Rule A-l
B Summary of Methodology and Data Used to Review Reclassifications B-l
C Estimates Used for Calculating Potential Control Costs for the Illustrative
125 Percent Scenario Cost Analysis C-l
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LIST OF FIGURES
Number Page
1 -1. Cost-to-Sales Ratios Percentile Results for the PRIMARY SCENARIO,
ALTERNATIVE SCENARIO 1, and ALTERNATIVE SCENARIO 2 20
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LIST OF TABLES
Number Page
1 -1. Summary of Illustrative Cost Savings for the PRIMARY SCENARIO (2017$) 9
1-2. Summary of Illustrative Cost Savings for ALTERNATIVE SCENARIO 1
(2017$) 11
1-3. Summary of Illustrative Cost Savings for ALTERNATIVE SCENARIO 2
(2017$) 11
1-4. Summary of Costs or Cost Savings by Time Period 15
2-1. Facilities with Actual Emissions below 75 Percent of the MST under the
PRIMARY SCENARIO 28
2-2. Facilities with Actual Emissions Below 50 Percent of the MST under
ALTERNATIVE SCENARIO 1 30
2-3. Facilities with Actual Emissions Below 125 Percent of the MST under
ALTERNATIVE SCENARIO 2 31
3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) 36
3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1
(2017$) 49
3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2
(2017$) 63
3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) 78
3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1
(2017$) 87
3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2
(2017$) 95
3-7. Estimated Present Value of the Net Cost Savings for Each ALTERNATIVE
SCENARIO (billions of 2017$) 103
3-8. Estimated Equivalent Annualized Value of the Net Cost Savings for Each
ALTERNATIVE SCENARIO (millions of 2017$) 104
4-1. Source Categories Determined to have No Change in Emissions under the
MM2A Final Rule 113
4-2. Number of Facilities in Source Categories Included in Emissions Analysis:
Incremental Across Illustrative Scenarios 117
4-3. Estimation of Potential Emission Change for Petroleum Refinery Facilities in
the PRIMARY SCENARIO 125
4-4. Source Categories Considered for Final Rule Illustrative Analysis of
ALTERNATIVE SCENARIO 2 139
4-5. List of Source Categories with Sources Having Actual HAP Emissions
Between the PRIMARY SCENARIO and ALTERNATIVE SCENARIO 2 140
4-6. HAP Cost-effectiveness Estimates for Source Categories with Available
Control Technologies and Practices Included in Illustrative Analysis of
ALTERNATIVE SCENARIO 2 143
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4-7. Potential Cost Impacts to HAP Source Categories with Sources Under
ALTERNATIVE SCENARIO 2 and Having Available HAP Control
Technologies or Techniques (2017$) 146
6-1. Number of Establishments by Industry and Enterprise Size: 2012 166
6-2. Number of Employees by Industry and Enterprise Size: 2012 177
6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) 189
6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO 206
6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO 217
6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 230
6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 242
6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 255
6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 267
6-10. Avoided Cost-to-Sales Ratios Percentile Results for the Three Scenarios 279
7-1. Data Limitations for Specific NAICS Codes 284
A-1. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO A-l
A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 A-10
A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 A-19
C-l. Nationwide Cost Impacts of Final OLD Amendments (2016$) C-l
C-2. Total Capital Investment and Total Annual Costs (2016$) C-l
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SECTION 1.
EXECUTIVE SUMMARY
1.1 Summary
This Regulatory Impact Analysis (RIA) examines the benefits, costs, and economic
impacts of the final rulemaking titled "Reclassification of Major Sources as Area Sources under
Section 112 of Clean Air Act" (also known as Major MACT to Area (MM2A) rule). The MM2A
rule implements the plain language reading of the Clean Air Act (CAA) section 112 definitions
of "major" and "area" source and allows major sources to reclassify to area source status at such
time the source takes enforceable limits on its potential to emit (PTE) hazardous air pollutants
(HAP) below the MST.
Section 112 of the CAA distinguishes between major and area sources of HAP emissions.
Major sources are larger sources of air emissions than area sources and, generally, different
requirements apply to major sources and area sources.1 Whether a source is a "major source" or
an "area source" depends on the amount of HAP emitted by the source based on its actual or
potential emissions. Section 112 of the CAA defined "major source" to mean a source that emits
or has the potential to emit at or above either of the statutory thresholds of 10 tons per year (tpy)
of any one HAP or 25 tpy of total HAP (henceforth referred to as MST) according to CAA
section 112(a)(1). An "area source" is defined as any source that is not a major source according
to CAA section 112(a)(2). If a source does not emit or does not have the potential to emit at or
above either of the MST, then it is an "area source."
Shortly after the EPA began implementing individual National Emission Standards for
Hazardous Air Pollutants (NESHAP) resulting from the 1990 CAA Amendments, the Agency
received multiple requests to clarify when a major source of HAP could avoid section 112
requirements applicable to major sources by taking enforceable limits on its PTE below the
MST. In response, the EPA issued, on May 16, 1995, a memorandum from John Seitz, Director
of the Office of Air Quality Planning and Standards, to the EPA regional air division directors
(the 1995 Seitz Memorandum). In the 1995 Seitz Memorandum, the EPA stated its interpretation
of the relevant statutory language that facilities that are major sources of HAP may switch to area
source status at any time until the "first compliance date" of the standard. Under this
1 For example, national emission standards for hazardous air pollutants (NESHAP) standards applicable to major
sources of HAP are, with certain exceptions, emissions limits based on maximum available control technology
(MACT) floor and/or beyond the floor analyses under CAA sections 112(d)(2) and (d)(3), while area sources
may be subject to standards based on generally available control technology (GACT) standards rather than
MACT standards, as provided in CAA section 112(d)(5).
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interpretation, facilities that are major sources on the first substantive compliance date of an
applicable major source NESHAP were required to comply permanently with that major source
standard even if the source was subsequently to become an area source by limiting its PTE. This
position was commonly referred to as the "Once In Always In" (OIAI) policy.
On January 25, 2018, the EPA issued a guidance memorandum from William L.
Wehrum, Assistant Administrator of the Office of Air and Radiation, to the EPA regional air
division directors titled "Reclassification of Major Sources as Area Sources Under Section 112
of the Clean Air Act" (MM2A Memorandum).2 In the MM2A Memorandum, the EPA discussed
the plain language of CAA section 112(a) regarding Congress's definitions of "major source"
and "area source," and determined that the OIAI policy articulated in the 1995 Seitz
Memorandum is contrary to the plain language of the CAA and, therefore, must be withdrawn.
The EPA is now proposing regulatory text to implement the plain language reading of the statute
as discussed in the MM2A Memorandum. Under the plain language of the statute, a major source
that takes enforceable limits on its PTE to bring its HAP emissions below the CAA section 112
MST becomes an area source under the plain language of the statute, no matter when the source
may choose to take enforceable measures to limit its PTE HAP emissions. That source, now
having area source status, will not be subject to the CAA section 112 requirements applicable to
the source as a major source under CAA section 112 - so long as the source's actual and PTE
HAP remains below the CAA section 112 thresholds - and will instead be subject to any
applicable area source requirements. The decision of a major source facility to take enforceable
limits on its PTE HAP emissions and reclassify to area source status is purely voluntary.
This RIA estimates the potential net cost savings associated with the reclassification of
major sources as area sources under section 112 of the CAA. The potential cost savings include
illustrative estimates of administrative burden reduction for sources that reclassify to area source
status and are no longer subject to major source NESHAP requirements. These cost savings are
then estimated net of any additional illustrative costs to State and local agencies associated with
the review of potential reclassifications. The economic impacts are separate estimates from the
estimates of cost savings and measure avoided cost to sales for affected sources and industries.
The avoided costs included in the measurement of avoided cost-to-sales ratios are estimates of
administrative burden reduction or cost savings. The RIA does not estimate any costs or cost
savings related to control equipment changes (e.g., decrease in control device operating and
maintenance costs due to reduced device use), though it does provide an illustrative analysis of
2 See notice in 83 FR 5543, February 8, 2018.
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the potential control costs for sources that may reduce HAP emissions in one instance (U.S.
EPA, Sorrels, August 2020). Instead of a quantitative estimate of changes in benefits, the RIA
provides a qualitative assessment of potential health and other benefits.
This RIA uses industry-level (six-digit North American Industry Classification System
[NAICS] code) data and gauges the magnitude of the reduction in regulation for affected sources
by comparing the avoided burden cost estimates to average industry revenues. The burden cost
estimates are in annual terms (2016 and 2017 dollars), and the avoided annualized cost-to-sales
ratios are calculated using average industry revenue and average industry revenue by entity (or
by establishment) size. The U.S. Small Business Administration small business size standards
current list (as of October 1, 2017) is used to define a small entity. We note that this analysis
approach in general was used for the RIA for the Final Prevention of Significant Deterioration
and Title V Greenhouse Gas Tailoring Rule, a regulatory relief rule promulgated in 2010.3
For the final MM2A rule, we have updated the assessment conducted at proposal for the
six source categories and expanded our assessment to numerous additional source categories in
response to public comments. We identify several source categories that are not likely to
experience a change in emissions as a result of MM2A. We also conducted an in-depth analysis
of potential changes in emissions upon reclassification for many source categories where we
have information.
1.2 Summary of Approach for the Analysis
To assess the impacts associated with the MM2A final rulemaking, one would need to
know which sources will reclassify from major source to area source status. Because the EPA
does not know which sources will reclassify, for purposes of this rulemaking, we assessed
potential impacts for three illustrative scenarios, each using a different analytical threshold. For
this assessment, we estimated the number of facilities with actual HAP emissions at or below
these analytical thresholds. Note that the EPA does not project that these facilities will reclassify,
nor do we necessarily expect them to reclassify.4
The 2017 National Emissions Inventory (NEI) whole facility emissions along with source
category modeling files were used to identify facilities with actual emissions for HAP (U.S.
3 The RI A is available at https://www3.epa.gov/ttii/ecas/docs/ria/pemiitting ria fuial-ghg-tailoring-rule 2010-
05.pdf.
4 The EPA has information for 69 facilities that have reclassified from major to area source status since January
2018 in response to the MM2A policy. These facilities are described in the permit review technical support
memorandum for the final MM2A rulemaking.
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EPA, 2020b. The level of actual emissions at which facilities will consider participating in the
MM2A reclassification process can be viewed as a continuous line from some level below the
MST (incorporating a compliance margin below the MST) to a reasonable level above the MST
(for sources that can reduce emissions and take a limit on their PTE to become area sources).
To illustrate the continuous line of actual emissions at which sources will consider
participating in the MM2A reclassification process, for the MM2A illustrative analysis, the EPA
focuses on three analytical scenarios. The 75 percent of the MST at 7.5 tons per year (tpy) for
one HAP or 18.75 tpy for all HAP defines the primary illustrative analytical scenario in this
analysis to calculate the cost savings and economic impact of the implementation of the MM2A
final rule on industry sectors. In addition, to comply with the Office of Management and
Budget's (OMB's) Circular A-4 guidance that analysis of a regulation includes at least three
scenarios (a primary scenario and two alternatives: one more stringent and one less stringent),5
two alternative scenarios are examined. The two alternative illustrative scenarios examined in
this report present: a 50 percent of the MST scenario (alternative scenario 1) and a 125 percent of
the MST scenario (alternative scenario 2). The 50 percent of the MST is at 5 tpy of a single HAP
or 12.5 tpy of all combined HAP. The 125 percent of the MST is at 12.5 tpy of a single HAP or
31.25 tpy of all combined HAP. Our analysis that includes these three alternative scenarios
reflects an illustration of impacts for this final rule in which we present three representations of
potential impacts, where impacts could occur for sources below the MST and for those above the
MST. We are not able to determine exactly which major sources will reclassify nor precisely
what impacts will occur for each source that does choose to reclassify, so the potential impacts
are necessarily illustrative in nature. The analyses in this RIA for these three alternative
scenarios reflect possible outcomes associated with this final rule.
Our analysis of the final MM2A rule includes several key elements:
identification of HAP source categories potentially affected, and thus those that are
not potentially affected, by the final rule;
estimation of the number of facilities in each of these source categories;
estimation of the number of facilities with actual HAP emissions below the thresholds
for the primary illustrative scenario and the two alternative illustrative scenarios;
5 OMB's Circular A-4 is guidance that Federal agencies must follow to comply with Executive Order 12866, the
basis for the content of regulatory impact analyses for rulemakings. This guidance is available at
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A4/a-4.ixlf. and p. 16 of Circular A-4
contains discussion on the development of regulatory alternatives.
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estimation of avoided ongoing labor burden;
estimation of one-time permitting costs for the area source permits;
estimation of area source burdens;
estimation of cost savings;
examination of potential control costs for some sources affected under the 125
percent scenario
estimation of emissions impacts for some source categories;
estimation of the economic impacts of this final rule; and
¦ benefits/disbenefits analysis.
A brief synopsis of these analytical aspects follows.
1.2.1 Baseline
The baseline for this final rulemaking is a state under which facilities that are major
sources on the first substantive compliance date of an applicable major source NESHAP are
required to comply permanently with that major source NESHAP . In terms of emissions, the no-
action case baseline accounts for emissions changes from the maximum allowable emissions
under the major source NESHAP that each major source is subject to. In contrast, the EPA in this
final rule is indicating that a major source can reclassify to area source status at any time by
limiting its PTE HAP to below the MST of 10 tpy of any single HAP or 25 tpy of any
combination of HAP. The implementation of the plain language reading of the statute provides
potential regulatory relief for sources that choose to limit their PTE HAP emissions and
reclassify from major to area source status. As described, the no-action case is the baseline for
this RIA. All of the alternative scenarios analyzed in this RIA estimate the level of potential
regulatory relief in comparison to a baseline of major sources in that status according to their
operating permits.
1.2.2 Analytical Approach for Identifying Affected Sources and Calculating Cost Savings
There are more than 7,000 sources in the major source NESHAP program covering a
total of 114 industrial source categories. To facilitate the analyses conducted for the final rule,
the EPA developed an MM2A database containing data from the 2017 National Emission
Inventory (NEI), data collected to conduct residual risk and technology reviews (RTR) under
sections 112(d)(6) and 112(f) of the CAA (henceforth referred to as RTR modeling file data),
and data from the EPA's Enforcement and Compliance History On-line (ECHO) database. The
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information contained in the MM2A database includes facility name and location, facility ID
number, and HAP emissions data. The majority (and generally the most accurate) of the data
were compiled from the NEI and RTR modeling file data for 74 source categories. The EPA
used the RTR modeling file data and NEI data to estimate the number of facilities in each of
these 74 source categories, and identify those that have actual emissions below the thresholds of
the illustrative analytical scenarios. We used the ECHO data to estimate the number of facilities
in the other 27 source categories. We then used the data for 74 RTR source categories to
extrapolate the number of facilities that could be below the analytical thresholds under analysis
in the other 27 source categories. This analysis, therefore, includes a total of 101 source
categories out of 114 in the major source NESHAP program.
The EPA conducted an illustrative cost analysis to determine the potential impacts of the
removal of the OIAI policy. The cost analysis is illustrative because the final rule does not
mandate facilities to reclassify. A facility's decision to reclassify is voluntary and is based on
several factors specific to the facility and factors specific to a given source category. Among the
factors that may be a basis for a facility's decision to reclassify include the potential financial
and other benefits and costs of changing operations that affect their emissions. Given standard
economic behavior by facilities and the firms that own them, they will select the lowest-cost
opportunities to sustain their emissions below the MST including a reasonable compliance
margin for the facility. The choice to reclassify would be pursued only if the action is a financial
return to the company that weighs the costs of preparing for the reclassification action and the
benefits of not having to comply with one or more major source NESHAP. If it is not
advantageous from a business perspective for the source to undergo reclassification, they will not
seek a change in status in response to MM2A, thus not all facilities below the MST will
reclassify.
To ensure facilities sustain emissions below the MST, facilities that reclassify are likely
to create operating plans that include a compliance margin (i.e., operate at a reasonable level
below the MST to guarantee they maintain area source status). In addition, many industries and
areas of the country have other federal or state regulations the effect of which will continue to
limit HAP emissions after a source reclassifies to area source status. Finally, there are economic
limitations on production levels that can impact the level of potential emission changes. To the
extent that a source's emissions correlate with the level of production and the level of
competitiveness in the markets it is in, a source will face competition and limitations associated
with industry growth (which is linked to how much the product is demanded by consumers) that
will create rigidity in a source's efforts to increase production and hence emissions. All of these
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factors will reduce opportunities to increase emissions to the maximum level permissible under
area source status. As part of this analysis, the EPA examined 114 source categories subject to
major source NESHAP under 40 CFR part 63. The EPA identified 13 source categories that
would not be impacted by the change in policy because either the facilities would not be able to
reach emissions below the MST or the NESHAP for the source category regulates area sources
to the same level as major sources. So, the EPA's analysis therefore reduces to a total of 101
source categories. Of the 101 source categories included in the analysis, 74 were assessed using a
direct approach based on emissions data in the RTR modeling files to estimate the number of
facilities with emissions below the MST scenario, and 24 were assessed using an approach that
relied on extrapolating from the source categories with RTR data to estimate the number of
facilities with emissions below the MST scenario. For three source categories for industrial,
commercial, and institutional (ICI) boilers and process heaters, the EPA also extrapolated from
the RTR data, but used an approach that accounted for the fact that ICI boilers and process
heaters are almost always located with sources subject to additional NESHAP. The EPA
included the Reciprocating Internal Combustion Engines (RICE) source category in the
extrapolated analysis, but did not include any costs or savings in the RIA because the compliance
requirements for RICE at major and area sources are similar.
We received public comments on the analyses conducted at proposal requesting the EPA
to expand the analyses to evaluate all major sources in the NESHAP program. For the final rule,
we evaluate impacts on all source categories included in the major source NESHAP program and
provide some insights to illustrate the potential response to the MM2A rule. As discussed in the
MM2A database memo, of the 114 NESHAP source categories, the EPA determined early in the
analysis of potential impacts that the MM2A rule would not affect facilities in 13 source
categories. For 74 source categories, the EPA used RTR modeling file data to estimate the
number of facilities in each source category and the HAP emissions from each facility. Among
these 74 RTR source categories, the EPA determined that that the MM2A rule would not affect
facilities in 16 source categories. For the remaining 27 source categories, the EPA generally
estimated the number of facilities from the Environmental Compliance History Online
(ECHO)data base, and extrapolated the number of facilities that would be affected from the
source categories for which the EPA had RTR modeling data files. Among these 27 source
categories, the EPA determined that that the MM2A rule would not affect facilities in nine
source categories. In summary, we determined that facilities in 38 source categories would not be
affected by the MM2A rulemaking.
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For a detailed description of how the EPA identified and assessed affected sources
categories, please see the two memoranda, Documentation of the Data for Analytical Evaluations
& Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major
Sources as Area Sources Under Section 112 of the Clean Air Act, " and Documentation of the
compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as
Area Sources Under Section 112 of the Clean Air Act" (ERG, 2020a and 2020b).
For the source categories for which there are completed RTR modeling files, the EPA
used the modeling files to approximate the total number of major source facilities in each source
category. The EPA also used the RTR modeling files to estimate the number of facilities that
could obtain area source status per source category under the three scenarios that are referred to
in this RIA as the primary scenario, alternative scenario 1, and alternative scenario 2. For the 27
source categories for which EPA does not have RTR modeling files, the EPA used the ECHO
database to estimate the number of major source facilities. To illustrate the potential for facilities
with emissions below the MST for these 27 source categories, the EPA used 3-digit NAICS
codes to match each extrapolated category to directly assessed source categories with RTR data.
The two documentation memoranda (ERG, 2020a and 2020b) explain how the EPA calculated
the number of major source facilities, the facilities with emissions below the MST and the
estimated net cost savings per source category. The estimated net cost savings are based on
deregulatory cost savings as measured by avoided supporting statement costs (avoided labor
burden), costs associated with reclassification permit applications, and the costs of the area
source rule requirements (area source burden). A summary description of the cost savings or
avoided costs of the final MM2A rule is provided in Section 1.3.
Given that the actions of sources and businesses in response to this final rule are entirely
voluntary, the analyses in this RIA, including the estimates of cost savings, are illustrative. The
analytic timeline is assumed to begin with the year 2021, the year after the expected
promulgation of this rule. In preparing the final analyses, the EPA concluded that not all of the
reclassifications will likely occur in the first year after the rule is issued as assumed at proposal.
This conclusion is consistent with findings from the review of the 69 actual reclassifications that
have taken place that is included in the Permit Review and Reclassifications TSM and
summarized in Attachment B of this RIA. To illustrate the potential cost impact of the policy, the
EPA presents both the impacts if all reclassifications occur in a single year (i.e., the first year),
and a 5-year outlook that assumes all sources included in the facility count will reclassify in that
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timeframe and assumes 6the reclassifications are evenly distributed over the years within this
outlook. Thus, in our final illustrative analysis, potential reclassifications will be complete by the
end of 2024. This would be the case for all scenarios included in the analysis. We also presume
that all sources in the MM2A database with emissions below the MST will voluntarily choose to
reclassify and incur the estimated costs. Once reclassifications are complete, the sources receive
a cost savings from reduced monitoring, recordkeeping, and reporting (MRR) of the major
source NESHAP program in all subsequent years and incur costs to meet area source
requirements in all subsequent years. These cost savings begin to accrue in the second year after
reclassification. Thus, 2025 (the fifth year after all reclassifications are processed) displays the
annual cost savings that continue in all future years given that there is no required review time
for this change in policy. Table 1-1 summarizes the illustrative cost savings and number of
facilities that may obtain area source status for the primary scenario analyzed. As shown in Table
1-1, the illustrative or potential annual cost savings for the primary scenario is negative $4.0
million (2017 dollars) in year 1 (spread evenly over 4 years). For year 5 (2025) and years
thereafter, the illustrative or potential cost savings is $90.6 million annually (2017 dollars).
Table 1-1. Summary of Illustrative Cost Savings for the PRIMARY SCENARIO (2017$)
Total Number of
Facilities in Source
Coverage of Source
Category Subject to
Facilities with Emissions
Potential Net Annual
Categories
Major Source NESHAP
Below 75% of the MST
Cost Savings (2017$)
Source Categories with RTR
4,068
1,614 (39.7%)
($2.5) Million (year 1)
data (74 Categories)
$56.1 Million (year 5)
All Other Source Categories
1,294
266 (20.6%)
($0.4) Million (year 1)
(24 Categories)
$9.0 Million (year 5)
ICI Boilers and Process
1,821
687 (37.7%)
($1.1) Million (year 1)
Heaters (3 categories)
$25.5 Million (year 5)
All Source Categories
7,183
2,567 (35.7%)
($4.0) Million) (year 1)
$90.6 Million (year 5)
Sources: Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations &
Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources
Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group.
August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act".
Memorandum for U.S. EPA/OAQPS/SPPD. Net annual cost savings in parentheses denote negative estimates
(i.e., positive costs).
6 We acknowledge that facilities that choose to reclassify have some finite period of time in which they will operate.
Industrial plant lifetimes can be 25 years or longer, according the U.S. Energy Information Administration (EIA)
(2015). Given the extent and variety of sectors, with several of them that are not industrial in nature, we chose
not to analyze the impacts of the final rule over a definite period of time.
9
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Tables 1-2 and 1-3 summarize the illustrative cost savings and number of facilities with
actual emissions below the thresholds for alternative scenario 1 and alternative scenario 2. As
shown in Tables 1-2 and 1-3, the illustrative or potential annual cost savings for these scenarios
are negative $3.3 million and negative $4.9 million (2017 dollars), respectively, in year 1 (spread
evenly over 4 years). For year 5 and years thereafter, the illustrative or potential cost savings are
$73.8 million and $111.0 million annually, respectively (2017 dollars).
To comply with Executive Order (EO) 12866, we have also estimated the present value
(PV) of the illustrative cost savings for each scenario. For this analysis, there is the presumption
of an infinite time horizon to estimate the PV, given that there is no review period for this action
stated in the CAA. The PV of the cost savings for the primary scenario is $0.86 billion (in 2017
dollars) at a discount rate of 7 percent, which is discounted to 2020. At a discount rate of 3
percent, the PV is $1.50 billion (in 2017 dollars), again discounted to 2020. In 2016 dollars,
these present values are $0.84 billion and $1.47 billion, again discounted to 2020. In addition, the
PV is $0.63 billion at a 7 percent discount rate and $1.12 billion at a 3% discount rate, in 2016
dollars and discounted to 2016. A measure of the annual cost savings consistent with the PV
estimate is the equivalent annualized value (EAV), and this is $68 million (2017 dollars) at a 7
percent rate for the primary scenario. At a 3 percent discount rate, the EAV is $76 million (2017
dollars). In 2016 dollars, the EAV is $67 million at a 7 percent discount rate and $75 million at a
3 percent rate. Finally, the EAV is $51 million at a 7 percent discount rate and $57 million at a 3
percent rate in 2016 dollars, and discounted to 2016. We show the PVs and EAVs in 2016
dollars as well as 2017 dollars to comply not only with EO 12866 but also with EO 13771.7 All
of the PVs and EAVs are estimated presuming an infinite time horizon (i.e., perpetuity).
We also estimate the potential control costs for some sources that may reduce HAP
emissions under alternative scenario 2. Alternative scenario 2 differs from the primary scenario
and alternative scenario 1 in that facilities with emissions above major source levels would have
to reduce their actual HAP emissions in order to reclassify, either by adopting controls or process
modifications that reduce emissions, or by reducing production or throughput to reduce
emissions. The sources in this alternative illustrative scenario would consider the cost associated
with reducing emissions below the MST against the avoided costs associated with no longer
having to comply with the major source NESHAP compliance requirements when deciding
7 Executive Order 13771, "Reducing Regulation and Controlling Regulatory Costs," Guidance from US OMB on
complying with Executive Order 13771 can be found at
https://www.federalregister.gOv/documents/2017/02/03/2017-02451/reducing-regulation-and-controlling-
regulatory-costs and https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2017/M-17-21-
OMB.pdf
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whether to pursue reclassification. We examine this cost consideration in our analysis of
alternative scenario 2 as applied to several source categories. This analysis and its results are
described in more detail in Section 4 of this RIA and in the memorandum for this analysis (U.S.
EPA, Sorrels, August 2020).
Table 1-2. Summary of Illustrative Cost Savings for ALTERNATIVE SCENARIO 1
(2017$)
Total Number of
Facilities in Source
Facilities with
Coverage of Source
Category Subject to
Emissions Below
Potential Net Annual
Categories
Major Source NESHAP
50% of the MST
Cost Savings (2017$)
Source Categories with RTR
4,068
1,345 (33.1%)
($2.1) Million (year 1)
data (74 Categories)
$46.2 Million (year 5)
All Other Source Categories
1,294
219 (16.9%)
($0.3) Million (year 1)
(24 Categories)
$7.5 Million (year 5)
ICI Boilers and Process Heaters
1,821
545 (29.9%)
($0.9) Million (year 1)
(3 categories)
$20.1 Million (year 5)
All Source Categories
7,183
2,109 (29.4%)
($3.3) Million (year 1)
$73.8 Million (year 5)
Source: Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations &
Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources
Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group.
August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act".
Memorandum for U.S. EPA/OAQPS/SPPD. Net annual cost savings in parentheses denote negative estimates
(i.e., positive costs).
Table 1-3. Summary of Illustrative Cost Savings for ALTERNATIVE SCENARIO 2
(2017$)
Total Number of
Facilities in Source
Facilities with
Coverage of Source
Category Subject to
Emissions Below
Potential Net Annual
Categories
Major Source NESHAP
125% of the MST
Cost Savings (2017$)
Source Categories with RTR
4,068
1,965 (48.3%)
($3.1) Million (year 1)
data (74 Categories)
$68.7 Million (year 5)
All Other Source Categories
1,294
330 (25.5%)
($0.5) Million (year 1)
(24 Categories)
$11.5 Million (year 5)
ICI Boilers and Process Heaters
1,821
814 (44.7%)
($1.3) Million (year 1)
(3 categories)
$30.7 Million (year 5)
All Source Categories
7,183
3,109 (43.3%)
($4.9) Million (year 1)
$111.0 Million (year 5)
Source: Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations &
Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources
Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group.
August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act".
Memorandum for U.S. EPA/OAQPS/SPPD. Net annual cost savings in parentheses denote negative estimates
(i.e., positive costs).
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1.2.3 Economic Impact Estimation Approach
To estimate the economic impacts of this final rule, the EPA implemented the sales test to
measure impacts on industrial, commercial, and other sources. The sales test is an approach that
computes the annualized compliance costs as a share of sales for each company and is often the
methodology the EPA employs in economic impact analyses such as this one. Another
methodology is a profits test, in which annualized compliance costs are calculated as a share of
profits.8 The EPA employs the sales test methodology because revenues or sales data are
commonly available data for entities affected by EPA regulations, and profits data normally
made available are often not the true profits earned by firms because of accounting and tax
considerations. Firms and entities often have ways legally available in the tax code to minimize
their reported profits; thus, using reported profits may lead to a less than accurate estimate of the
economic impact of a regulation to an affected firm or entity and their consumers. Although
screening-level analyses are often employed to estimate impacts to small businesses or entities as
part of an analysis in compliance with the Regulatory Flexibility Act as amended by the Small
Business Regulatory Enforcement Fairness Act (SBREFA), a screening-level analysis can also
be used in an economic impact analysis such as this one whose focus is on the regulated
companies. Given a general lack of information on the identity of owners of companies
potentially affected by the final rule, the EPA implemented the recommended sales test and
computed cost-to-sales ratios for affected sectors at the establishment (or facility) level.9
Information on establishments, employees, and receipts (sales) was taken from the latest
complete set of data from the U.S. Economic Census (for 2012, the most recently complete
Economic Census).10 For NAICS 115114, Postharvest Crop Activities, and 611310, Colleges and
Universities, the data are from the 2012 County Business Patterns. The cost-to-sales ratios
8 More information on sales and profit tests as used in analyses done by the EPA can be found at
http://www.epa.gov/sbrefa/documents/rfaguidancell-00-06.pdf. pp. 32-33.
9 Typically, SBREFA impact assessments are conducted at the ultimate parent company level. The EPA assumed
that the U.S. Census Bureau definition of enterprise is equivalent to ultimate parent company. Theoretically, the
comparison of compliance costs to sales should be conducted at the enterprise level. Because the U.S. Census
Bureau only provides data for typical establishments within various enterprise size categories, the EPA chose to
compute the cost-to-sales ratio at the establishment (or facility level). The same ratio could be computed at the
enterprise level by multiplying both the numerator and the denominator by the typical number of establishments
per enterprise in the appropriate enterprise size categories. Using the 2012 Economic Census data on typical
establishments means that the cost-to-sales ratios are identical, whether computed at the establishment level or at
the enterprise level.
10The 2012 Economic Census is the most recent version that is complete and publicly available. The 2017 Economic
Census started being released in stages beginning in September 2019 and will continue to be released until
December 2021. Because all of the data for the 2017 Economic Census are not yet released, the EPA chose to
use the complete datasets from the 2012 Economic Census for the final RIA. See
https://www.census.gov/programs-survevs/economic-census/news-utxlates/releases.html for more details.
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examine the ratio of the average establishment's total yearly avoided costs to the average
establishment receipts for enterprises within several employment categories.
1.2.4 Benefits/Disbenefits Analysis
The benefits/disbenefits analysis describes the human health impacts associated with the
final rule. This final rule may potentially result in both emission reductions and increases from a
broad array of existing sources. As described in Section 5, pollutant emissions that may be
affected include HAP, volatile organic compounds (VOCs), which are precursors to both fine
particulate matter (PM2.5) and ozone formation; sulfur dioxide (SO2), which is a precursor to
PM2.5; oxides of nitrogen (NOx), a precursor to both PM2.5 and ground-level ozone; organic HAP
such as benzene, ethylbenzene, toluene, and vinyl chloride; and methane, a greenhouse gas
(GHG) and precursor to ozone formation. As described in the subsequent sections, these
pollutants are associated with substantial health effects, climate effects, and other welfare effects.
Although the illustrative emissions analysis suggests that there may be both emission increases
and decreases among source categories, we are uncertain of the magnitude, direction, and
geographic distribution of changes in the emissions across the broad array of sources resulting
from this rulemaking. As such, we are unable to quantify the changes in some HAP and all other
pollutant emissions across these sources and cannot either simulate the change in air quality or
characterize the impact of these changes to human health. This is not to imply that changing
emissions will not affect human health. Rather, our approach reflects the challenges associated
with modeling the direct and indirect impacts of the reductions in emissions for these sectors
with the data currently available. In place of quantitative estimates of the quantity and economic
value of the pollutant changes, we instead characterize these impacts in qualitative terms. Section
5 provides a qualitative assessment of the health benefits associated with altering exposure to
these pollutants, as well as visibility impairment and ecosystem benefits.
1.3 Avoided Costs of the Final MM2A Rule
The EPA identified the facilities that could potentially be affected by the final MM2A
rule. These facilities are classified as major sources that might opt to seek reclassifications to
area source status with the final MM2A rule. The MM2A cost analysis memo describes how the
estimated cost savings per source category were calculated for the source categories for which
the EPA has completed RTR modeling files. Once a facility achieves area source status, there
will be deregulatory cost savings due to avoided monitoring, recordkeeping, and reporting costs.
However, the facility will still incur compliance costs as an area source facility. There will be
costs associated with a reclassification permit application incurred by the facility and by the state
agency. These permitting costs are one-time in nature and are reflected in the year 1 cost savings
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estimates. The MM2A cost analysis memo describes how the deregulatory cost savings,
compliance costs, and permitting costs are calculated. The EPA used the costs associated with
obtaining a Minor New Source Review (NSR) Permit to calculate the costs to a facility of
obtaining a permit to limit the PTE below the MST. The EPA used the permitting costs
associated with an Administrative Amendment under 40 CFR part 70 (Administrative
Amendment) to calculate the costs to a facility of modifying its existing operating permit to
remove the major source NESHAP requirements and include any relevant area source NESHAP
requirements. The EPA used the same minor NSR and Administrative Amendment permitting
processes to estimate the cost incurred by a state agency to review and process the permit
modifications. The one-time facility permitting cost is $4,089 per facility (2017 dollars), and the
one-time permitting agency burden is $2,198 per facility (2017 dollars).
The estimated illustrative net cost savings in the first year after major source facilities
obtain area source status (or year 1) is the sum of the permitting costs to the facilities, and the
permitting costs to the state agencies. At proposal, we expected that all potential reclassifications
would take place in one year. Based on the number of potential reclassifications discussed in this
final analysis, we can confidently conclude that not all of the reclassifications will occur in the
first year after the rule is issued. There are a limited number of hours in a year by which these
reclassifications can be processed and determinations can be issued as final actions. The timing
of a reclassification is influenced by several considerations including: time for facilities to
determine whether it is in their best interests to reclassify, time to prepare applications for
reclassification, and time for permitting authorities to review applications and process
reclassification requests. There is also time allotted for the EPA to review determinations by
permitting authorities (i.e., for Title V operating permit renewals), and for public participation in
the process. Given these considerations, it is reasonable to assume that not all the
reclassifications will occur within one year after the MM2A rule is finalized and instead the
reclassifications assessed in the cost analysis will occur over some extended period of time. To
illustrate the cost impact of the policy, we present both the impacts if all reclassifications occur
in a single year, and a 5-year outlook that assumes all sources will reclassify in that time frame
and assumes the reclassifications are evenly distributed over the years.
Thus, in our final illustrative analysis, potential reclassifications will be complete by the
end of 2024. This would be the case for all scenarios included in the analysis. We also presume
that all sources in the MM2A database with emissions below the MST will voluntarily choose to
reclassify and incur the estimated costs. We therefore illustrate the cost impact of the policy
change by presenting both the impacts if all reclassifications occur in a single year and a 5-year
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outlook that assumes all sources included in our facility counts will reclassify in that timeframe,
and assumes the reclassifications are evenly distributed over the years.
Table 1-4 shows, relative to the baseline, the timing of potential costs and cost savings
that lead to an overall net annual cost savings for this final rule. The estimate of cost savings for
each year do not account for changes in the costs of control equipment that may be associated
with reclassification from major to area source status, such as capital, energy, and operating and
maintenance costs.
Table 1-4. Summary of Costs or Cost Savings by Time Period
Source Size
Year 1
Year 5 and Years Thereafter
Major Source
Deregulatory cost savings
Area Source
¦ Ongoing reporting costs
(existing area sources)
¦ Ongoing reporting costs
(existing area sources)
¦ Ongoing reporting costs
(new area sources)
¦ Ongoing reporting costs
(new area sources)
¦ One-time permitting costs
(new area sources)
For the 27 source categories for which the EPA does not have complete RTR modeling
files, the EPA used an extrapolated approach. The EPA used 3-digit NAICS codes to match each
of these categories (called extrapolated categories) to the directly assessed source categories with
RTR modeling data. Then, for each source category for which EPA did not have RTR modeling
data, we summed the estimated cost savings in year 1 for the source categories with RTR
modeling data that were matched by NAICS code to the category being evaluated. This was then
divided by the number of facilities in the matching NAICS code to obtain the average cost
savings in year 1 per facility. The same was then done for the cost savings in year 2 per facility.
These average cost savings per facility were then multiplied by the estimated number of facilities
that would be eligible to obtain area source status in each of the categories for which EPA did
not have RTR modeling data to calculate the cost savings for each source category.
The EPA calculated the sum of estimated net cost savings for years 1 (2021) and years up
to year 5 (2025 and beyond) of the source categories that were matched to the extrapolated
category. Next, the EPA determined the average cost savings for years 1 and 5, and the other
years in the analysis, for the matched source categories and used these to determine the cost
savings for the extrapolated category. The MM2A Cost Analysis Memorandum describes the
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extrapolated approach to calculate cost savings in detail.11 This MM2A Cost Memorandum also
details the methodology for calculating the estimated cost savings for the separate categories of
ICI Boilers and Process Heaters and RICE. The EPA developed a list of facilities for RICE by
downloading the data for major source facilities subject to 40 CFR 63, subpart ZZZZ from
ECHO. Because subpart ZZZZ regulates both major and area sources and the compliance
requirements are similar for RICE at major and area sources, the EPA assumed no cost savings
for RICE located at major source facilities that obtain area source status. Although it is possible
that these facilities would experience some savings, the EPA does not currently have enough
detailed data to quantify those savings. However, the EPA estimated costs for the first year to
obtain area source permits as a facility permit cost and a regulatory agency permit cost. No costs
or savings were estimated for subsequent years.
1.4 Results
1.4.1 A dministrative Cost Savings
The illustrative net cost savings in Tables 1-1, 1-2, and 1-3 are the avoided administrative
burden for years 1 and 5. The illustrative or potential net annual cost savings for the primary
scenario is negative $4.0 million (2017 dollars) in year 1. For year 5 and years thereafter, the
illustrative or potential net cost savings are $90.6 million annually (2017 dollars). For alternative
scenario 1, the illustrative or potential annual net cost savings are negative $3.3 million (2017
dollars) in year 1 and $73.8 million (2017 dollars) in year 5. For alternative scenario 2, the
illustrative or potential annual net cost savings are negative $4.9 million (2017 dollars) in year 1
and $111.0 million (2017 dollars) in year 5. Thus, there are negative net annual cost savings in
year 1 (2021), or positive costs, under each alternative scenario, but positive annual net cost
savings in all years thereafter, including years 2 through 4 as shown in the MM2A cost analysis
memorandum.
1.4.2 Economic Impact Findings for the Primary Scenario
The year 1 (2021) potential avoided cost-to-sales ratios range from -0.19 percent to less
than 0.01 percent, with a median (or 50th percentile) potential avoided cost-to-sales ratio of less
than 0.01 percent across all employment size categories. The twenty-fifth (25th) percentile and
seventy-fifth (75th) percentile avoided cost-to-sales ratio in year 1 are -0.01 percent and less than
0.01 percent respectively across all employment size categories. The year 5 (2025 and beyond)12
11 The MM2A Cost Analysis Memorandum includes the net annual cost savings estimates for years 2, 3, and 4 for
all source categories and alternative scenarios.
12 The impacts of the final rule in 2025 and beyond are those annual impacts that reflect full implementation of this
final rule according to this analysis.
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avoided cost-to-sales ratios range from less than 0.01 percent to 5.68 percent, with a median
potential avoided cost-to-sales ratio of 0.05 percent across all employment size categories. The
twenty-fifth percentile and seventy-fifth percentile avoided cost-to-sales ratios in year 5 are 0.01
percent and 0.17 percent, respectively, across all employment size categories. Figure 1-1 below
in Section 1.5 provides a chart of these values.
Because facilities according to our analysis do not face permitting costs in year 5 and all
reclassifications have taken place, the cost savings are larger in year 5 than year 1, and the
resulting avoided cost-to-sales ratios are larger. For example, NAICS 337110 (Wood Kitchen
Cabinet and Countertop Manufacturing) has an overall year 1 avoided cost-to-sales ratio of -0.06
percent and an overall year 5 avoided cost-to-sales ratio of 0.52 percent. Some NAICS codes that
have less than 0.01 percent ratios in year 1 have positive ratios in year 5, such as NAICS 327310
(Cement Manufacturing), which has an overall avoided cost-to-sales ratio of less than 0.01
percent in year 1 and 0.09 percent in year 5.
As discussed above, we conducted a small entity analysis for both year 1 and year 5
impact estimates. In year 1, some small size categories have very small negative avoided cost-to-
sales ratios. The "fewer than or equal to 19 employees" category of NAICS 424710 (Petroleum
Bulk Stations and Terminals) has a less than 0.01 percent avoided cost-to-sales ratio, and the "20
to 99 employees" category of NAICS 325120 (Industrial Gas Manufacturing) has a less than
0.01 percent avoided cost-to-sales ratio. However, there are other cases of more negative
economic impacts in year 1 for small size categories, even though these impacts are small in
absolute terms. In year 1, the "fewer than or equal to 19 employees" category of NAICS 562211
(Hazardous Waste Treatment and Disposal), has a -0.06 percent avoided cost-to-sales ratio .
Establishments in this size category are considered small businesses for NAICS 562211 because
the average receipts per establishment in 2017 dollars is $1.8 million which is less than the SBA
size standard of $38.5 million for this NAICS code. For the same size category, NAICS 493110
(General Warehousing and Storage) has an avoided cost-to-sales ratio of -0.11 percent in year 1.
Establishments in the "fewer than or equal to 19 employees" size category for NAICS 493110
are treated as small businesses for purposes of this analysis because the average receipts per
establishment in 2017 dollars is $0.9 million which is less than the SBA size standard of $27.5
million for this NAICS code.
In year 5, small entities generally have larger cost savings and the resulting avoided cost-
to-sales ratios are larger. For example, for NAICS 213112 (Support Activities for Oil and Gas
Operations) the "fewer than or equal to 19 employees" category in year 1 has an avoided cost-to-
sales of -0.05 percent and in year 5, the ratio is 0.69 percent. Establishments in the "fewer than or
17
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equal to 19 employees" size category for NAICS 213112 are treated as small businesses for
purposes of this analysis because the average receipts per establishment is $2.2 million in 2017
dollars which is less than the SBA size standard of $38.5 million. For NAICS 562211, for the
"fewer than or equal to 19 employees" category, the avoided cost-to-sales ratio in year 5 is 4.95
percent.
1.4.3 Findings for Alternative Scenario 1
For the first alternative scenario with a threshold of 50 percent, the year 1 avoided cost-
to-sales ratios range from -0.19 percent to less than 0.01 percent, with a median avoided cost-to-
sales ratio of less than 0.01 percent across all employment size categories. The twenty-fifth
percentile and seventy-fifth percentile avoided cost-to-sales ratio in year 1 are -0.01 percent and
less than 0.01 percent, respectively, across all employment size categories. The year 5 avoided
cost-to-sales ratios range from less than 0.01 percent to 5.69 percent, with a median avoided
cost-to-sales ratio of 0.05 percent across all employment size categories. The twenty-fifth
percentile and seventy-fifth percentile avoided cost-to-sales ratio in year 5 are 0.03 percent and
0.23 percent, respectively, across all employment size categories.
Because facilities that may reclassify would not face permitting costs by year 5 and all
reclassifications would be expected to have occurred by this time, the cost savings are larger and
the resulting avoided cost-to-sales ratios are higher in year 5 than year 1. For example, NAICS
493110 (General Warehousing and Storage) has an overall year 1 avoided cost-to-sales ratio of -
0.06 percent and an overall year 5 avoided cost-to-sales ratio of 1.34 percent. All NAICS codes
have negative cost-to-sales ratios in year 1, and positive cost-to-sales ratios in year 5.
Like the primary scenario, we conducted a small entity analysis for both year 1 and year
5 impact estimates for the alternate scenario 1. In year 1, some small size categories have small
negative avoided cost-to-sales ratios. NAICS 424710 (Petroleum Bulk Stations and Terminals)
has an avoided cost-to-sales ratio of less than 0.01 percent for the "fewer than or equal to 19
employees" category and less than 0.01 percent for the "20 to 99 employees" category in year 1.
There are no cases of positive economic impacts for year 1, but there are cases of larger positive
economic impacts for small size categories in year 5. NAICS 332812 (Metal Coating, Engraving
(except Jewelry and Silverware), and Allied Services to Manufacturers) has an avoided cost-to-
sales ratio of -0.12 percent for the "fewer than or equal to 19 employees" category in year 1, and
NAICS 493190 (Other Warehousing and Storage), has an avoided cost-to-sales ratio of 3.35
percent for the same size category in year 5. Establishments in the "fewer than or equal to 19
employees" size category for NAICS 493190 are considered small businesses for purposes of
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this analysis because the average receipts per establishment is $0.7 million, which is less than the
SBA size standard of $27.5 million for this NAICS code.
1.4.4 Findings for Alternative Scenario 2
For alternative scenario 2, which has a threshold of 125 percent MST, the year 1 avoided
cost-to-sales ratios range from -0.19 percent to less than 0.01 percent, with a median avoided
cost-to-sales ratio of less than 0.01 percent across all employment size categories. The twenty-
fifth percentile and seventy-fifth percentile avoided cost-to-sales ratio in year 1 are -0.01 percent
and less than 0.01 percent, respectively, across all employment size categories. The year 5
avoided cost-to-sales ratios range from less than 0.01 percent to 5.75 percent, with a median
avoided cost-to-sales ratio of 0.06 percent across all employment size categories. The twenty-
fifth percentile and seventy-fifth percentile avoided cost-to-sales ratio in year 5 are 0.02 percent
and 0.18 percent, respectively, across all employment size categories.
Because facilities that may reclassify would not face permitting costs by year 5 and all
reclassifications would be expected to have occurred by this time, the cost savings are generally
larger, and the resulting avoided cost-to-sales ratios are larger in year 5 than year 1. For example,
NAICS 562211 (Hazardous Waste Treatment and Disposal) has an overall year 1 avoided cost-
to-sales ratio of -0.01 percent and an overall year 5 avoided cost-to-sales ratio of 1.04 percent.
Some other NAICS codes that have negative ratios in year 1 have positive ratios in year 5, such
as NAICS 326191 (Plastics Plumbing Fixture Manufacturing), which has an overall avoided
cost-to-sales ratio of -0.01 percent in year 1 and 0.29 percent in year 5.
Like for the primary scenario and alternative scenario 1, we conducted a small entity
analysis for both year 1 and year 5 impact estimates for alternative scenario 2. In year 1, small
size categories have negative avoided cost-to-sales ratios. For instance, NAICS 488210 (Support
Activities for Rail Transportation) has an avoided cost-to-sales of -0.09 percent for the "fewer
than or equal to 19 employees" category and -0.01 percent for the "20 to 99 employees" category
in year 1. However, there are cases of larger positive economic impacts for small size categories
in year 5. NAICS 332812 (Metal Coating, Engraving (except Jewelry and Silverware), and
Allied Services to Manufacturers) has a year 5 "fewer than or equal to 19 employees" category
avoided cost-to-sales ratio of 5.75 percent, and NAICS 493110 (General Warehousing and
Storage) has a year 5 avoided cost-to-sales ratio of 2.75 percent for the same size category. As
stated previously, for this analysis, establishments in this size category for NAICS 493110 are
treated as small businesses based on the SBA size standard for this NAICS code.
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1.5 Comparison of the Percentile Results for Each Scenario
Figure 1-1 displays the cost-to-sales ratios percentile results for the primary and two
alternative scenarios. In year 1, the twenty-fifth percentiles, fiftieth percentiles (medians), and
seventy-fifth percentiles across all employment size categories are very similar across the three
scenarios. The twenty-fifth percentiles are -0.01 percent for each scenario, the medians are less
than 0.01 percent for each scenario, and the seventy-fifth percentiles are less than 0.01 percent
for each scenario. Hence, in year 1 these percentiles are approximately the same for each of the
three scenarios.
Figure 1-1. Cost-to-Sales Ratios Percentile Results for the PRIMARY SCENARIO,
ALTERNATIVE SCENARIO 1, and ALTERNATIVE SCENARIO 2
0.35%
0.30%
0.25%
0.20%
0.15%
0.10%
0.05%
0.00%
I
Year 1 Year 5 j Year 1 Year 5 Year 1 Year 5
-0.05% MST 75% MST 50% MKT 125%
75th Percentile
¦ 5Dth Percentile (Median)
25th Percentile
Note: The Year 1 percentile results are for 2021. The Year 5 percentile results are for Year 5 (2025) and years
thereafter.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, SBA February 2016
Size Standards, SBA 2007 Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern
Research Group. August 2020a. MM2A Database Memorandum, Analytical Evaluations & Summary of
Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under
Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group.
August 2020b. MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final rulemaking
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for
U.S. EPA/OAQPS/SPPD.
In year 5 (2025 and beyond), the percentiles across all employment size categories are
also quite similar across the three scenarios. The twenty-fifth percentiles are between 0.01
percent and 0.03 percent for the three scenarios, the medians are between 0.05 percent and 0.06
percent for each scenario, and the seventy-fifth percentiles are between 0.17 percent and 0.23
percent for the three scenarios (0.17 percent for the primary scenario, 0.23 percent for alternative
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scenario 1 and 0.18 percent for alternative scenario 2). Hence, in year 5 the median is similar
across the alternative scenarios, the twenty-fifth percentile results are also similar across
scenarios, but the seventy-fifth percentiles are slightly different across scenarios. We note that
these impacts for each scenario are less than half of those for the proposal, reflecting the lower
estimate of net cost savings for the final rule as compared to those for the proposal. The
estimated net annual cost savings for the final rule are less than half of those for the proposal.
This change in net annual cost savings is the result of several factors: 1) the updated and
enhanced final emissions database; 2) elimination of the double counting of sources when
subject to multiple NESHAP; 3) updated 2017 emission information; and 4) updated cost
parameters (the updated permitting costs and MRR costs), and our methodology that spreads out
the cost impacts included in the final rule. At proposal, we assumed that all reclassifications
would be expected to occur by the end of 2022. In the final rule all reclassifications that take
place would be expected to occur by the end of 2024. Hence, the net cost savings will occur later
according to the final rule analysis compared to that for the proposal.
The EPA recognizes there are efficiency considerations that may be inherent with the
implementation of the final MM2A rule. This final rule implements the plain language reading of
the CAA section 112 definitions of "major" and "area" source and provides major sources of
HAP with the flexibility and opportunity to reclassify to area source status provided they reduce
their emissions and HAP PTE below the major source thresholds. In contrast to OIAI, MM2A
may provide potentially valuable incentives for research, development and diffusion of
innovative, environmentally benign technologies that allow firms to substitute away from HAP-
intensive production processes. While it is widely recognized that such incentives are important
for sustainable economic growth, they are difficult to characterize empirically, or forecast. The
flexibility provided by the rule allows major sources of HAP to no longer be subject to major
source NESHAP requirements, which could result in a transfer of resources to production
processes that could be used for technological innovation or investment to modernize regulated
sources. If the final rule leads to greater incentives to invest and modernize regulated sources,
this could lead to economic improvements across the country and thus increase overall efficiency
from a social welfare standpoint.
We are unable to measure the economic value of the greater flexibilities provided by this
rule and any potential change in innovation that could result. However, the reduction in costs of
monitoring, recordkeeping and reporting associated with reclassification to area source status
could lead to input substitution and other changes in the production process, particularly if the
cost of compliance with a major source NESHAP is a nontrivial fraction of the overall cost of
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production. To the extent that this rule encourages capital investments that improves the
efficiency of the production process, less costly production of both end-use and intermediate
outputs could lead to greater consumer demand, potentially improving social welfare, all else
equal. The overall social costs and impacts of this rule, however, will depend on the relative
magnitudes of these demand side effects and changes to the returns to factors of production. If an
effect of this final rule is additional capital investment, then owners of capital will be better off
as a result of the increase in return to capital. If the increased return to capital leads to a reduction
in the return to labor, then less labor may be required in production, which would impact the
overall social costs and impacts of this rule.
1.5.1 Reclassification Considerations
This RIA also recognizes and evaluates other behavioral responses to the action,
including any potential change in emissions as a result of the rule. The EPA analyzed the 69
sources that have reclassified since January 2018 and also completed an illustrative analysis of
potential reclassifications across numerous source categories, and concluded that most of these
sources are not expected to increase emissions if they were to reclassify to area source status. In
the illustrative analyses of impacts, the EPA does recognize, however, that some sources may
increase or decrease their emissions if they were to reclassify and permitting authorities allow for
changes in the enforceable conditions or practices used to comply with major source NESHAP
requirements. We present these estimates of emissions increases or decreases in section 4 and
Attachment B in this RIA. While some sources may increase their emissions after they reclassify,
in most cases the potential change in emissions is modest and limited by many factors related to
other regulatory limits, technology requirements, and economic reasons as discussed later in this
RIA. Such potential emissions increases are consistent with the plain language and the statutory
structure that Congress created in CAA section 112 as discussed in section IV of the preamble.
We recognize that any potential emissions increases related to this action may have the
potential to lead to disbenefits to exposed populations, and vice versa for any potential emissions
decreases. Benefits and disbenefits that may be associated with this action are discussed in
section 5 of the RIA. Such benefits and disbenefits, if they were to occur, could affect overall
efficiency from a social welfare standpoint.
1.6 Limitations and Uncertainties of the Analysis
This economic analysis has several sources of uncertainty. The most prominent
uncertainty is that the EPA does not know which HAP major sources will take advantage of the
opportunity to reclassify. The EPA recognizes that it is only able to quantify the approximate
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number of facilities that are currently below the MST thresholds and be potentially eligible to
reclassify. We are not able to precisely estimate the number of facilities that will actually choose
to reclassify. It is possible that major sources may choose not to reclassify because the cost
savings may not be a sufficient incentive to do so, or for other reasons.
Additional limitations and uncertainties include the following:
The EPA reviewed some but not all operating permits for major sources in all source
categories. This could lead to overestimation of the number of facilities in these
source categories. This overestimate is in the range of 5 to 10 percent of the estimated
number of facilities in each of these source categories.
The accuracy of the emissions values used in this analysis will vary. The source of the
data, the method to estimate the emissions, incomplete or missing data, the accuracy
of assumptions, and other factors will influence emission estimates, which in turn will
influence the number of facilities below the MST thresholds.
The EPA considered emission estimates that are annual totals for certain years and
that do not account for year-to-year variations. We found that the potential variation
in our emissions estimates will be minimal in comparison to other uncertainties in
these estimates that are discussed in the emissions memo. Therefore, the estimate of
the number of facilities below the MST thresholds is based on a single year's
emission estimate for each facility, whereas a facility's decision to reclassify could be
based on expected emissions for several years in the future.
In addition to the uncertainty in the emission and facility estimates, there is
uncertainty in the burden costs used to estimate the regulatory relief from this rule.
These uncertainties also affect the economic impact analysis conducted. The
economic impact analysis compares the avoided burden cost estimates with average
industry revenues to gauge the impact of the final MM2A rule for affected sources.
The estimated compliance costs after facilities obtain area source status were based
on the average estimated compliance costs for a relatively small number of area
source rules. Each major source rule does not have a corresponding area source rule,
so the average area source rule cost may not be representative of the actual
compliance cost for all source categories.
¦ We were not able to estimate the reduction in costs to sources, and any reduction in
revenues to states, from sources not having to incur Title V fees that are payable to
states, due to reclassification.
¦ We used average industry revenue and average establishment revenue estimates by
entity size to estimate avoided cost-to-sales ratios. The actual impacts to individual
entities potentially affected by this policy change may differ from industry averages.
The average entity costs used to compute the sales test vary across sources but are the
same across establishment size categories. As a result, the sales test may overstate the
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avoided cost-to-receipt ratio for establishments owned by small businesses, all other
factors being equal.
¦ Using the 2012 Economic Census, we collected and organized data on number of
establishments, employment, and receipts for affected sources represented by NAICS
codes. However, because of confidentiality issues, some data values were not
available or reported with a range of values. In addition, some NAICS codes were not
valid 2012 NAICS codes, and either no data were reported for them in the 2012
Economic Census, or limited data were reported and not broken down by
employment size categories. These data limitations are described in detail in
Table 7-1 in Section 7 and prevent us from reporting avoided cost-to-sales ratios for
every employment size category for some NAICS codes.
The underlying establishment and receipts data are a limiting factor because if either
of these measures is not reported for a certain category, we cannot calculate the
average receipts per establishment, which is needed for the avoided cost-to-sales ratio
calculation. However, for some cases avoided cost-to-sales ratios are not reported
because we determined in our analysis that zero facilities would opt to reclassify;
therefore, there are no facilities to calculate the average cost per entity.
This RIA estimates administrative burden reduction and some economic impact as
measured by avoided cost-to-sales ratios. The overall analysis of costs and cost savings does not
measure impacts related to control equipment changes (e.g., decrease in control device operating
and maintenance costs due to reduced device use) and does not provide quantitative estimates of
changes in emissions and benefits.
1.7 Organization of this Report
The remainder of this report supports and details the methodology and the results of this
illustrative RIA.
Section 2 presents a discussion of the regulatory baseline, analysis scenarios, and
affected entities.
Section 3 describes the administrative cost savings of the final rule including those
for the two alternative scenarios.
Section 4 describes the impacts on emissions from the final rule and potential control
cost impacts for sources affected in the analysis of alternative scenario 2.
Section 5 describes the benefits/disbenefits of the final rule.
Section 6 describes the economic impact methodology and the estimated economic
impacts of the final rule.
Section 7 describes limitations and uncertainties of the analyses in the RIA.
Section 8 lists the references for the analyses included in this RIA.
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SECTION 2.
BASELINE DESCRIPTION, REGULATORY SCENARIOS, AND
AFFECTED ENTITIES
The OIAI policy did not allow a major source to become an area source if its PTE was
over the major source threshold as of the source's first compliance date. With the final MM2A
rule, sources that were once classified as major sources can reclassify to area source status at any
time by taking limits on its PTE HAP below the MST. To determine which facilities could
reclassify to area source status, the EPA used the 2017 NEI whole facility HAP emissions along
with source category risk assessment modeling files to identify facilities with actual emissions
below 75 percent of the MST. This primary scenario of 7.5 tpy for one HAP or 18.75 tpy for all
HAPs is the primary scenario in this analysis to calculate the economic impacts of the final
MM2A rule on various industry sectors. Two alternative scenarios, alternative scenario 1 and
alternative scenario 2, are also included in this analysis. An explanation of the uncertainties
associated with this methodology is discussed in Section 7 of this report. The basic steps used to
estimate affected sources and permitting actions under the primary and alternative scenarios are
described in Sections 2.1, 2.2, and 2.3.
2.1 Basic Steps for the Analysis Under the Primary Scenario
1) Identify source categories. The EPA selected 114 source categories subject to major
source NESHAP requirements to be included in the MM2A cost analysis. At proposal, the EPA
identified 13 categories with RTR data where the MM2A policy change is not expected to have
an impact. The scope of EPA's analysis was thus reduced to a total of 101 source categories.
Seventy-four categories in this group were assessed by the EPA using data from the RTR
modeling files. In addition, 27 source categories were analyzed using an extrapolated approach
{i.e., using the cost information for the 74 source categories to estimate impacts for 24 of the 27
source categories). The RICE category was separately assessed but not included in the analysis.
Three ICI Boilers and Process Heaters source categories were separately assessed. A detailed
description of how the EPA identified and assessed affected source categories is provided in the
MM2A Database Memorandum.
The selected sources evaluated in this analysis can be grouped in the following sectors:
¦ Energy {e.g., Crude Petroleum & Natural Gas Extraction)
Industrial {e.g., Petrochemical Manufacturing and Automobile Manufacturing)
¦ Waste Treatment {e.g., Hazardous Waste Treatment & Disposal)
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Commercial (e.g., General Warehousing & Storage)
Agriculture (e.g., Postharvest Crop Activities [except Cotton Ginning])
¦ Utilities (e.g., Hydroelectric Power Generation)
¦ Educational Services (e.g., Colleges, Universities, and Professional Schools)
The 13 source categories with RTR data that would not be affected by the final MM2A
rule are as follows:
1. Decorative Chromium Electroplating (NAICS 332813, Industrial Sector)
2. Hard Chromium Electroplating (NAICS 332813, Industrial Sector)
3. Integrated Iron & Steel (NAICS 331110, Heavy Industry)
4. Iron & Steel Foundries (NAICS 331511, Heavy Industry)
5. Municipal Solid Waste Landfills (NAICS 562212, Waste Treatment Sector)
6. Other Chromium Electroplating (NAICS 332813, Industrial Sector)
7. Portland Cement (NAICS 327310, Industrial Sector)
8. Secondary Aluminum (NAICS 331314, Heavy Industry)
9.. Secondary Lead (NAICS 331492, Industrial Sector)
10.. Stationary Combustion Turbines (NAICS 486210, Energy Sector)
11. Taconite Iron Ore Processing (NAICS 212210, Heavy Industry)
12. Vegetable Oil (NAICS 311224, Heavy Industry)13
13. Wool Fiberglass (NAICS 327993, Industrial Sector)
2) Identify facilities for the primary scenario. The EPA used source category RTR
modeling files and 2017 NEI whole facility emissions to identify facilities with actual emissions
below 75 percent of the MST that could potentially qualify as area source facilities for the
primary scenario. Actual emissions for each source category were obtained from the 2017 NEI.
Table 2-1 identifies facilities affected by the final MM2A rule under the primary scenario. The
calculation of number of facilities in each sector and source category is based on the sources in
our illustrative analysis that may experience regulatory relief listed by sector in Appendix A-l.
13 For the Vegetable Oil category, it was determined from our emissions analysis that there are two facilities that are
eligible and thus could choose to reclassify, but are likely not to reclassify due to specific conditions at the
facilities (expansion project, biorefinery). Therefore, their emissions are not likely to change as a result of the
final rule.
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Our illustrative analysis is cognizant that these major sources may voluntarily decide to
reclassify, or not.
Table 2-1. Facilities with Actual Emissions below 75 Percent of the MST under the
PRIMARY SCENARIO
Number of Facilities with Actual Emissions below 75% of the MST
Agriculture
0
Commercial
64
Educational Services
9
Energy
163
Industrial
2,150
Utilities
151
Waste Treatment
30
Grand Total
2,567
Note: Some facilities in the Industrial category may actually be in the Public Administration (NAICS 922140,
927110, and 928110) and Unclassified (NAICS 999999) code categories.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. MM2A Database Memorandum,
Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of
Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. MM2A Cost Analysis Memorandum, Compliance
cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section
112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD. August 2020.
The NEI contains the EPA's most comprehensive estimates of annual HAP emissions.
The EPA's Air Toxics Program identifies 187 HAP (excepting the recently added 1-
bromopropane). Some examples of these are benzene, formaldehyde, and acetaldehyde. The
NEI's HAP emission estimates allow the EPA to determine if there is any progress being made
in the reduction of HAP as described in the Clean Air Act Amendments of 1990. The 2017 NEI
obtains data from the state, local, and tribal (S/L/T) air agencies, as well as the development of
NESHAP, and creates a national emissions database with this information.
The Air Emissions Reporting Rule (AERR) requires state agencies to report all sources of
emissions, except fires and biogenic sources. States must report criteria air pollutant emissions,
and there is a system in place for the voluntary submission of HAP emissions. The 2017 NEI
uses the AERR-based inventory. The emission thresholds for reporting to the AERR are PTE
thresholds versus actual emission thresholds. However, the reported emissions are actual
emissions.
3) Estimate Deregulatory Cost Savings. The EPA calculated a per-facility labor burden
using supporting statements issued with Information Collection Requests (ICRs) that accompany
each regulatory action authorizing the government to collect data and information required by
rules. Supporting statement costs are the monitoring, recordkeeping, and reporting costs that an
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emitting unit incurs yearly as a result of being classified as a HAP major source and subject to a
major source NESHAP. This per-facility labor burden multiplied by the number of facilities
below 75 percent of the MST provides the estimated cost savings for these facilities becoming
area sources for the primary scenario.
4) Obtain average one-time permitting costs. The EPA estimated the one-time permitting
costs to facilities of $4,089 per facility and the one-time state agency burden of $2,198 per
facility, based on inputs from the minor NSR and Administrative Amendment permitting
processes. Both of these costs are in 2017 dollars. These one-time permitting costs to obtain area
source permits were multiplied by the number of facilities below the primary scenario to estimate
total permitting costs.
5) Obtain area source burden estimates. Where available, the EPA obtained area source
burden estimates for facilities in each category subject to area source NESHAP. If the burden
estimate data were not available, the EPA used the default weighted average of $1,787 per year
per facility. The ERG MM2A Cost Analysis Memorandum explains how this default value was
estimated. These area source burden estimates per facility were multiplied by the number of
facilities included in the primary scenario to obtain total area source burden.
2.2 Basic Steps Under Alternative Scenario 1
The EPA used source category RTR modeling files and 2017 NEI whole facility
emissions to identify facilities with actual emissions below 50 percent of the MST that could
potentially qualify as area source facilities for alternative scenario 1. The per facility labor
burden multiplied by the number of facilities below 50 percent of the MST provided the
estimated deregulatory cost savings for the facilities becoming area sources for the alternative
scenario 1. The one-time permitting costs were multiplied by the number of facilities included in
alternative scenario 1 to estimate total permitting costs. The per facility area source burden
estimates were multiplied by the number of facilities in alternative scenario 1 to obtain total area
source burden. Table 2-2 identifies facilities affected by the final MM2A rule under the
alternative scenario 1. The calculation of the number of facilities in each sector is based on the
sources in our illustrative analysis that may experience regulatory relief listed by sector and
source category in Appendix A-2. The uncertainties discussed for the primary scenario also
apply to this analytical scenario.
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Table 2-2. Facilities with Actual Emissions Below 50 Percent of the MST under
ALTERNATIVE SCENARIO 1
Number of Facilities with Emissions Below 50% of the MST under
ALTERNATIVE SCENARIO 1
Agriculture 0
Commercial 59
Educational Services 8
Energy 134
Industrial 1,754
Utilities 129
Waste Treatment 21
Grand Total 2,105
Note: Some facilities in the Industrial category may actually be in the Public Administration (NAICS 922140,
927110, and 928110) and Unclassified (NAICS 999999) code categories.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum,
Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of
Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum,
Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources
Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
2.3 Basic Steps Under Alternative Scenario 2
The EPA used source category RTR modeling files and 2017 NEI whole facility
emissions to identify facilities with actual emissions below 125 percent of the MST and that
could potentially qualify as area source facilities for alternative scenario 2. The per-facility labor
burden multiplied by the number of facilities below 125 percent of the MST provided the cost
savings for the facilities becoming area sources for the alternative scenario 2. The one-time
permitting costs were multiplied by the number of facilities included in alternative scenario 2 to
estimate total permitting costs. The area source burden estimates were multiplied by the number
of facilities included in alternative scenario 2 to obtain total area source burden. Table 2-3
identifies facilities affected by the final MM2A rule under the alternative scenario 2. The
calculation of the number of facilities in each sector is based on the sources in our illustrative
analysis that may experience regulatory relief listed by sector and source category in Appendix
A-3. The uncertainties discussed for the primary scenario also apply to this analytical scenario.
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Table 2-3. Facilities with Actual Emissions Below 125 Percent of the MST under
ALTERNATIVE SCENARIO 2
Number of Facilities with Emissions Below 125% of the MST
under ALTERNATIVE SCENARIO 2
Agriculture 0
Commercial 72
Educational Services 11
Energy 193
Industrial 2,648
Utilities 151
Waste Treatment 34
Grand Total 3,109
Note: Some facilities in the Industrial category may actually be in the Public Administration (NAICS 922140,
927110, and 928110) and Unclassified (NAICS 999999) code categories.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum,
Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of
Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum,
Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources
Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
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SECTION 3.
REGULATORY RELIEF OR AVOIDED BURDEN COSTS
This chapter discusses the regulatory relief to sources that may potentially reclassify as a
result of the removal of OIAI. This regulatory relief is estimated in the form of avoided costs or
cost savings. Sections 3.1 and 3.2 explain the potential avoided costs to affected sources from
this policy change.
If a source voluntarily chooses to reclassify to area source status, upon reclassification
they will no longer be subject to applicable major source NESHAP and will no longer have the
major source NESHAP compliance costs. The savings for a reclassified source from no longer
having to comply with a major source NESHAP relates to monitoring, recordkeeping, and
reporting requirements for such sources. However, a reclassified source may incur area source
NESHAP compliance costs if the facility is subject to an applicable area source NESHAP. Costs
associated with an area source rule may include different emissions control requirements, along
with monitoring, recordkeeping, and reporting requirements. Facilities will also incur costs to
obtain limits on the facility's potential to emit (PTE) and modify the facility's operating permit
to remove major source NESHAP provisions and add newly applicable area source NESHAP
provisions. To modify an operating permit under this action, owners or operators will be required
to collect data and demonstrate that they qualify for consideration of status change from major or
area source status. They will prepare an application and submit the request to the permitting
authority and respond to any inquiries regarding the permit modification request. Overall, it is
expected that the sum of costs and cost savings of actions taken to reclassify from major source
to area source status in the long run will be a net annual cost savings.
It is difficult, if not impossible to predict whether any facility will choose to reclassify in
response to MM2A rulemaking. The decision made by each facility will depend on facility-
specific factors and factors that are also likely to be specific to a given source category.
For the cost savings analysis presented below, we estimate the costs associated with the
number of facilities with actual HAP emissions below each analytical threshold as mentioned in
the previous RIA chapter. These facility counts are likely to represent the maximum number of
facilities that could seek to reclassify at each of these analytical thresholds, and not the actual
number that would reclassify. Most facilities that reclassify would do so only if they were able to
maintain a reasonable compliance margin between actual emissions and their limitations on the
potential to emit HAP emissions below the MST still provide margin that would allow for a
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reasonable amount of operating flexibility to allow for increased production or throughput when
needed.
3.1 Year 1 Avoided Costs for Sources Affected by the Final MM2A Rule
Table 3-1 shows the costs avoided by affected sources in year 1 of the final MM2A rule
under the primary scenario. It provides the number of facilities within a NAICS code that are
subject to major source NESHAP requirements standards under section 112 of the CAA. These
facilities are considered major sources. With the final MM2A rule, a facility that is a major
source can reclassify to area source status by taking enforceable limits on its PTE HAP
emissions. The table also shows the number of major source facilities with actual emissions
under 75 percent of the MST. Once a facility achieves area source status, there will be avoided
costs; however, within the first year, there will be one-time permitting costs to the facility and
the permitting agency. Each major source facility that could potentially become an area source
facility will have to apply for and obtain an area source permit, and the state agency will need to
review and issue the permit. Hence, there will be permitting costs for both of these entities.
As mentioned previously in this RIA, the permitting cost to a facility is a one-time
facility permitting burden estimate of $4,089 (2017 dollars) per facility, and there is a one-time
permitting authority agency burden of $2,198 (2017 dollars) per facility. These one-time
permitting costs are multiplied by the number of facilities under the analytical threshold to obtain
total permitting costs to the state agency and to the facilities obtaining area source status.
For the categories with completed RTR modeling files, the annual estimated cost savings
per source category are calculated based on the average supporting statement costs (i.e.,
monitoring, recordkeeping and reporting costs) per facility from the ICR supporting statement
associated with the major source NESHAP. These cost savings are multiplied by the number of
facilities under the analytical threshold to obtain the projected cost savings per source category.
The annual estimated cost of area source requirements for a source category is calculated
based on the estimated area source rule burden for that source category multiplied by the number
of facilities under the analytical threshold.
The estimated net cost savings for year 1 for the categories with RTR modeling files are
calculated by adding together the total permit modification costs to the state agency and the total
permit modification costs to the facilities within each identified NAICS code. The EPA assumed
that not all of the potential reclassifications from major source to area source will occur in the
first year after the rule is issued and that all the potential reclassifications are evenly distributed
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(that is, 25 percent of potential reclassifications are estimated to occur each year) over 4 years.
So, the estimated net cost savings for year 1 shown in Table 3-1 are the year 1 (2021) portion (25
percent) of estimated net cost savings.
For the categories that were assessed using an extrapolated approach, the EPA used 3-
digitNAICS codes to match the extrapolated category to the directly assessed source categories
with RTR data. Then, the EPA calculated the sum of estimated cost savings in year 1 of the
source categories that were matched to the extrapolated category. Next, the EPA determined the
average cost savings for year 1 for the matched source categories and used these to determine the
cost savings for the extrapolated category in year 1. The MM2A Cost Analysis Memorandum
describes how these categories were assessed in year 1 in greater detail. RICE was not included
in the cost analysis because the compliance requirements for RICE at major and area sources are
similar.
The avoided costs in year 1, excluding the permitting cost to the state agency of
reviewing and issuing area source permits, are also displayed in Table 3-1. For the categories
with completed RTR modeling files, this calculation is the sum of the area source permitting cost
to the facilities with actual emissions below the analytical thresholds. Again, based on the EPA
assumptions about potential reclassifications, the avoided costs in year 1, excluding the
permitting cost to the state agency shown in Table 3-1, are the year 1 (2021) portion (25 percent)
of these costs. The average avoided cost per entity is the average net estimated cost savings in
year 1, excluding the permitting costs to the state agency, for the facilities that could obtain area
source status.
Table 3-2 shows the costs avoided by potentially affected sources in year 1 of the final
MM2A rule under the alternative scenario 1. Table 3-3 shows the costs avoided by potentially
affected sources in year 1 of the final MM2A rule under the alternative scenario 2. We note that
the cost for facilities potentially affected under the alternative scenario 2 include those that have
HAP emissions of between 75 percent to 125 percent, and this cost accounts for the 542
additional sources that potentially could reclassify under this scenario as compared to the
primary scenario. Since these costs do not account for costs from control technology installation
and operation that may be incurred by these sources as they reduce emissions part of a potential
reclassification, the overall cost savings may be lower than shown here.
35
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Agriculture
Postharvest Crop Activities (except
Cotton Ginning)
115114
1
0
-
-
-
-
-
Energy
Crude Petroleum and Natural Gas
Extraction
211111
120
48
196,272
105,504
(67,128) 18,768
75,446
(49,067)
(1,022)
Energy
Natural Gas Liquid Extraction
211112
26
11
44,979
24,178
-
17,290
(11,244)
(1,022)
Industrial
Iron Ore Mining
212210
11
0
-
-
-
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
-
-
-
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
-
-
-
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
-
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
-
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
-
-
-
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
6
0
-
-
-
-
-
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
-
-
-
-
-
Energy
Support Activities for Oil and Gas
Operations
213112
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Hydroelectric Power Generation
221111
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Fossil Fuel Electric Power Generation
221112
334
100
408,900
219,800
-
157,180
(102,222)
(1,022)
Utilities
Biomass Electric Power Generation
221117
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Utilities
Other Electric Power Generation
221118
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Other Electric Power GenerationA
221119
8
6
24,534
13,188
-
9,431
(6,133)
(1,022)
Utilities
Electric Power Distribution
221122
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Natural Gas Distribution
221210
13
9
36,801
19,782
-
14,146
(9,200)
(1,022)
Utilities
Water Supply and Irrigation Systems
221310
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Utilities
Sewage Treatment Facilities
221320
17
12
49,068
26,376
(46) 47
18,862
(12,267)
(1,022)
Utilities
Steam and Air-Conditioning Supply
221330
22
15
61,335
32,970
-
23,577
(15,333)
(1,022)
Industrial
Other Animal Food Manufacturing
311119
1
0
-
-
-
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
-
-
-
Industrial
Soybean ProcessingA
311222
16
0
-
-
-
-
-
Industrial
Other Oilseed ProcessingA
311223
5
0
-
-
-
-
-
Industrial
Soybean and Other Oilseed Processing
311224
116
2
8,178
4,396
(18,537) 894
3,144
(2,044)
(1,022)
Industrial
Fats and Oils Refining and Blending
311225
2
0
-
-
-
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
-
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
-
-
-
Industrial
Frozen Fruit, Juice, and Vegetable
Manufacturing
311411
2
0
-
-
-
-
-
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
-
-
-
Industrial
Specialty Canning
311422
2
0
-
-
-
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
-
-
-
Industrial
Dry, Condensed, and Evaporated Dairy
Product Manufacturing
311514
3
0
-
-
-
-
-
Industrial
Rendering and Meat Byproduct
Processing
311613
1
0
-
-
-
-
-
Industrial
Commercial Bakeries
311812
2
0
-
-
-
-
-
Industrial
Other Snack Food Manufacturing
311919
1
0
-
-
-
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
-
-
-
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1
0
-
-
-
-
-
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
-
-
-
Industrial
All Other Miscellaneous Food
Manufacturing
311999
6
0
-
-
-
-
-
Industrial
Breweries
312120
3
1
4,089
2,198
-
1,572
(1,022)
Industrial
Distilleries
312140
1
0
-
-
-
-
-
(1,022)
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
4,089
2,198
-
1,572
(1,022)
Industrial
Thread MillsA
313113
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Mills
313210
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Narrow Fabric MillsA
313221
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Textile and Fabric Finishing Mills
313310
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Fabric Coating Mills
313320
50
28
114,492
61,544
(81,842) 4,484
44,010
(28,622)
(1,022)
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
-
-
(1,022)
Industrial
Leather and Hide Tanning and Finishing 316110
6
4
16,356
8,792
(1,594) 374
6,287
(4,089)
Industrial
Sawmills
321113
61
11
44,979
24,178
-
17,290
(11,244)
(1,022)
Industrial
Wood Preservation
321114
3
0
-
-
-
-
-
(1,022)
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
3
0
-
-
-
-
-
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
29
6
24,534
13,188
-
9,431
(6,133)
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
6
1
4,089
2,198
1,572
(1,022)
(1,022)
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), S
agency)
(2017)
Industrial
Reconstituted Wood Product
Manufacturing
321219
315
61
249,429
134,078
(302,819)
16,776
95,880
(62,356)
(1,022)
Industrial
Wood Window and Door Manufacturing
321911
4
0
-
-
-
-
-
-
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
4
0
-
-
-
-
-
-
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
3
0
-
-
-
-
-
-
Industrial
Pulp Mills
322110
18
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Paper (except Newsprint) Mills
322121
282
11
44,979
24,178
-
-
17,290
(11,244)
(1,022)
Industrial
Newsprint Mills
322122
7
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Paperboard Mills
322130
36
7
28,623
15,386
-
-
11,003
(7,156)
(1,022)
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
174
55
224,895
120,890
(23,451)
10,276
86,449
(56,222)
(1,022)
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
17
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Coated and Laminated Paper
ManufacturingA
322222
12
2
8,178
4,396
~
3,144
(2,044)
(1,022)
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
-
-
-
-
-
-
Industrial
All Other Converted Paper Product
Manufacturing
322299
1
0
-
-
-
-
-
-
Industrial
Commercial Lithographic PrintingA
323110
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Commercial Printing (except Screen and
Books)
323111
188
110
449,790
241,780
(476,884)
18,870
172,898
$(112,445)
(1,022)
Industrial
Books Printing
323117
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Petroleum Refineries
324110
430
77
314,853
169,246
(767,790)
14,010
121,678
(79,683)
(1,035)
Industrial
Asphalt Shingle and Coating Materials
Manufacturing
324122
3
0
-
-
-
-
-
-
Industrial
All Other Petroleum and Coal Products
Manufacturing
324199
4
0
-
-
-
-
-
-
Industrial
Petrochemical Manufacturing
325110
597
218
891,402
479,164
(103,327)
45,682
342,497
(222,744)
(1,022)
Industrial
Industrial Gas Manufacturing
325120
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1
0
-
-
-
-
-
-
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
3
1
4,089
2,198
¦
~
1,572
(1,022)
(1,022)
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), S
agency)
(2017)
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
2
0
-
-
-
-
-
-
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
10
3
12,267
6,594
~
4,715
(3,067)
(1,022)
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Carbon Black ManufacturingA
325182
21
7
28,623
15,386
-
-
11,060
(7,193)
(1,028)
Industrial
All Other Basic Inorganic Chemical
ManufacturingA
325188
93
3
12,267
6,594
"
-
4,715
(3,067)
(1,022)
Industrial
Cyclic Crude and Intermediate
ManufacturingA
325192
1
0
-
-
-
-
-
-
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Cyclic Crude, Intermediate, and Gum
and Wood Chemical Manufacturing
325194
2
0
-
-
"
-
-
-
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
77
23
94,047
50,554
(132,560)
2,186
36,151
(23,511)
(1,022)
Industrial
Plastics Material and Resin
Manufacturing
325211
857
254
$ 1,038,606
558,292
$(1,911,759)
108,947
399,644
$(259,910)
(1,023)
Industrial
Synthetic Rubber Manufacturing
325212
22
2
8,178
4,396
(225)
547
3,144
(2,044)
(1,022)
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1
0
-
-
-
-
-
-
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
6
24,534
13,188
-
-
9,431
(6,133)
(1,022)
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
22
5
20,445
10,990
(73,333)
2,186
7,859
(5,111)
(1,022)
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Pharmaceutical Preparation
Manufacturing
325412
36
9
36,801
19,782
(4,133)
3,279
14,146
(9,200)
(1,022)
Industrial
Biological Product (except Diagnostic)
Manufacturing
325414
1
0
-
-
-
-
-
-
Industrial
Paint and Coating Manufacturing
325510
48
19
77,691
41,762
(610,761)
9,291
29,864
(19,422)
(1,022)
Industrial
Adhesive Manufacturing
325520
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Surface Active Agent Manufacturing
325613
2
0
-
-
-
-
-
-
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
-
-
Industrial
Custom Compounding of Purchased
325991
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Resins
Industrial
Photographic Film, Paper, Plate, and
325992
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical
325998
10
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Product and Preparation Manufacturing
Industrial
Plastics Packaging Film and Sheet
326112
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
(including Laminated) Manufacturing
Industrial
Unlaminated Plastics Film and Sheet
326113
16
7
28,623
15,386
-
11,003
(7,156)
(1,022)
(except Packaging) Manufacturing
Industrial
Unlaminated Plastics Profile Shape
326121
12
0
-
-
-
-
-
Manufacturing
Industrial
Plastics Pipe and Pipe Fitting
326122
1
0
-
-
-
-
-
Manufacturing
Industrial
Laminated Plastics Plate, Sheet (except
326130
7
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Packaging), and Shape Manufacturing
Industrial
Polystyrene Foam Product
326140
1
0
-
-
-
-
-
Manufacturing
Industrial
Urethane and Other Foam Product
326150
19
13
53,157
28,574
(21,096) 1,410
20,908
(13,598)
(1,046)
(except Polystyrene) Manufacturing
Industrial
Plastics Plumbing Fixture
326191
2
0
-
-
-
-
-
Manufacturing
Industrial
All Other Plastics Product
326199
148
64
261,696
140,672
(570,759) 9,902
100,595
(65,422)
(1,022)
Manufacturing
Industrial
Tire Manufacturing (except Retreading)
326211
39
19
77,691
41,762
-
29,344
(19,084)
(1,004)
Industrial
Rubber and Plastics Hoses and Belting
326220
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Rubber Product Manufacturing for
326291
2
0
-
-
-
-
-
Mechanical Use
Industrial
All Other Rubber Product
326299
14
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Manufacturing
Industrial
Pottery, Ceramics, and Plumbing
327110
4
1
4,089
2,198
-
2,032
(1,321)
(1,321)
Fixture Manufacturing
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), S
agency)
(2017)
Industrial
Clay Building Material and Refractories
Manufacturing
327120
76
47
192,183
103,306
(197,152)
21,002
73,874
(48,045)
(1,022)
Industrial
Clay Refractory ManufacturingA
327124
8
3
12,267
6,594
-
-
5,418
(3,524)
(1,175)
Industrial
Flat Glass Manufacturing
327211
2
0
-
-
-
-
-
-
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
17
7
28,623
15,386
(13,643)
1,787
11,003
(7,156)
(1,022)
Industrial
Cement Manufacturing
327310
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Lime Manufacturing
327410
38
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Gypsum Product Manufacturing
327420
1
0
-
-
-
-
-
-
Industrial
Abrasive Product Manufacturing
327910
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Mineral Wool Manufacturing
327993
13
4
16,356
8,792
(18,426)
894
6,287
(4,089)
(1,022)
Industrial
All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
327999
2
0
-
-
-
-
-
-
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
73
39
159,471
85,722
(345,850)
16,534
61,300
(39,867)
(1,022)
Industrial
Iron and Steel MillsA
331111
50
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Electrometallurgical Ferroalloy Product
ManufacturingA
331112
1
0
-
-
-
-
-
-
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331210
5
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Primary Aluminum ProductionA
331312
2
0
-
-
-
-
-
-
Industrial
Alumina Refining and Primary
Aluminum Production
331313
16
2
8,178
4,396
(127,250)
447
3,144
(2,044)
(1,022)
Industrial
Secondary Smelting and Alloying of
Aluminum
331314
56
7
28,623
15,386
(12,824)
8,344
11,003
(7,156)
(1,022)
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Aluminum Extruded Product
ManufacturingA
331316
1
0
-
-
-
-
-
-
Industrial
Other Aluminum Rolling, Drawing, and
Extruding
331318
2
0
-
-
-
-
-
-
Industrial
Nonferrous Metal (except Aluminum)
Smelting and Refining
331410
1
0
-
-
-
-
-
-
Industrial
Primary Smelting and Refining of
CopperA
331411
0
0
-
-
-
-
-
-
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Number of
Estimated
Portion
Facilities
Facilities
Estimated
Net Costs
(Excluding
Average
Category
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), S
agency)
(2017)
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper and
Aluminum)A
331419
2
0
Industrial
Copper Rolling, Drawing, Extruding,
and Alloying
331420
3
0
-
-
-
-
-
-
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1
0
-
-
-
-
-
-
Industrial
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and
Extruding
331491
3
1
4,089
2,198
1,572
(1,022)
(1,022)
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal (except
Copper and Aluminum)
331492
2
0
Industrial
Iron Foundries
331511
59
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Industrial
Steel Foundries (except Investment)
331513
2
0
-
-
-
-
-
-
Industrial
Aluminum Die-Casting FoundriesA
331521
1
0
-
-
-
-
-
-
Industrial
Aluminum Foundries (except Die-
Casting)
331524
2
0
-
-
-
-
-
-
Industrial
Nonferrous Forging
332112
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332119
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Fabricated Structural Metal
Manufacturing
332312
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Window and Door Manufacturing
332321
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Industrial
Sheet Metal Work Manufacturing
332322
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Can Manufacturing
332431
14
9
36,801
19,782
(30,882)
560
14,146
(9,200)
(1,022)
Industrial
Other Metal Container Manufacturing
332439
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Heat Treating
332811
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), S
agency)
(2017)
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
433
280
$ 1,144,920
615,440
$(3,295,295)
50,070
440,103
$(286,223)
(1,022)
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Small Arms Ammunition
Manufacturing
332992
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
3
2
8,178
4,396
¦
3,144
(2,044)
(1,022)
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Farm Machinery and Equipment
Manufacturing
333111
8
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Lawn and Garden Tractor and Home
Lawn and Garden Equipment
Manufacturing
333112
1
0
Industrial
Construction Machinery Manufacturing
333120
64
28
114,492
61,544
(87,249)
11,618
44,010
(28,622)
(1,022)
Industrial
Mining Machinery and Equipment
Manufacturing
333131
2
0
-
-
-
-
-
-
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
1
0
-
-
-
-
-
-
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1
0
-
-
-
-
-
-
Industrial
Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing
333415
1
0
Industrial
Machine Tool (Metal Cutting Types)
ManufacturingA
333512
1
0
-
-
-
-
-
-
Industrial
Machine Tool (Metal Forming Types)
ManufacturingA
333513
1
0
-
-
-
-
-
-
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1
0
-
-
-
-
-
-
Industrial
Other Engine Equipment Manufacturing
333618
5
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Industrial
Overhead Traveling Crane, Hoist, and
333923
1
0
-
-
-
-
-
Monorail System Manufacturing
Industrial
Welding and Soldering Equipment
333992
2
0
-
-
-
-
-
Manufacturing
Industrial
Radio and Television Broadcasting and
334220
1
0
-
-
-
-
-
Wireless Communications Equipment
Manufacturing
Industrial
Electron Tube ManufacturingA
334411
1
0
-
-
-
-
-
Industrial
Bare Printed Circuit Board
334412
1
0
-
-
-
-
-
Manufacturing
Industrial
Semiconductor and Related Device
334413
23
13
53,157
28,574
-
20,270
(13,182)
(1,014)
Manufacturing
Industrial
Automatic Environmental Control
334512
1
0
-
-
-
-
-
Manufacturing for Residential,
Commercial, and Appliance Use
Industrial
Blank Magnetic and Optical Recording
334613
0
0
-
-
-
-
-
Media Manufacturing
Industrial
Electric Lamp Bulb and Part
335110
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Household Laundry Equipment
335224
13
9
36,801
19,782
(72,435) 1,308
14,146
(9,200)
(1,022)
Manufacturing
Industrial
Other Major Household Appliance
335228
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Power, Distribution, and Specialty
335311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Transformer Manufacturing
Industrial
Motor and Generator Manufacturing
335312
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Storage Battery Manufacturing
335911
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Current-Carrying Wiring Device
335931
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Noncurrent-Carrying Wiring Device
335932
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Carbon and Graphite Product
335991
6
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Automobile Manufacturing
336111
66
18
73,602
39,564
(54,439) 934
28,292
(18,400)
(1,022)
Industrial
Light Truck and Utility Vehicle
336112
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Industrial
Motor Vehicle Body Manufacturing
336211
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Industrial
Truck Trailer Manufacturing
336212
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Motor Vehicle Steering and Suspension
Components (except Spring)
Manufacturing
336330
2
2
8,178
4,396
3,144
(2,044)
(1,022)
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1
1
4,089
2,198
~
1,572
(1,022)
(1,022)
Industrial
Motor Vehicle Transmission and Power
Train Parts Manufacturing
336350
2
2
8,178
4,396
~
3,144
(2,044)
(1,022)
Industrial
Motor Vehicle Seating and Interior Trim
Manufacturing
336360
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Motor Vehicle Metal Stamping
336370
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
13
7
28,623
15,386
-
11,003
(7,156)
(1,022)
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
2
2
8,178
4,396
~
3,144
(2,044)
(1,022)
Industrial
Aircraft Manufacturing
336411
125
102
417,078
224,196
(2,630,648) 17,188
160,323
(104,267)
(1,022)
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
10
6
24,534
13,188
~
9,431
(6,133)
(1,022)
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit
Parts Manufacturing
336415
1
1
4,089
2,198
1,572
(1,022)
(1,022)
Industrial
Railroad Rolling Stock Manufacturing
336510
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Ship Building and Repairing
336611
92
55
224,895
120,890
(671,875) 9,341
86,449
(56,222)
(1,022)
Industrial
Boat Building
336612
96
26
106,314
57,148
(98,842) 10,725
40,867
(26,578)
(1,022)
Industrial
Military Armored Vehicle, Tank, and
Tank Component Manufacturing
336992
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings) Requirement
Portion), S
agency)
(2017)
Industrial
Wood Kitchen Cabinet and Countertop
337110
347
233
952,737
512,134
(507,664) 84,624
366,229
$(238,178)
(1,022)
Manufacturing
Industrial
Upholstered Household Furniture
337121
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Nonupholstered Wood Household
337122
14
9
36,801
19,782
-
14,146
(9,200)
(1,022)
Furniture Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Wood Office Furniture Manufacturing
337211
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Industrial
Office Furniture (except Wood)
337214
19
12
49,068
26,376
(69,072) 1,868
18,862
(12,267)
(1,022)
Manufacturing
Industrial
Showcase, Partition, Shelving, and
337215
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Surgical and Medical Instrument
339112
0
-
-
-
-
-
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
1
0
-
-
-
-
-
Manufacturing
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
-
-
-
-
-
Industrial
Sporting and Athletic Goods
339920
1
0
-
-
-
-
-
Manufacturing
Industrial
Office Supplies (except Paper)
339940
1
0
-
-
-
-
-
Manufacturing
Industrial
Gasket, Packing, and Sealing Device
339991
2
0
-
-
-
-
-
Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Commercial
Grain and Field Bean Merchant
424510
1
0
-
-
-
-
-
Wholesalers
Commercial
Petroleum Bulk Stations and Terminals
424710
7
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Commercial
Scheduled Passenger Air Transportation
481111
2
0
-
-
-
-
-
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
-
-
Energy
Pipeline Transportation of Crude Oil
486110
1
0
-
-
-
-
-
Energy
Pipeline Transportation of Natural Gas
486210
257
103
421,167
226,394
(45,900) 14,746
161,895
$(105,289)
(1,022)
Energy
Pipeline Transportation of Refined
486910
1
0
-
-
-
-
-
Petroleum Products
(continued)
-------
Table 3-1. Year 1 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion ($/yr)
Cost ($)
Avoided
Costs
Year 1
Number of
Estimated
Portion
Number of
Facilities
Estimated
Net Costs
(Excluding
Average
Facilities
Under the
Estimated
Cost of Area
(Savings)
permitting
Avoided
Subject to
Primary
State
Costs
Source
(Year 1
cost to state
Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Facility
Agency
(Savings)
Requirement
Portion), $
agency)
(2017)
Commercial
Support Activities for Rail
Transportation
488210
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
-
-
-
Commercial
General Warehousing and Storage
493110
180
57
233,073
125,286
(459,363)
105,839
89,592
(58,267)
(1,022)
Commercial
Other Warehousing and Storage
493190
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Commercial
Lessors of Nonresidential Buildings
(except Miniwarehouses)
531120
1
0
-
-
-
-
-
-
Commercial
Testing Laboratories
541380
2
0
-
-
-
-
-
-
Commercial
Research and Development in the
Physical, Engineering and Life Sciences
(except Nanotechnology and
Biotechnology)^
541715
2
0
Commercial
All Other Support Services
561990
1
0
-
-
-
-
-
-
Waste Treatment
Hazardous Waste Treatment and
Disposal
562211
41
23
94,047
50,554
(503,197)
9,384
36,151
(23,511)
(1,022)
Waste Treatment
Solid Waste Landfill
562212
6
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Waste Treatment
Solid Waste Combustors and
Incinerators
562213
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Waste Treatment
Remediation Services
562910
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Educational
Colleges, Universities, and Professional
611310
23
9
36,801
19,782
-
-
14,146
(9,200)
(1,022)
Services
Schools
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
-
-
-
Commercial
Industrial Launderers
812332
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Notes:
One-time facility permitting burden is $4,089 per facility (2017 dollars).
One-time state agency burden is $2,196 per facility (2017 dollars).
Six source categories in the assessed source categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subject to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories and they were excluded from the table.
For Table 3-1, the two columns—Estimated Costs Savings and Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without completed RTR modeling files, we
only have the extrapolated cost or savings for facilities in year 1 and not a breakdown of those cost savings by area source requirement costs or supporting statement cost savings. We have included all
of the cost information that is currently available.
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities estimated to obtain area source status.
-------
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and therefore, we have not included it in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1 -1 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2ACost
Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
NAICS 2012 and NAICS 2007 ("https://www.census.gov/eos/www/naics/downloadables/downloadables.html)
OO
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Agriculture
Postharvest Crop Activities
(except Cotton Ginning)
115114
1
0
-
-
-
-
-
-
Energy
Crude Petroleum and Natural
Gas Extraction
211111
120
40
163,560
87,920
(55,940)
15,640
62,872
(40,889)
(1,022)
Energy
Natural Gas Liquid Extraction
211112
26
9
36,801
19,782
-
-
14,146
(9,200)
(1,022)
Industrial
Iron Ore Mining
212210
11
0
-
-
-
-
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
-
-
-
-
Industrial
Copper Ore and Nickel Ore
Mining
212234
1
0
-
-
-
-
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
-
-
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
-
-
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
-
-
-
-
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
6
0
-
-
-
-
-
-
Industrial
All Other Nonmetallic Mineral
Mining
212399
1
0
-
-
-
-
-
-
Energy
Support Activities for Oil and
Gas Operations
213112
3
1
4,089
2,198
¦
1,572
(1,022)
(1,022)
Utilities
Hydroelectric Power Generation
221111
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Utilities
Fossil Fuel Electric Power
Generation
221112
334
85
347,565
186,830
-
133,603
(86,889)
(1,022)
Utilities
Biomass Electric Power
Generation
221117
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Utilities
Other Electric Power Generation
221118
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Utilities
Other Electric Power
GenerationA
221119
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Utilities
Electric Power Distribution
221122
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Utilities
Natural Gas Distribution
221210
13
7
28,623
15,386
-
-
11,003
(7,156)
(1,022)
Utilities
Water Supply and Irrigation
Systems
221310
2
2
8,178
4,396
"
-
3,144
(2,044)
(1,022)
Utilities
Sewage Treatment Facilities
221320
17
10
40,890
21,980
(40)
41
15,718
(10,222)
(1,022)
Utilities
Steam and Air-Conditioning
Supply
221330
22
13
53,157
28,574
"
-
20,433
(13,289)
(1,022)
Industrial
Other Animal Food
Manufacturing
311119
1
0
-
-
-
-
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
-
-
-
-
Industrial
Soybean ProcessingA
311222
16
0
-
-
-
-
-
-
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Other Oilseed ProcessingA
311223
5
0
-
-
-
-
-
Industrial
Soybean and Other Oilseed
Processing
311224
116
1
4,089
2,198
(9,269) 447
1,572
(1,022)
(1,022)
Industrial
Fats and Oils Refining and
Blending
311225
2
0
-
-
-
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
-
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
-
-
-
Industrial
Frozen Fruit, Juice, and
Vegetable Manufacturing
311411
2
0
-
-
-
-
-
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
-
-
-
Industrial
Specialty Canning
311422
2
0
-
-
-
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
-
-
-
Industrial
Dry, Condensed, and Evaporated
Dairy Product Manufacturing
311514
3
0
-
-
-
-
-
Industrial
Rendering and Meat Byproduct
Processing
311613
1
0
-
-
-
-
-
Industrial
Commercial Bakeries
311812
2
0
-
-
-
-
-
Industrial
Other Snack Food
Manufacturing
311919
1
0
-
-
-
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
-
-
-
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1
0
-
-
-
-
-
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
-
-
-
Industrial
All Other Miscellaneous Food
Manufacturing
311999
6
0
-
-
-
-
-
Industrial
Breweries
312120
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Distilleries
312140
1
0
-
-
-
-
-
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Thread MillsA
313113
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Mills
313210
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Narrow Fabric MillsA
313221
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Textile and Fabric Finishing
Mills
313310
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Finishing
MillsA
313311
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Fabric Coating Mills
313320
50
26
106,314
57,148
(75,022) 4,110
40,867
(26,578)
(1,022)
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
-
-
-
Industrial
Leather and Hide Tanning and
316110
6
4
16,356
8,792
(1,594)
374
6,287
(4,089)
(1,022)
Finishing
Industrial
Sawmills
321113
61
8
32,712
17,584
-
-
12,574
(8,178)
(1,022)
Industrial
Wood Preservation
321114
3
0
-
-
-
-
-
-
Industrial
Hardwood Veneer and Plywood
321211
3
0
-
-
-
-
-
-
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
29
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Manufacturing
Industrial
Engineered Wood Member
321213
6
0
-
-
-
-
-
-
(except Truss) Manufacturing
Industrial
Reconstituted Wood Product
321219
315
44
179,916
96,712
(222,915)
10,667
69,159
(44,978)
(1,022)
Manufacturing
Industrial
Wood Window and Door
321911
4
0
-
-
-
-
-
-
Manufacturing
Industrial
Cut Stock, Resawing Lumber,
321912
4
0
-
-
-
-
-
-
and Planing
Industrial
All Other Miscellaneous Wood
321999
3
0
-
-
-
-
-
-
Product Manufacturing
Industrial
Pulp Mills
322110
18
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Paper (except Newsprint) Mills
322121
282
9
36,801
19,782
-
-
14,146
(9,200)
(1,022)
Industrial
Newsprint Mills
322122
7
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Paperboard Mills
322130
36
6
24,534
13,188
-
-
9,431
(6,133)
(1,022)
Industrial
Corrugated and Solid Fiber Box
322211
174
46
188,094
101,108
(19,613)
8,594
72,303
(47,022)
(1,022)
Manufacturing
Industrial
Paper Bag and Coated and
322220
17
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Treated Paper Manufacturing
Industrial
Coated and Laminated Paper
322222
12
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
ManufacturingA
Industrial
Sanitary Paper Product
322291
2
0
-
-
-
-
-
-
Manufacturing
(Industrial
All Other Converted Paper
322299
1
0
-
-
-
-
-
-
Product Manufacturing
Industrial
Commercial Lithographic
323110
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
PrintingA
Industrial
Commercial Printing (except
323111
188
99
404,811
217,602
(429,668)
17,001
155,608
$(101,200)
(1,022)
Screen and Books)
Industrial
Books Printing
323117
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities y
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Petroleum Refineries
324110
430
65
265,785
142,870
(644,421)
11,824
102,837
(67,430)
(1,037)
Industrial
Asphalt Shingle and Coating
324122
3
0
-
-
-
-
-
-
Materials Manufacturing
Industrial
All Other Petroleum and Coal
324199
4
0
-
-
-
-
-
-
Products Manufacturing
Industrial
Petrochemical Manufacturing
325110
597
190
776,910
417,620
(85,516)
42,355
298,123
$(193,885)
(1,020)
Industrial
Industrial Gas Manufacturing
325120
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Synthetic Dye and Pigment
325130
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Inorganic Dye and Pigment
325131
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Manufacturing"
Industrial
Synthetic Organic Dye and
325132
2
0
-
-
-
-
-
-
Pigment Manufacturing"
Industrial
Other Basic Inorganic Chemical
325180
10
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Alkalies and Chlorine
325181
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Manufacturing"
Industrial
Carbon Black Manufacturing"
325182
21
6
24,534
13,188
-
-
9,598
(6,242)
(1,040)
Industrial
All Other Basic Inorganic
325188
93
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Chemical Manufacturing"
Industrial
Cyclic Crude and Intermediate
325192
1
0
-
-
-
-
-
-
Manufacturing"
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Cyclic Crude, Intermediate, and
325194
2
0
-
-
-
-
-
-
Gum and Wood Chemical
Manufacturing
Industrial
All Other Basic Organic
325199
77
20
81,780
43,960
(132,560)
2,186
31,436
(20,444)
(1,022)
Chemical Manufacturing
Industrial
Plastics Material and Resin
325211
857
197
805,533
433,006
$(1,551,769)
84,119
309,686
$(201,405)
(1,022)
Manufacturing
Industrial
Synthetic Rubber Manufacturing
325212
22
2
8,178
4,396
(225)
547
3,144
(2,044)
(1,022)
Industrial
Artificial and Synthetic Fibers
325220
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
and Filaments Manufacturing
Industrial
Cellulosic Organic Fiber
325221
1
0
-
-
-
-
-
-
Manufacturing"
Industrial
Noncellulosic Organic Fiber
325222
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Manufacturing"
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Nitrogenous Fertilizer
325311
16
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Phosphatic Fertilizer
325312
30
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Pesticide and Other Agricultural
325320
22
3
12,267
6,594
(36,667)
1,093
4,715
(3,067)
(1,022)
Chemical Manufacturing
Industrial
Medicinal and Botanical
325411
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Pharmaceutical Preparation
325412
36
4
16,356
8,792
(1,378)
1,093
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Biological Product (except
325414
1
0
-
-
-
-
-
-
Diagnostic) Manufacturing
Industrial
Paint and Coating Manufacturing
325510
48
18
73,602
39,564
(574,834)
8,745
28,292
(18,400)
(1,022)
Industrial
Adhesive Manufacturing
325520
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Surface Active Agent
325613
2
0
-
-
-
-
-
-
Manufacturing
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
-
-
-
Industrial
Custom Compounding of
325991
5
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Purchased Resins
Industrial
Photographic Film, Paper, Plate,
325992
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
and Chemical Manufacturing
Industrial
All Other Miscellaneous
325998
10
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Chemical Product and
Preparation Manufacturing
Industrial
Plastics Packaging Film and
326112
5
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Sheet (including Laminated)
Manufacturing
Industrial
Unlaminated Plastics Film and
326113
16
6
24,534
13,188
-
-
9,431
(6,133)
(1,022)
Sheet (except Packaging)
Manufacturing
Industrial
Unlaminated Plastics Profile
326121
12
0
-
-
-
-
-
-
Shape Manufacturing
Industrial
Plastics Pipe and Pipe Fitting
326122
1
0
-
-
-
-
-
-
Manufacturing
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Laminated Plastics Plate, Sheet
326130
7
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
(except Packaging), and Shape
Manufacturing
Industrial
Polystyrene Foam Product
326140
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Urethane and Other Foam
326150
19
13
53,157
28,574
(21,096)
1,410
20,060
(13,046)
(1,004)
Product (except Polystyrene)
Manufacturing
Industrial
Plastics Plumbing Fixture
326191
2
0
-
-
-
-
-
-
Manufacturing
Industrial
All Other Plastics Product
326199
148
46
188,094
101,108
(409,224)
7,099
72,303
(47,022)
(1,022)
Manufacturing
Industrial
Tire Manufacturing (except
326211
39
14
57,246
30,772
-
-
22,638
(14,723)
(1,052)
Retreading)
Industrial
Rubber and Plastics Hoses and
326220
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Belting Manufacturing
Industrial
Rubber Product Manufacturing
326291
2
0
-
-
-
-
-
-
for Mechanical Use
Industrial
All Other Rubber Product
326299
14
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Manufacturing
Industrial
Pottery, Ceramics, and Plumbing
327110
4
1
4,089
2,198
-
-
1,687
(1,097)
(1,097)
Fixture Manufacturing
Industrial
Clay Building Material and
327120
76
41
167,649
90,118
(171,983)
18,321
64,444
(41,911)
(1,022)
Refractories Manufacturing
Industrial
Clay Refractory ManufacturingA
327124
8
3
12,267
6,594
-
-
4,498
(2,925)
(975)
Industrial
Flat Glass Manufacturing
327211
2
0
-
-
-
-
-
-
Industrial
Other Pressed and Blown Glass
327212
17
5
20,445
10,990
(6,821)
894
7,859
(5,111)
(1,022)
and Glassware Manufacturing
Industrial
Cement Manufacturing
327310
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Lime Manufacturing
327410
38
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Gypsum Product Manufacturing
327420
1
0
-
-
-
-
-
-
Industrial
Abrasive Product Manufacturing
327910
4
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Mineral Wool Manufacturing
327993
13
3
12,267
6,594
(9,213)
447
4,715
(3,067)
(1,022)
Industrial
All Other Miscellaneous
327999
2
0
-
-
-
-
-
-
Nonmetallic Mineral Product
Manufacturing
Industrial
Iron and Steel Mills and
331110
73
37
151,293
81,326
(327,155)
15,640
58,157
(37,822)
(1,022)
Ferroalloy Manufacturing
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Iron and Steel MillsA
331111
50
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
1
0
-
-
-
-
-
-
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
331210
5
1
4,089
2,198
1,572
(1,022)
(1,022)
Industrial
Rolled Steel Shape
Manufacturing
331221
6
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Primary Aluminum ProductionA
331312
2
0
-
-
-
-
-
-
Industrial
Alumina Refining and Primary
Aluminum Production
331313
16
0
-
-
-
-
-
-
Industrial
Secondary Smelting and
Alloying of Aluminum
331314
56
5
20,445
10,990
(10,687)
6,953
7,859
(5,111)
(1,022)
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
6
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Aluminum Extruded Product
ManufacturingA
331316
1
0
-
-
-
-
-
-
Industrial
Other Aluminum Rolling,
Drawing, and Extruding
331318
2
0
-
-
-
-
-
-
Industrial
Nonferrous Metal (except
Aluminum) Smelting and
Refining
331410
1
0
Industrial
Primary Smelting and Refining
of CopperA
331411
0
0
-
-
-
-
-
-
Industrial
Primary Smelting and Refining
of Nonferrous Metal (except
Copper and Aluminum)A
331419
2
0
Industrial
Copper Rolling, Drawing,
Extruding, and Alloying
331420
3
0
-
-
-
-
-
-
Industrial
Copper Wire (except
Mechanical) DrawingA
331422
1
0
-
-
-
-
-
-
Industrial
Nonferrous Metal (except
Copper and Aluminum) Rolling,
Drawing, and Extruding
331491
3
0
Industrial
Secondary Smelting, Refining,
and Alloying of Nonferrous
Metal (except Copper and
Aluminum)
331492
2
0
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Iron Foundries
331511
59
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Industrial
Steel Foundries (except
331513
2
0
-
-
-
-
-
Investment)
Industrial
Aluminum Die-Casting
331521
1
0
-
-
-
-
-
Foundries'^
Industrial
Aluminum Foundries (except
331524
2
0
-
-
-
-
-
Die-Casting)
Industrial
Nonferrous Forging
332112
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Metal Crown, Closure, and Other
332119
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Metal Stamping (except
Automotive)
Industrial
Hand and Edge Tool
332212
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
ManufacturingA
Industrial
Prefabricated Metal Building and
332311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Component Manufacturing
Industrial
Fabricated Structural Metal
332312
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Metal Window and Door
332321
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Sheet Metal Work
332322
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Metal Can Manufacturing
332431
14
8
32,712
17,584
(20,588) 374
12,574
(8,178)
(1,022)
Industrial
Other Metal Container
332439
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Bolt, Nut, Screw, Rivet, and
332722
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Washer Manufacturing
Industrial
Metal Heat Treating
332811
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Metal Coating, Engraving
332812
433
241
985,449
529,718
$(2,837,352) 43,157
378,803
$(246,356)
(1,022)
(except Jewelry and Silverware),
and Allied Services to
Manufacturers
Industrial
Electroplating, Plating,
332813
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Polishing, Anodizing, and
Coloring
Industrial
Other Fabricated Metal
332990
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Small Arms Ammunition
332992
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Ammunition (except Small
Arms) Manufacturing
332993
3
2
8,178 4,396
-
-
3,144
(2,044)
(1,022)
Industrial
All Other Miscellaneous
Fabricated Metal Product
Manufacturing
332999
3
2
8,178 4,396
3,144
(2,044)
(1,022)
Industrial
Farm Machinery and Equipment
Manufacturing
333111
8
3
12,267 6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden
Equipment Manufacturing
333112
1
0
Industrial
Construction Machinery
Manufacturing
333120
64
27
110,403 59,346
(83,894)
11,171
42,439
(27,600)
(1,022)
Industrial
Mining Machinery and
Equipment Manufacturing
333131
2
0
-
-
-
-
-
Industrial
Printing Machinery and
Equipment ManufacturingA
333293
1
0
-
-
-
-
-
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1
0
-
-
-
-
-
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1
0
Industrial
Machine Tool (Metal Cutting
Types) ManufacturingA
333512
1
0
-
-
-
-
-
Industrial
Machine Tool (Metal Forming
Types) ManufacturingA
333513
1
0
-
-
-
-
-
Industrial
Turbine and Turbine Generator
Set Units Manufacturing
333611
1
0
-
-
-
-
-
Industrial
Other Engine Equipment
Manufacturing
333618
5
2
8,178 4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Overhead Traveling Crane,
Hoist, and Monorail System
Manufacturing
333923
1
0
Industrial
Welding and Soldering
Equipment Manufacturing
333992
2
0
-
-
-
-
-
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Radio and Television
334220
1
0
-
-
-
-
-
Broadcasting and Wireless
Communications Equipment
Manufacturing
Industrial
Electron Tube Manufacturing"
334411
1
0
-
-
-
-
-
Industrial
Bare Printed Circuit Board
334412
1
0
-
-
-
-
-
Manufacturing
Industrial
Semiconductor and Related
334413
23
11
44,979
24,178
-
16,959
(11,029)
(1,003)
Device Manufacturing
Industrial
Automatic Environmental
334512
1
0
-
-
-
-
-
Control Manufacturing for
Residential, Commercial, and
Appliance Use
Industrial
Blank Magnetic and Optical
334613
0
0
-
-
-
-
-
Recording Media Manufacturing
Industrial
Electric Lamp Bulb and Part
335110
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Household Laundry Equipment
335224
13
8
32,712
17,584
(62,087) 1,121
12,574
(8,178)
(1,022)
Manufacturing
Industrial
Other Major Household
335228
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Appliance Manufacturing
Industrial
Power, Distribution, and
335311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Specialty Transformer
Manufacturing
Industrial
Motor and Generator
335312
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Storage Battery Manufacturing
335911
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Current-Carrying Wiring Device
335931
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Noncurrent-Carrying Wiring
335932
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Device Manufacturing
Industrial
Carbon and Graphite Product
335991
6
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Automobile Manufacturing
336111
66
10
40,890
21,980
(21,775) 374
15,718
(10,222)
(1,022)
Industrial
Light Truck and Utility Vehicle
336112
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Heavy Duty Truck
336120
8
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Motor Vehicle Body
Manufacturing
336211
8
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Truck Trailer Manufacturing
336212
1
0
-
-
-
-
-
Industrial
Motor Vehicle Gasoline Engine
and Engine Parts Manufacturing
336310
2
0
-
-
-
-
-
Industrial
Carburetor, Piston, Piston Ring,
and Valve ManufacturingA
336311
1
0
-
-
-
-
-
Industrial
Gasoline Engine and Engine
Parts ManufacturingA
336312
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
2
0
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1
0
-
-
-
-
-
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
2
0
-
-
-
-
-
Industrial
Motor Vehicle Seating and
Interior Trim Manufacturing
336360
1
0
-
-
-
-
-
Industrial
Motor Vehicle Metal Stamping
336370
1
0
-
-
-
-
-
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
13
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Industrial
All Other Motor Vehicle Parts
Manufacturing"
336399
2
0
-
-
-
-
-
Industrial
Aircraft Manufacturing
336411
125
89
363,921
195,622
$(2,373,302) 15,507
139,890
(90,978)
(1,022)
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
8
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Other Aircraft Parts and
Auxiliary Equipment
Manufacturing
336413
10
3
12,267
6,594
4,715
(3,067)
(1,022)
Industrial
Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts
Manufacturing
336415
1
0
Industrial
Railroad Rolling Stock
Manufacturing
336510
1
0
-
-
-
-
-
Industrial
Ship Building and Repairing
336611
92
18
73,602
39,564
(215,000) 2,989
28,292
(18,400)
(1,022)
Industrial
Boat Building
336612
96
16
65,424
35,168
(61,776) 6,703
25,149
(16,356)
(1,022)
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Military Armored Vehicle, Tank,
336992
2
0
-
-
-
-
-
-
and Tank Component
Manufacturing
Industrial
Wood Kitchen Cabinet and
337110
347
209
854,601
459,382
(455,537)
75,935
328,506
$(213,645)
(1,022)
Countertop Manufacturing
Industrial
Upholstered Household Furniture
337121
2
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Nonupholstered Wood
337122
14
8
32,712
17,584
-
-
12,574
(8,178)
(1,022)
Household Furniture
Manufacturing
Industrial
Institutional Furniture
337127
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Wood Office Furniture
337211
5
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Office Furniture (except Wood)
337214
19
11
44,979
24,178
(62,165)
1,681
17,290
(11,244)
(1,022)
Manufacturing
Industrial
Showcase, Partition, Shelving,
337215
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
and Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Surgical and Medical Instrument
339112
2
0
-
-
-
-
-
-
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Jewelry and Silverware
339910
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Sporting and Athletic Goods
339920
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Office Supplies (except Paper)
339940
1
0
-
-
-
-
-
-
Manufacturing
Industrial
Gasket, Packing, and Sealing
339991
2
0
-
-
-
-
-
-
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
All Other Miscellaneous
339999
5
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
1
0
-
-
-
-
-
-
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
7
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Terminals
(continued)
-------
Table 3-2. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
Facility
State Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Commercial
Scheduled Passenger Air
481111
2
0
-
-
-
-
-
-
Transportation
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
-
-
-
Energy
Pipeline Transportation of Crude
Oil
486110
1
0
-
-
-
-
-
-
Energy
Pipeline Transportation of
486210
257
84
343,476
184,632
(37,555)
12,065
132,031
(85,867)
(1,022)
Natural Gas
Energy
Pipeline Transportation of
486910
1
0
-
-
-
-
-
-
Refined Petroleum Products
Commercial
Support Activities for Rail
488210
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Transportation
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
-
-
-
Commercial
General Warehousing and
493110
180
53
216,717
116,494
(427,127)
98,411
83,305
(54,178)
(1,022)
Storage
Commercial
Other Warehousing and Storage
493190
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Commercial
Lessors of Nonresidential
531120
1
0
-
-
-
-
-
-
Buildings (except
Mini warehouses)
Commercial
Testing Laboratories
541380
2
0
-
-
-
-
-
-
Commercial
Research and Development in
541715
2
0
-
-
-
-
-
-
the Physical, Engineering and
Life Sciences (except
Nanotechnology and
Biotechnology)^
Commercial
All Other Support Services
561990
1
0
-
-
-
-
-
-
Waste
Hazardous Waste Treatment and
562211
41
18
73,602
39,564
(407,350)
7,597
28,292
(18,400)
(1,022)
Treatment
Disposal
Waste
Solid Waste Landfill
562212
6
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Treatment
Waste
Solid Waste Combustors and
562213
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Treatment
Incinerators
Waste
Remediation Services
562910
1
0
-
-
-
-
-
-
Treatment
Educational
Colleges, Universities, and
611310
23
8
32,712
17,584
-
-
12,574
(8,178)
(1,022)
Services
Professional Schools
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
-
-
-
Commercial
Industrial Launderers
812332
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
(continued)
-------
Notes:
One-time facility permitting burden is $4,089 per facility (2017 dollars).
One-time state agency burden is $2,198 per facility (2017 dollars).
Six source categories in the assessed source categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subject to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories and they were excluded from the table.
For Table 3-2, the two columns—Estimated Costs Savings and Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without completed RTR modeling files, we
only have the extrapolated cost or savings for facilities in year 1 and not a breakdown of those cost savings by area source requirement costs or supporting statement cost savings. We have included all
of the cost information that is currently available.
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities estimated to obtain area source status.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and therefore, we have not included it in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1 -2 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost
Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
On NAICS 2012 and NAICS 2007 ('https://www.census.gov/eos/www/naics/downloadables/downloadables.html')
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Agriculture
Postharvest Crop Activities
(except Cotton Ginning)
115114
1
0
-
-
-
-
-
Energy
Crude Petroleum and Natural Gas
Extraction
211111
120
57
233,073
125,286
(81,512) 22,790
89,592
(58,267)
(1,022)
Energy
Natural Gas Liquid Extraction
211112
26
12
49,068
26,376
-
18,862
(12,267)
(1,022)
Industrial
Iron Ore Mining
212210
11
0
-
-
-
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
-
-
-
Industrial
Copper Ore and Nickel Ore
Mining
212234
1
0
-
-
-
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
-
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
-
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
-
-
-
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
6
0
-
-
-
-
-
Industrial
All Other Nonmetallic Mineral
Mining
212399
1
0
-
-
-
-
-
Energy
Support Activities for Oil and Gas
Operations
213112
3
1
4,089
2,198
~
1,572
(1,022)
(1,022)
Utilities
Hydroelectric Power Generation
221111
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Fossil Fuel Electric Power
Generation
221112
334
100
408,900
219,800
-
157,180
$(102,222)
(1,022)
Utilities
Biomass Electric Power
Generation
221117
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Utilities
Other Electric Power Generation
221118
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Other Electric Power GenerationA
221119
8
6
24,534
13,188
-
9,431
(6,133)
(1,022)
Utilities
Electric Power Distribution
221122
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Utilities
Natural Gas Distribution
221210
13
9
36,801
19,782
-
14,146
(9,200)
(1,022)
Utilities
Water Supply and Irrigation
Systems
221310
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Utilities
Sewage Treatment Facilities
221320
17
12
49,068
26,376
(46) 47
18,862
(12,267)
(1,022)
Utilities
Steam and Air-Conditioning
Supply
221330
22
15
61,335
32,970
-
23,577
(15,333)
(1,022)
Industrial
Other Animal Food
Manufacturing
311119
1
0
-
-
-
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
-
-
-
Industrial
Soybean ProcessingA
311222
16
0
-
-
-
-
-
Industrial
Other Oilseed ProcessingA
311223
5
0
-
-
-
-
-
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Soybean and Other Oilseed
Processing
311224
116
2
8,178
4,396
(18,537) 894
3,144
(2,044)
(1,022)
Industrial
Fats and Oils Refining and
Blending
311225
2
0
-
-
-
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
-
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
-
-
-
Industrial
Frozen Fruit, Juice, and Vegetable
Manufacturing
311411
2
0
-
-
-
-
-
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
-
-
-
Industrial
Specialty Canning
311422
2
0
-
-
-
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
-
-
-
Industrial
Dry, Condensed, and Evaporated
Dairy Product Manufacturing
311514
3
0
-
-
-
-
-
Industrial
Rendering and Meat Byproduct
Processing
311613
1
0
-
-
-
-
-
Industrial
Commercial Bakeries
311812
2
0
-
-
-
-
-
Industrial
Other Snack Food Manufacturing
311919
1
0
-
-
-
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
-
-
-
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1
0
-
-
-
-
-
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
-
-
-
Industrial
All Other Miscellaneous Food
Manufacturing
311999
6
0
-
-
-
-
-
Industrial
Breweries
312120
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Distilleries
312140
1
0
-
-
-
-
-
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Thread MillsA
313113
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Mills
313210
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Narrow Fabric MillsA
313221
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Textile and Fabric Finishing Mills
313310
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Broadwoven Fabric Finishing
MillsA
313311
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Fabric Coating Mills
313320
50
32
130,848
70,336
(92,072) 5,044
50,298
(32,711)
(1,022)
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
-
-
Industrial
Leather and Hide Tanning and
Finishing
316110
6
5
20,445
10,990
(2,391) 560
7,859
(5,111)
(1,022)
Industrial
Sawmills
321113
61
25
102,225
54,950
-
39,295
(25,556)
(1,022)
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Wood Preservation
321114
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
29
11
44,979
24,178
17,290
(11,244)
(1,022)
Industrial
Engineered Wood Member
(except Truss) Manufacturing
321213
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Reconstituted Wood Product
Manufacturing
321219
315
126
515,214
276,948
(569,091) 42,434
198,047
$(128,800)
(1,022)
Industrial
Wood Window and Door
Manufacturing
321911
4
1
4,089
2,198
~
1,572
(1,022)
(1,022)
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Pulp Mills
322110
18
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Industrial
Paper (except Newsprint) Mills
322121
282
14
57,246
30,772
-
22,005
(14,311)
(1,022)
Industrial
Newsprint Mills
322122
7
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Paperboard Mills
322130
36
9
36,801
19,782
-
14,146
(9,200)
(1,022)
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
174
68
278,052
149,464
(28,994) 12,704
106,882
(69,511)
(1,022)
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
17
3
12,267
6,594
~
4,715
(3,067)
(1,022)
Industrial
Coated and Laminated Paper
ManufacturingA
322222
12
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Sanitary Paper Product
Manufacturing
322291
2
0
~
Industrial
All Other Converted Paper
Product Manufacturing
322299
1
0
-
-
-
-
-
Industrial
Commercial Lithographic
PrintingA
323110
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Commercial Printing (except
Screen and Books)
323111
188
121
494,769
265,958
(528,822) 20,925
190,188
$(123,689)
(1,022)
Industrial
Books Printing
323117
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Petroleum Refineries
324110
430
88
359,832
193,424
(860,316) 15,650
138,559
(90,662)
(1,030)
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
3
0
-
-
-
-
-
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
All Other Petroleum and Coal
324199
4
0
-
-
-
-
-
Products Manufacturing
Industrial
Petrochemical Manufacturing
325110
597
260
1,063,140
571,480
(106,490) 49,704
408,273
$(265,522)
(1,021)
Industrial
Industrial Gas Manufacturing
325120
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Synthetic Dye and Pigment
325130
1
0
-
-
-
-
-
Manufacturing
Industrial
Inorganic Dye and Pigment
325131
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
ManufacturingA
Industrial
Synthetic Organic Dye and
325132
2
0
-
-
-
-
-
Pigment ManufacturingA
Industrial
Other Basic Inorganic Chemical
325180
10
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Manufacturing
Industrial
Alkalies and Chlorine
325181
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
ManufacturingA
Industrial
Carbon Black Manufacturing"
325182
21
8
32,712
17,584
-
13,255
(8,620)
(1,078)
Industrial
All Other Basic Inorganic
325188
93
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Chemical Manufacturing"
Industrial
Cyclic Crude and Intermediate
325192
1
0
-
-
-
-
-
Manufacturing"
Industrial
Ethyl Alcohol Manufacturing
325193
7
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Industrial
Cyclic Crude, Intermediate, and
325194
2
0
-
-
-
-
-
Gum and Wood Chemical
Manufacturing
Industrial
All Other Basic Organic Chemical
325199
77
28
114,492
61,544
(165,700) 2,733
44,010
(28,622)
(1,022)
Manufacturing
Industrial
Plastics Material and Resin
325211
857
341
$1,394,349
749,518
(2,927,508) 147,682
535,367
$(348,178)
(1,021)
Manufacturing
Industrial
Synthetic Rubber Manufacturing
325212
22
2
8,178
4,396
(225) 547
3,144
(2,044)
(1,022)
Industrial
Artificial and Synthetic Fibers and
325220
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Filaments Manufacturing
Industrial
Cellulosic Organic Fiber
325221
1
0
-
-
-
-
-
Manufacturing"
Industrial
Noncellulosic Organic Fiber
325222
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing"
Industrial
Nitrogenous Fertilizer
325311
16
6
24,534
13,188
-
9,431
(6,133)
(1,022)
Manufacturing
Industrial
Phosphatic Fertilizer
325312
30
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Manufacturing
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Pesticide and Other Agricultural
325320
22
6
24,534
13,188
(91,667) 2,733
9,431
(6,133)
(1,022)
Chemical Manufacturing
Industrial
Medicinal and Botanical
325411
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Pharmaceutical Preparation
325412
36
11
44,979
24,178
(5,511) 4,372
17,290
(11,244)
(1,022)
Manufacturing
Industrial
Biological Product (except
325414
1
0
-
-
-
-
-
Diagnostic) Manufacturing
Industrial
Paint and Coating Manufacturing
325510
48
26
106,314
57,148
(862,250) 13,117
40,867
(26,578)
(1,022)
Industrial
Adhesive Manufacturing
325520
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Surface Active Agent
325613
2
0
-
-
-
-
-
Manufacturing
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
-
-
Industrial
Custom Compounding of
325991
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Purchased Resins
Industrial
Photographic Film, Paper, Plate,
325992
4
1
4,089
2,198
-
1,572
(1,022)
(1,022)
and Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical
325998
10
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Product and Preparation
Manufacturing
Industrial
Plastics Packaging Film and Sheet
326112
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
(including Laminated)
Manufacturing
Industrial
Unlaminated Plastics Film and
326113
16
8
32,712
17,584
-
12,574
(8,178)
(1,022)
Sheet (except Packaging)
Manufacturing
Industrial
Unlaminated Plastics Profile
326121
12
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Shape Manufacturing
Industrial
Plastics Pipe and Pipe Fitting
326122
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Laminated Plastics Plate, Sheet
326130
7
4
16,356
8,792
-
6,287
(4,089)
(1,022)
(except Packaging), and Shape
Manufacturing
Industrial
Polystyrene Foam Product
326140
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Urethane and Other Foam Product
(except Polystyrene)
Manufacturing
326150
19
16
65,424
35,168
(21,096)
1,410
24,843
(16,157)
(1,010)
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
2
2
8,178
4,396
¦
3,144
(2,044)
(1,022)
Industrial
All Other Plastics Product
Manufacturing
326199
148
81
331,209
178,038
(721,526)
12,517
127,316
(82,800)
(1,022)
Industrial
Tire Manufacturing (except
Retreading)
326211
39
23
94,047
50,554
~
35,812
(23,291)
(1,013)
Industrial
Rubber and Plastics Hoses and
Belting Manufacturing
326220
6
4
16,356
8,792
~
6,287
(4,089)
(1,022)
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
2
2
8,178
4,396
"
-
3,144
(2,044)
(1,022)
Industrial
All Other Rubber Product
Manufacturing
326299
14
6
24,534
13,188
"
-
9,431
(6,133)
(1,022)
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
4
3
12,267
6,594
~
3,949
(2,568)
(856)
Industrial
Clay Building Material and
Refractories Manufacturing
327120
76
57
233,073
125,286
(230,709)
24,577
89,592
(58,267)
(1,022)
Industrial
Clay Refractory ManufacturingA
327124
8
4
16,356
8,792
-
-
6,338
(4,122)
(1,031)
Industrial
Flat Glass Manufacturing
327211
2
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Other Pressed and Blown Glass
and Glassware Manufacturing
327212
17
11
44,979
24,178
(17,054)
2,234
17,290
(11,244)
(1,022)
Industrial
Cement Manufacturing
327310
6
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Industrial
Lime Manufacturing
327410
38
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Gypsum Product Manufacturing
327420
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Abrasive Product Manufacturing
327910
4
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Industrial
Mineral Wool Manufacturing
327993
13
6
24,534
13,188
(18,426)
894
9,431
(6,133)
(1,022)
Industrial
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
327999
2
2
8,178
4,396
3,144
(2,044)
(1,022)
Industrial
Iron and Steel Mills and
Ferroalloy Manufacturing
331110
73
44
179,916
96,712
(392,586)
18,768
69,159
(44,978)
(1,022)
Industrial
Iron and Steel MillsA
331111
50
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
1
0
-
-
-
-
-
-
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Iron and Steel Pipe and Tube
331210
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing from Purchased
Steel
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Industrial
Primary Aluminum ProductionA
331312
2
0
-
-
-
-
-
Industrial
Alumina Refining and Primary
331313
16
2
8,178
4,396
(127,250) 447
3,144
(2,044)
(1,022)
Aluminum Production
Industrial
Secondary Smelting and Alloying
331314
56
8
32,712
17,584
(14,962) 9,735
12,574
(8,178)
(1,022)
of Aluminum
Industrial
Aluminum Sheet, Plate, and Foil
331315
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Aluminum Extruded Product
331316
1
0
-
-
-
-
-
ManufacturingA
Industrial
Other Aluminum Rolling,
331318
2
0
-
-
-
-
-
Drawing, and Extruding
Industrial
Nonferrous Metal (except
331410
1
0
-
-
-
-
-
Aluminum) Smelting and Refining
Industrial
Primary Smelting and Refining of
331411
0
0
-
-
-
-
-
CopperA
Industrial
Primary Smelting and Refining of
331419
2
0
-
-
-
-
-
Nonferrous Metal (except Copper
and Aluminum)A
Industrial
Copper Rolling, Drawing,
331420
3
0
-
-
-
-
-
Extruding, and Alloying
Industrial
Copper Wire (except Mechanical)
331422
1
0
-
-
-
-
-
DrawingA
Industrial
Nonferrous Metal (except Copper
331491
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
and Aluminum) Rolling, Drawing,
and Extruding
Industrial
Secondary Smelting, Refining,
331492
2
0
-
-
-
-
-
and Alloying of Nonferrous Metal
(except Copper and Aluminum)
Industrial
Iron Foundries
331511
59
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Industrial
Steel Foundries (except
331513
2
0
-
-
-
-
-
Investment)
Industrial
Aluminum Die-Casting
331521
1
0
-
-
-
-
-
Foundries'^
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Industrial
Aluminum Foundries (except Die-
Casting)
331524
2
0
-
-
-
-
-
-
Industrial
Nonferrous Forging
332112
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
1
1
4,089
2,198
1,572
(1,022)
(1,022)
Industrial
Hand and Edge Tool
ManufacturingA
332212
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Fabricated Structural Metal
Manufacturing
332312
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Window and Door
Manufacturing
332321
5
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Industrial
Sheet Metal Work Manufacturing
332322
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Can Manufacturing
332431
14
11
44,979
24,178
(41,175)
747
17,290
(11,244)
(1,022)
Industrial
Other Metal Container
Manufacturing
332439
4
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Bolt, Nut, Screw, Rivet, and
Washer Manufacturing
332722
1
1
4,089
2,198
¦
-
1,572
(1,022)
(1,022)
Industrial
Metal Heat Treating
332811
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and
Allied Services to Manufacturers
332812
433
332
$1,357,548
729,736
$(3,917,226
)
59,224
521,837
(339,378)
(1,022)
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
3
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
Industrial
Other Fabricated Metal
Manufacturing
332990
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Industrial
Small Arms Ammunition
Manufacturing
332992
1
1
4,089
2,198
¦
-
1,572
(1,022)
(1,022)
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
3
3
12,267
6,594
¦
-
4,715
(3,067)
(1,022)
Industrial
All Other Miscellaneous
Fabricated Metal Product
Manufacturing
332999
3
3
12,267
6,594
4,715
(3,067)
(1,022)
Industrial
Farm Machinery and Equipment
Manufacturing
333111
8
3
12,267
6,594
-
-
4,715
(3,067)
(1,022)
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden
Equipment Manufacturing
333112
1
0
Industrial
Construction Machinery
Manufacturing
333120
64
30
122,670 65,940
(93,961) 12,512
47,154
(30,667)
(1,022)
Industrial
Mining Machinery and Equipment
Manufacturing
333131
2
0
-
-
-
-
Industrial
Printing Machinery and
Equipment Manufacturing"
333293
1
0
-
-
-
-
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1
0
-
-
-
-
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1
0
Industrial
Machine Tool (Metal Cutting
Types) Manufacturing"
333512
1
0
-
-
-
-
Industrial
Machine Tool (Metal Forming
Types) Manufacturing"
333513
1
0
-
-
-
-
Industrial
Turbine and Turbine Generator
Set Units Manufacturing
333611
1
0
-
-
-
-
Industrial
Other Engine Equipment
Manufacturing
333618
5
2
8,178 4,396
-
3,144
(2,044)
(1,022)
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1
0
Industrial
Welding and Soldering Equipment
Manufacturing
333992
2
0
-
-
-
-
Industrial
Radio and Television
Broadcasting and Wireless
Communications Equipment
Manufacturing
334220
1
0
Industrial
Electron Tube Manufacturing"
334411
1
0
-
-
-
-
Industrial
Bare Printed Circuit Board
Manufacturing
334412
1
0
-
-
-
-
Industrial
Semiconductor and Related
Device Manufacturing
334413
23
15
61,335 32,970
-
23,554
(15,318)
(1,021)
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Automatic Environmental Control
334512
1
0
-
-
-
-
-
Manufacturing for Residential,
Commercial, and Appliance Use
Industrial
Blank Magnetic and Optical
334613
0
0
-
-
-
-
-
Recording Media Manufacturing
Industrial
Electric Lamp Bulb and Part
335110
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Household Laundry Equipment
335224
13
9
36,801
19,782
(72,435) 1,308
14,146
(9,200)
(1,022)
Manufacturing
Industrial
Other Major Household Appliance
335228
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Power, Distribution, and Specialty
335311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Transformer Manufacturing
Industrial
Motor and Generator
335312
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Storage Battery Manufacturing
335911
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Current-Carrying Wiring Device
335931
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Noncurrent-Carrying Wiring
335932
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Device Manufacturing
Industrial
Carbon and Graphite Product
335991
6
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Automobile Manufacturing
336111
66
28
114,492
61,544
(141,540) 2,429
44,010
(28,622)
(1,022)
Industrial
Light Truck and Utility Vehicle
336112
5
4
16,356
8,792
-
6,287
(4,089)
(1,022)
Manufacturing
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Industrial
Motor Vehicle Body
336211
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Manufacturing
Industrial
Truck Trailer Manufacturing
336212
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Motor Vehicle Gasoline Engine
336310
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
and Engine Parts Manufacturing
Industrial
Carburetor, Piston, Piston Ring,
336311
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
and Valve ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
3
2
8,178
4,396
-
3,144
(2,044)
(1,022)
ManufacturingA
Industrial
Motor Vehicle Steering and
336330
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Suspension Components (except
Spring) Manufacturing
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Motor Vehicle Brake System
336340
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Motor Vehicle Transmission and
336350
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Power Train Parts Manufacturing
Industrial
Motor Vehicle Seating and
336360
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Interior Trim Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Other Motor Vehicle Parts
336390
13
7
28,623
15,386
-
11,003
(7,156)
(1,022)
Manufacturing
Industrial
All Other Motor Vehicle Parts
336399
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
ManufacturingA
Industrial
Aircraft Manufacturing
336411
125
107
437,523
235,186
(2,716,430) 17,749
168,182
$(109,378)
(1,022)
Industrial
Aircraft Engine and Engine Parts
336412
8
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Manufacturing
Industrial
Other Aircraft Parts and Auxiliary
336413
10
6
24,534
13,188
-
9,431
(6,133)
(1,022)
Equipment Manufacturing
Industrial
Guided Missile and Space Vehicle
336415
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Propulsion Unit and Propulsion
Unit Parts Manufacturing
Industrial
Railroad Rolling Stock
336510
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Ship Building and Repairing
336611
92
67
273,963
147,266
(833,125) 11,583
105,310
(68,489)
(1,022)
Industrial
Boat Building
336612
96
35
143,115
76,930
(135,908) 14,746
55,013
(35,778)
(1,022)
Industrial
Military Armored Vehicle, Tank,
336992
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
and Tank Component
Manufacturing
Industrial
Wood Kitchen Cabinet and
337110
347
263
$1,075,407
578,074
(571,121) 95,202
413,383
$(268,845)
(1,022)
Countertop Manufacturing
Industrial
Upholstered Household Furniture
337121
2
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Industrial
Nonupholstered Wood Household
337122
14
11
44,979
24,178
-
17,290
(11,244)
(1,022)
Furniture Manufacturing
Industrial
Institutional Furniture
337127
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Manufacturing
Industrial
Wood Office Furniture
337211
5
5
20,445
10,990
-
7,859
(5,111)
(1,022)
Manufacturing
Industrial
Office Furniture (except Wood)
337214
19
17
69,513
37,366
(96,701) 2,616
26,721
(17,378)
(1,022)
Manufacturing
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion (S/yr)
Cost (S)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings) Requirement
(year 1)
agency)
(2017)
Industrial
Showcase, Partition, Shelving, and
337215
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
Surgical and Medical Instrument
339112
2
0
-
-
-
-
-
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
1
0
-
-
-
-
-
Manufacturing
Industrial
Jewelry and Silverware
339910
1
0
-
-
-
-
-
Manufacturing
Industrial
Sporting and Athletic Goods
339920
1
0
-
-
-
-
-
Manufacturing
Industrial
Office Supplies (except Paper)
339940
1
0
-
-
-
-
-
Manufacturing
Industrial
Gasket, Packing, and Sealing
339991
2
0
-
-
-
-
-
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Industrial
All Other Miscellaneous
339999
5
2
8,178
4,396
-
3,144
(2,044)
(1,022)
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
1
0
-
-
-
-
-
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
7
3
12,267
6,594
-
4,715
(3,067)
(1,022)
Terminals
Commercial
Scheduled Passenger Air
481111
2
0
-
-
-
-
-
Transportation
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
-
-
Energy
Pipeline Transportation of Crude
Oil
486110
1
0
-
-
-
-
-
Energy
Pipeline Transportation of Natural
Gas
486210
257
123
502,947
270,354
(55,636) 17,874
193,331
$(125,734)
(1,022)
Energy
Pipeline Transportation of Refined
486910
1
0
-
-
-
-
-
Petroleum Products
Commercial
Support Activities for Rail
488210
3
1
4,089
2,198
-
1,572
(1,022)
(1,022)
Transportation
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
-
-
Commercial
General Warehousing and Storage
493110
180
65
265,785
142,870
(523,835) 120,693
102,167
(66,445)
(1,022)
Commercial
Other Warehousing and Storage
493190
6
2
8,178
4,396
-
3,144
(2,044)
(1,022)
(continued)
-------
Table 3-3. Year 1 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Permitting Cost (2017)
Year 1 Portion ($/yr)
Cost ($)
Avoided
Costs in
Number of
Year 1
Average
Number of
Facilities
Estimated
Estimated
(excluding
Avoided
Facilities
Under
Estimated
Cost of Area
Net Costs
permitting
Cost/
Subject to
Alternative
State
Costs
Source
(Savings)
cost to state
Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario 2
Facility
Agency
(Savings)
Requirement
(year 1)
agency)
(2017)
Commercial
Lessors of Nonresidential
Buildings (except
Mini warehouses)
531120
1
0
Commercial
Testing Laboratories
541380
2
0
-
-
-
-
-
-
Commercial
Research and Development in the
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
541715
2
0
Commercial
All Other Support Services
561990
1
0
-
-
-
-
-
-
Waste
Hazardous Waste Treatment and
562211
41
27
110,403
59,346
(599,044)
11,171
42,439
(27,600)
(1,022)
Treatment
Disposal
Waste
Solid Waste Landfill
562212
6
4
16,356
8,792
-
-
6,287
(4,089)
(1,022)
Treatment
Waste
Solid Waste Combustors and
562213
3
2
8,178
4,396
-
-
3,144
(2,044)
(1,022)
Treatment
Incinerators
Waste
Remediation Services
562910
1
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Treatment
Educational
Colleges, Universities, and
611310
23
11
44,979
24,178
-
-
17,290
(11,244)
(1,022)
Services
Professional Schools
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
-
-
-
Commercial
Industrial Launderers
812332
3
1
4,089
2,198
-
-
1,572
(1,022)
(1,022)
Notes:
One-time facility permitting burden is $4,089 per facility (2017 dollars).
One-time state agency burden is $2,198 per facility (2017 dollars).
Six source categories in the assessed source categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subj ect to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories and they were excluded from the table.
For Table 3-3, two columns—Estimated Costs Savings and Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without completed RTR modeling files, we
only have the extrapolated cost or savings for facilities in year 1 and not a breakdown of those cost savings by area source requirement costs or supporting statement cost savings. We have included all
of the cost information that is currently available.
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities estimated to obtain area source status.
For the not directly assessed Source Category "Pulp & Paper (non-combust) MACT" (NAICS 322121), one facility is extrapolated to obtain area source status. However, in the estimation of
Extrapolated Costs (Savings), "No facilities are expected to be area sources." We assume the same when calculating the number of facilities expected to obtain area source status for this not directly
assessed category.
-------
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and therefore, we have not included it in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1 -3 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census, NAICS 2012, NAICS 2007; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries
Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research
Group. August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of
the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
NAICS 2012 and NAICS 2007 ("https://www.census.gov/eos/www/naics/downloadables/downloadables.html').
<1
On
-------
3.2 Year 5 Avoided Cost for Sources Affected by the Final MM2A Rule
As mentioned earlier in this RIA, the EPA assumed that all potential reclassifications will
occur over a 5-year time period. Tables 3-4 through 3-6 below show the avoided costs in year 5
(2025 and beyond), once all potential reclassifications have happened for each source. With the
final MM2A rule, in year 5, there will be no area source permitting costs to the facility or the
state agency. This is because it is assumed that the permitting changes are all completed in year 1
for each reclassification and there is no permitting action in year 5. Therefore, the only costs to
the affected facilities in year 5 are the area source burden requirements. For the categories with
completed RTR modeling files, the annual estimated cost savings in year 5 are the annual
monitoring, recordkeeping, and reporting (as included in supporting statements) costs for the
facilities expected to obtain area source status. The avoided costs in year 5 are the sum of the
estimated cost of area source requirements and the annual estimated cost savings from not having
to comply with the major source NESHAP rule.
For the categories without completed RTR modeling files, the EPA used 3-digit NAICS
codes to match each extrapolated category to the directly assessed source categories with RTR
data. Then, the EPA calculated the sum of estimated cost savings in year 5 of the source
categories that were matched to the extrapolated category. Next, the EPA determined the average
cost savings for year 5 for the matched source categories and used these to determine the cost
savings for the extrapolated category in year 5. The MM2A Cost Analysis Memorandum
describes how these categories were assessed in greater detail. RICE was not included in the cost
analysis because the compliance requirement for major and area sources are the same for this
category.
Table 3-4 shows the avoided costs in year 5 for the categories with completed RTR
modeling files and the extrapolated categories under the primary scenario. The average avoided
cost per entity is calculated using the average estimated net cost savings in year 5 for the
facilities affected. Table 3-5 shows the avoided costs in year 5 under alternative scenario 1.
Table 3-6 shows the avoided costs in year 5 under alternative scenario 2.
77
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Average
Facilities
Facilities Under
Estimated Cost
Avoided
Subject to
the Primary
Estimated Costs of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
(Savings) Requirements
Year 5
(2017)
Agriculture
Postharvest Crop Activities (except Cotton Ginning)
115114
1
0
-
-
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
48
(268,511) 75,072
494,197
10,296
Energy
Natural Gas Liquid Extraction
211112
26
11
-
411,198
37,382
Industrial
Iron Ore Mining
212210
11
0
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
-
-
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
-
-
Energy
Support Activities for Oil and Gas Operations
213112
3
1
-
15,247
15,247
Utilities
Hydroelectric Power Generation
221111
1
1
-
15,247
15,247
Utilities
Fossil Fuel Electric Power Generation
221112
334
100
-
4,018,555
40,186
Utilities
Biomass Electric Power Generation
221117
5
4
-
253,162
63,290
Utilities
Other Electric Power Generation
221118
1
1
-
15,247
15,247
Utilities
Other Electric Power GenerationA
221119
8
6
-
300,758
50,126
Utilities
Electric Power Distribution
221122
1
1
-
15,247
15,247
Utilities
Natural Gas Distribution
221210
13
9
-
363,601
40,400
Utilities
Water Supply and Irrigation Systems
221310
2
2
-
47,596
23,798
Utilities
Sewage Treatment Facilities
221320
17
12
(185) 189
268,404
22,367
Utilities
Steam and Air-Conditioning Supply
221330
22
15
-
490,519
32,701
Industrial
Other Animal Food Manufacturing
311119
1
0
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
Industrial
Soybean Processing"
311222
16
0
-
-
Industrial
Other Oilseed Processing"
311223
5
0
-
-
Industrial
Soybean and Other Oilseed Processing
311224
116
2
(74,149) 3,575
70,574
35,287
Industrial
Fats and Oils Refining and Blending
311225
2
0
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
Industrial
Frozen Fruit, Juice, and Vegetable Manufacturing
311411
2
0
-
-
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
Industrial
Specialty Canning
311422
2
0
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
Industrial
Dry, Condensed, and Evaporated Dairy Product
Manufacturing
311514
3
0
-
-
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
-
-
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Average
Facilities
Facilities Under
Estimated Cost
Avoided
Subject to
the Primary
Estimated Costs
of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
(Savings)
Requirements
Year 5
(2017)
Industrial
Commercial Bakeries
311812
2
0
-
-
-
Industrial
Other Snack Food Manufacturing
311919
1
0
-
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
-
Industrial
Flavoring Syrup and Concentrate Manufacturing
311930
1
0
-
-
-
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
-
Industrial
All Other Miscellaneous Food Manufacturing
311999
6
0
-
-
-
Industrial
Breweries
312120
3
1
-
-
15,247
15,247
Industrial
Distilleries
312140
1
0
-
-
-
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
-
-
15,247
15,247
Industrial
Thread MillsA
313113
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Mills
313210
2
2
-
-
47,596
23,798
Industrial
Narrow Fabric MillsA
313221
1
1
-
-
15,247
15,247
Industrial
Textile and Fabric Finishing Mills
313310
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
-
-
47,596
23,798
Industrial
Fabric Coating Mills
313320
50
28
(327,367)
17,935
562,594
20,093
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
Industrial
Leather and Hide Tanning and Finishing
316110
6
4
(6,375)
1,495
52,477
13,119
Industrial
Sawmills
321113
61
11
-
-
411,198
37,382
Industrial
Wood Preservation
321114
3
0
-
-
-
Industrial
Hardwood Veneer and Plywood Manufacturing
321211
3
0
-
-
-
Industrial
Softwood Veneer and Plywood Manufacturing
321212
29
6
-
-
300,758
50,126
Industrial
Engineered Wood Member (except Truss)
Manufacturing
321213
6
1
-
-
15,247
15,247
Industrial
Reconstituted Wood Product Manufacturing
321219
315
61
(1,211,278)
67,105
1,444,931
23,687
Industrial
Wood Window and Door Manufacturing
321911
4
0
-
-
-
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
0
-
-
-
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
3
0
-
-
-
Industrial
Pulp Mills
322110
18
3
-
-
62,843
20,948
Industrial
Paper (except Newsprint) Mills
322121
282
33
-
-
411,198
12,461
Industrial
Newsprint Mills
322122
7
1
-
-
15,247
15,247
Industrial
Paperboard Mills
322130
36
7
-
-
316,005
45,144
Industrial
Corrugated and Solid Fiber Box Manufacturing
322211
174
55
(93,803)
41,102
52,701
958
Industrial
Paper Bag and Coated and Treated Paper
Manufacturing
322220
17
3
-
-
62,843
20,948
Industrial
Coated and Laminated Paper ManufacturingA
322222
12
2
-
-
47,596
23,798
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
-
-
-
Industrial
All Other Converted Paper Product Manufacturing
322299
1
0
-
-
-
Industrial
Commercial Lithographic PrintingA
323110
1
1
-
-
15,247
15,247
Industrial
Commercial Printing (except Screen and Books)
323111
188
110
(1,907,536)
75,478
2,195,659
19,961
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Average
Facilities
Facilities Under
Estimated Cost
Avoided
Subject to
the Primary
Estimated Costs
of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
(Savings)
Requirements
Year 5
(2017)
Industrial
Books Printing
323117
3
2
-
-
47,596
23,798
Industrial
Petroleum Refineries
324110
430
77
(3,071,158)
56,042
7,555,577
98,124
Industrial
Asphalt Shingle and Coating Materials Manufacturing
324122
3
0
-
-
-
Industrial
All Other Petroleum and Coal Products Manufacturing
324199
4
0
-
-
-
Industrial
Petrochemical Manufacturing
325110
597
218
(413,309)
182,730
3,620,549
16,608
Industrial
Industrial Gas Manufacturing
325120
4
1
-
-
15,247
15,247
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
-
-
-
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
-
-
15,247
15,247
Industrial
Synthetic Organic Dye and Pigment ManufacturingA
325132
2
0
-
-
-
Industrial
Other Basic Inorganic Chemical Manufacturing
325180
10
3
-
-
62,843
20,948
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
-
-
24,362
24,362
Industrial
Carbon Black ManufacturingA
325182
21
7
-
-
193,443
27,635
Industrial
All Other Basic Inorganic Chemical ManufacturingA
325188
93
28
-
-
792,076
28,288
Industrial
Cyclic Crude and Intermediate ManufacturingA
325192
1
0
-
-
-
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
-
-
47,596
23,798
Industrial
Cyclic Crude, Intermediate, and Gum and Wood
Chemical Manufacturing
325194
2
0
-
-
-
Industrial
All Other Basic Organic Chemical Manufacturing
325199
77
23
(530,241)
8,745
1,265,177
55,008
Industrial
Plastics Material and Resin Manufacturing
325211
857
254
(7,647,034)
435,787
7,943,793
31,275
Industrial
Synthetic Rubber Manufacturing
325212
22
2
(900)
2,186
13,961
6,981
Industrial
Artificial and Synthetic Fibers and Filaments
Manufacturing
325220
6
2
-
-
47,596
23,798
Industrial
Cellulosic Organic Fiber ManufacturingA
325221
1
0
-
-
-
Industrial
Noncellulosic Organic Fiber ManufacturingA
325222
8
3
-
-
60,824
20,275
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
6
-
-
300,758
50,126
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
2
-
-
47,596
23,798
Industrial
Pesticide and Other Agricultural Chemical
Manufacturing
325320
22
5
(293,333)
8,745
299,836
59,967
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
-
-
15,247
15,247
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
9
(16,533)
13,117
66,260
7,362
Industrial
Biological Product (except Diagnostic) Manufacturing
325414
1
0
-
-
-
Industrial
Paint and Coating Manufacturing
325510
48
19
(2,443,042)
37,164
2,453,475
129,130
Industrial
Adhesive Manufacturing
325520
4
1
-
-
15,247
15,247
Industrial
Surface Active Agent Manufacturing
325613
2
0
-
-
-
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
Industrial
Custom Compounding of Purchased Resins
325991
5
2
-
-
47,596
23,798
Industrial
Photographic Film, Paper, Plate, and Chemical
Manufacturing
325992
4
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Chemical Product and
Preparation Manufacturing
325998
10
3
-
-
62,843
20,948
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Average
Facilities
Under the
Estimated Cost
Avoided
Subject to
Primary
Estimated
of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Costs (Savings)
Requirements
Year 5
(2017)
Industrial
Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
326112
5
2
-
-
47,596
23,798
Industrial
Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
326113
16
7
-
-
316,005
45,144
Industrial
Unlaminated Plastics Profile Shape Manufacturing
326121
12
0
-
-
-
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
0
-
-
-
Industrial
Laminated Plastics Plate, Sheet (except Packaging),
and Shape Manufacturing
326130
7
3
-
-
62,843
20,948
Industrial
Polystyrene Foam Product Manufacturing
326140
1
0
-
-
-
Industrial
Urethane and Other Foam Product (except
Polystyrene) Manufacturing
326150
19
13
(84,386)
5,639
162,278
12,483
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
0
-
-
-
Industrial
All Other Plastics Product Manufacturing
326199
148
64
(2,283,037)
39,608
2,654,627
41,479
Industrial
Tire Manufacturing (except Retreading)
326211
39
19
-
-
714,434
37,602
Industrial
Rubber and Plastics Hoses and Belting Manufacturing
326220
6
2
-
-
47,596
23,798
Industrial
Rubber Product Manufacturing for Mechanical Use
326291
2
0
-
-
-
Industrial
All Other Rubber Product Manufacturing
326299
14
5
-
-
110,439
22,088
Industrial
Pottery, Ceramics, and Plumbing Fixture
Manufacturing
327110
4
1
-
-
20,052
20,052
Industrial
Clay Building Material and Refractories
Manufacturing
327120
76
47
(788,607)
84,009
704,598
14,991
Industrial
Clay Refractory ManufacturingA
327124
8
3
-
-
53,473
17,824
Industrial
Flat Glass Manufacturing
327211
2
0
-
-
-
Industrial
Other Pressed and Blown Glass and Glassware
Manufacturing
327212
17
7
(54,571)
7,150
110,265
15,752
Industrial
Cement Manufacturing
327310
6
2
-
-
47,596
23,798
Industrial
Lime Manufacturing
327410
38
1
-
-
15,247
15,247
Industrial
Gypsum Product Manufacturing
327420
1
0
-
-
-
Industrial
Abrasive Product Manufacturing
327910
4
1
-
-
15,247
15,247
Industrial
Mineral Wool Manufacturing
327993
13
4
(73,704)
3,575
117,726
29,431
Industrial
All Other Miscellaneous Nonmetallic Mineral Product
Manufacturing
327999
2
0
-
-
-
Industrial
Iron and Steel Mills and Ferroalloy Manufacturing
331110
73
39
(1,383,399)
66,135
1,364,860
34,996
Industrial
Iron and Steel MillsA
331111
50
3
-
-
62,843
20,948
Industrial
Electrometallurgical Ferroalloy Product
Manufacturing"
331112
1
0
-
-
-
Industrial
Iron and Steel Pipe and Tube Manufacturing from
Purchased Steel
331210
5
2
-
-
47,596
23,798
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
-
-
47,596
23,798
Industrial
Primary Aluminum Production"
331312
2
0
-
-
-
Industrial
Alumina Refining and Primary Aluminum Production
331313
16
2
(508,999)
1,787
522,459
261,229
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Sector
NAICS Descriptions
NAICS
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Facilities Subject
to MACT
Number of
Facilities Under
the Primary
Scenario
Estimated Cost of
Estimated Costs Area Source
(Savings) Requirements
Avoided Costs
Year 5
Average Avoided
Cost/Entity
(2017)
Industrial
Secondary Smelting and Alloying of Aluminum
331314
56
7
(51,297) 33,376
33,168
4,738
Industrial
Aluminum Sheet, Plate, and Foil Manufacturing
331315
6
2
-
47,596
23,798
Industrial
Aluminum Extruded Product ManufacturingA
331316
1
0
-
-
Industrial
Other Aluminum Rolling, Drawing, and Extruding
331318
2
0
-
-
Industrial
Nonferrous Metal (except Aluminum) Smelting and
331410
1
0
-
-
Refining
Industrial
Primary Smelting and Refining of CopperA
331411
0
0
-
-
Industrial
Primary Smelting and Refining of Nonferrous Metal
331419
2
0
-
-
(except Copper and Aluminum)A
Industrial
Copper Rolling, Drawing, Extruding, and Alloying
331420
3
0
-
-
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
-
-
Industrial
Nonferrous Metal (except Copper and Aluminum)
331491
3
1
-
15,247
15,247
Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying of
331492
2
0
-
-
Nonferrous Metal (except Copper and Aluminum)
Industrial
Iron Foundries
331511
59
4
-
253,162
63,290
Industrial
Steel Foundries (except Investment)
331513
2
0
-
-
Industrial
Aluminum Die-Casting FoundriesA
331521
1
0
-
-
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
-
-
Industrial
Nonferrous Forging
332112
1
1
-
15,247
15,247
Industrial
Metal Crown, Closure, and Other Metal Stamping
332119
1
1
-
15,247
15,247
(except Automotive)
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
-
15,247
15,247
Industrial
Prefabricated Metal Building and Component
332311
1
1
-
15,247
15,247
Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
-
15,247
15,247
Industrial
Metal Window and Door Manufacturing
332321
5
4
-
253,162
63,290
Industrial
Sheet Metal Work Manufacturing
332322
1
1
-
15,247
15,247
Industrial
Metal Can Manufacturing
332431
14
9
(123,526) 2,242
422,042
46,894
Industrial
Other Metal Container Manufacturing
332439
4
2
-
47,596
23,798
Industrial
Bolt, Nut, Screw, Rivet, and Washer Manufacturing
332722
1
1
-
15,247
15,247
Industrial
Metal Heat Treating
332811
1
1
-
15,247
15,247
Industrial
Metal Coating, Engraving (except Jewelry and
332812
433
280
(13,181,179) 200,280
13,408,575
47,888
Silverware), and Allied Services to Manufacturers
Industrial
Electroplating, Plating, Polishing, Anodizing, and
332813
3
2
-
47,596
23,798
Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
-
15,247
15,247
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
-
15,247
15,247
Industrial
Ammunition (except Small Arms) Manufacturing
332993
3
2
-
47,596
23,798
Industrial
All Other Miscellaneous Fabricated Metal Product
332999
3
2
-
47,596
23,798
Manufacturing
Industrial
Farm Machinery and Equipment Manufacturing
333111
8
3
-
62,843
20,948
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Average
Facilities
Under the
Estimated Cost
Avoided
Subject to
Primary
Estimated of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Costs (Savings) Requirements
Year 5
(2017)
Industrial
Lawn and Garden Tractor and Home Lawn and
Garden Equipment Manufacturing
333112
1
0
-
-
Industrial
Construction Machinery Manufacturing
333120
64
28
(348,998) 46,473
350,121
12,504
Industrial
Mining Machinery and Equipment Manufacturing
333131
2
0
-
-
Industrial
Printing Machinery and Equipment ManufacturingA
333293
1
0
-
-
Industrial
Photographic and Photocopying Equipment
Manufacturing
333316
1
0
-
-
Industrial
Air-Conditioning and Warm Air Heating Equipment
and Commercial and Industrial Refrigeration
Equipment Manufacturing
333415
1
0
Industrial
Machine Tool (Metal Cutting Types) ManufacturingA
333512
1
0
-
-
Industrial
Machine Tool (Metal Forming Types) ManufacturingA
333513
1
0
-
-
Industrial
Turbine and Turbine Generator Set Units
Manufacturing
333611
1
0
-
-
Industrial
Other Engine Equipment Manufacturing
333618
5
2
-
47,596
23,798
Industrial
Overhead Traveling Crane, Hoist, and Monorail
System Manufacturing
333923
1
0
-
-
Industrial
Welding and Soldering Equipment Manufacturing
333992
2
0
-
-
Industrial
Radio and Television Broadcasting and Wireless
Communications Equipment Manufacturing
334220
1
0
-
-
Industrial
Electron Tube ManufacturingA
334411
1
0
-
-
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
-
-
Industrial
Semiconductor and Related Device Manufacturing
334413
23
13
-
533,693
41,053
Industrial
Automatic Environmental Control Manufacturing for
Residential, Commercial, and Appliance Use
334512
1
0
-
-
Industrial
Blank Magnetic and Optical Recording Media
Manufacturing
334613
0
0
-
-
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
-
15,247
15,247
Industrial
Household Laundry Equipment Manufacturing
335224
13
9
(289,742) 5,231
332,107
36,901
Industrial
Other Major Household Appliance Manufacturing
335228
2
2
-
47,596
23,798
Industrial
Power, Distribution, and Specialty Transformer
Manufacturing
335311
1
1
-
15,247
15,247
Industrial
Motor and Generator Manufacturing
335312
2
2
-
47,596
23,798
Industrial
Storage Battery Manufacturing
335911
1
1
-
15,247
15,247
Industrial
Current-Carrying Wiring Device Manufacturing
335931
1
1
-
15,247
15,247
Industrial
Noncurrent-Carrying Wiring Device Manufacturing
335932
1
1
-
15,247
15,247
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
-
253,162
63,290
Industrial
Automobile Manufacturing
336111
66
18
(217,754) 3,737
832,012
46,223
Industrial
Light Truck and Utility Vehicle Manufacturing
336112
5
4
-
253,162
63,290
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
-
285,511
57,102
Industrial
Motor Vehicle Body Manufacturing
336211
8
5
-
285,511
57,102
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Average
Facilities
Under the
Estimated Cost
Avoided
Subject to
Primary
Estimated
of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Costs (Savings)
Requirements
Year 5
(2017)
Industrial
Truck Trailer Manufacturing
336212
1
1
-
-
15,247
15,247
Industrial
Motor Vehicle Gasoline Engine and Engine Parts
Manufacturing
336310
2
2
-
-
47,596
23,798
Industrial
Carburetor, Piston, Piston Ring, and Valve
Manufacturing"
336311
1
1
~
15,247
15,247
Industrial
Gasoline Engine and Engine Parts Manufacturing"
336312
3
2
-
-
47,596
23,798
Industrial
Motor Vehicle Steering and Suspension Components
(except Spring) Manufacturing
336330
2
2
"
-
47,596
23,798
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
1
-
-
15,247
15,247
Industrial
Motor Vehicle Transmission and Power Train Parts
Manufacturing
336350
2
2
"
-
47,596
23,798
Industrial
Motor Vehicle Seating and Interior Trim
Manufacturing
336360
1
1
~
15,247
15,247
Industrial
Motor Vehicle Metal Stamping
336370
1
1
-
-
15,247
15,247
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
7
-
316,005
45,144
Industrial
All Other Motor Vehicle Parts Manufacturing"
336399
2
2
-
-
47,596
23,798
Industrial
Aircraft Manufacturing
336411
125
102
(10,522,592)
68,753
10,833,918
106,215
Industrial
Aircraft Engine and Engine Parts Manufacturing
336412
8
5
-
-
285,511
57,102
Industrial
Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336413
10
6
-
-
300,758
50,126
Industrial
Guided Missile and Space Vehicle Propulsion Unit
and Propulsion Unit Parts Manufacturing
336415
1
1
-
-
15,247
15,247
Industrial
Railroad Rolling Stock Manufacturing
336510
1
1
-
-
15,247
15,247
Industrial
Ship Building and Repairing
336611
92
55
(2,687,500)
37,366
2,935,646
53,375
Industrial
Boat Building
336612
96
26
(395,368)
42,898
400,066
15,387
Industrial
Military Armored Vehicle, Tank, and Tank
Component Manufacturing
336992
2
2
-
-
47,596
23,798
Industrial
Wood Kitchen Cabinet and Countertop Manufacturing
337110
347
233
(2,030,654)
338,496
2,055,760
8,823
Industrial
Upholstered Household Furniture Manufacturing
337121
2
2
-
-
47,596
23,798
Industrial
Nonupholstered Wood Household Furniture
Manufacturing
337122
14
9
-
-
363,601
40,400
Industrial
Institutional Furniture Manufacturing
337127
1
1
-
-
15,247
15,247
Industrial
Wood Office Furniture Manufacturing
337211
5
4
-
-
253,162
63,290
Industrial
Office Furniture (except Wood) Manufacturing
337214
19
12
(276,288)
7,473
316,411
26,368
Industrial
Showcase, Partition, Shelving, and Locker
Manufacturing
337215
1
1
-
-
15,247
15,247
Industrial
Blind and Shade Manufacturing
337920
1
1
-
-
15,247
15,247
Industrial
Surgical and Medical Instrument Manufacturing
339112
2
0
-
-
-
Industrial
Surgical Appliance and Supplies Manufacturing
339113
1
0
-
-
-
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
-
-
-
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
-
-
-
(continued)
-------
Table 3-4. Year 5 Avoided Cost for Sources under the PRIMARY SCENARIO (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Average
Facilities
Under the
Estimated Cost
Avoided
Subject to
Primary
Estimated
of Area Source
Avoided Costs Cost/Entity
Sector
NAICS Descriptions
NAICS
MACT
Scenario
Costs (Savings)
Requirements
Year 5
(2017)
Industrial
Office Supplies (except Paper) Manufacturing
339940
1
0
-
-
-
Industrial
Gasket, Packing, and Sealing Device Manufacturing
339991
2
0
-
-
-
Industrial
Burial Casket Manufacturing
339995
3
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
-
-
47,596
23,798
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
-
-
-
Commercial
Petroleum Bulk Stations and Terminals
424710
7
3
-
-
62,843
20,948
Commercial
Scheduled Passenger Air Transportation
481111
2
0
-
-
-
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
Energy
Pipeline Transportation of Crude Oil
486110
1
0
-
-
-
Energy
Pipeline Transportation of Natural Gas
486210
257
103
(183,600)
58,985
2,988,291
29,013
Energy
Pipeline Transportation of Refined Petroleum Products
486910
1
0
-
-
-
Commercial
Support Activities for Rail Transportation
488210
3
1
-
-
15,247
15,247
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
Commercial
General Warehousing and Storage
493110
180
57
(1,837,450)
423,355
1,414,096
24,809
Commercial
Other Warehousing and Storage
493190
6
2
-
-
47,596
23,798
Commercial
Lessors of Nonresidential Buildings (except
Mini warehouses)
531120
1
0
-
-
-
Commercial
Testing Laboratories
541380
2
0
-
-
-
Commercial
Research and Development in the Physical,
Engineering and Life Sciences (except
Nanotechnology and Biotechnology)^
541715
2
0
Commercial
All Other Support Services
561990
1
0
-
-
-
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
23
(2,012,789)
37,536
2,022,849
87,950
Waste Treatment
Solid Waste Landfill
562212
6
4
-
-
253,162
63,290
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
2
-
-
47,596
23,798
Waste Treatment
Remediation Services
562910
1
1
-
-
15,247
15,247
Educational
Colleges, Universities, and Professional Schools
611310
23
9
-
-
363,601
40,400
Services
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
Commercial
Industrial Launderers
812332
3
1
-
-
15,247
15,247
Notes:
Six source categories from the assessed categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subject to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating, and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories, and they were excluded from the table.
For Table 3-4, two columns—estimated Cost Savings and Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without completed RTR modeling files, we only
have the extrapolated cost or savings for facilities in year 5 (2025 and beyond) and not a breakdown of those cost savings by area source requirement costs or supporting statement cost savings. We have
included all of the cost information that is currently available.
-------
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities eligible to obtain area source status.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and are not included in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1 -1 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG Mm2A Cost
Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
NAICS 2012 and NAICS 2007 ("https://www.census.gov/eos/www/naics/downloadables/do wnloadables.html Y
OO
On
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings) Requirements
Year 5
Cost/Entity
Agriculture
Postharvest Crop Activities (except Cotton Ginning)
115114
1
0
-
-
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
40
(223,759) 62,560
446,711
11,168
Energy
Natural Gas Liquid Extraction
211112
26
9
-
363,601
40,400
Industrial
Iron Ore Mining
212210
11
0
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
-
-
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
-
-
Energy
Support Activities for Oil and Gas Operations
213112
3
1
-
15,247
15,247
Utilities
Hydroelectric Power Generation
221111
1
1
-
15,247
15,247
Utilities
Fossil Fuel Electric Power Generation
221112
334
85
-
3,528,036
41,506
Utilities
Biomass Electric Power Generation
221117
5
4
-
253,162
63,290
Utilities
Other Electric Power Generation
221118
1
1
-
15,247
15,247
Utilities
Other Electric Power GenerationA
221119
8
5
-
285,511
57,102
Utilities
Electric Power Distribution
221122
1
1
-
15,247
15,247
Utilities
Natural Gas Distribution
221210
13
7
-
316,005
45,144
Utilities
Water Supply and Irrigation Systems
221310
2
2
-
47,596
23,798
Utilities
Sewage Treatment Facilities
221320
17
10
(158) 162
253,158
25,316
Utilities
Steam and Air-Conditioning Supply
221330
22
13
-
442,922
34,071
Industrial
Other Animal Food Manufacturing
311119
1
0
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
Industrial
Soybean ProcessingA
311222
16
0
-
-
Industrial
Other Oilseed ProcessingA
311223
5
0
-
-
Industrial
Soybean and Other Oilseed Processing
311224
116
1
(37,074) 1,787
35,287
35,287
Industrial
Fats and Oils Refining and Blending
311225
2
0
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
Industrial
Frozen Fruit, Juice, and Vegetable Manufacturing
311411
2
0
-
-
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
Industrial
Specialty Canning
311422
2
0
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
Industrial
Dry, Condensed, and Evaporated Dairy Product
Manufacturing
311514
3
0
-
-
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
-
-
Industrial
Commercial Bakeries
311812
2
0
-
-
Industrial
Other Snack Food Manufacturing
311919
1
0
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
Industrial
Flavoring Syrup and Concentrate Manufacturing
311930
1
0
-
-
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs
of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
All Other Miscellaneous Food Manufacturing
311999
6
0
-
-
-
Industrial
Breweries
312120
3
1
-
-
15,247
15,247
Industrial
Distilleries
312140
1
0
-
-
-
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
-
-
15,247
15,247
Industrial
Thread MillsA
313113
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Mills
313210
2
2
-
-
47,596
23,798
Industrial
Narrow Fabric MillsA
313221
1
1
-
-
15,247
15,247
Industrial
Textile and Fabric Finishing Mills
313310
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
-
-
47,596
23,798
Industrial
Fabric Coating Mills
313320
50
26
(300,087)
16,441
536,808
20,646
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
Industrial
Leather and Hide Tanning and Finishing
316110
6
4
(6,375)
1,495
52,477
13,119
Industrial
Sawmills
321113
61
8
-
-
348,354
43,544
Industrial
Wood Preservation
321114
3
0
-
-
-
Industrial
Hardwood Veneer and Plywood Manufacturing
321211
3
0
-
-
-
Industrial
Softwood Veneer and Plywood Manufacturing
321212
29
3
-
-
62,843
20,948
Industrial
Engineered Wood Member (except Truss)
Manufacturing
321213
6
0
-
-
-
Industrial
Reconstituted Wood Product Manufacturing
321219
315
44
(891,659)
42,667
1,134,503
25,784
Industrial
Wood Window and Door Manufacturing
321911
4
0
-
-
-
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
0
-
-
-
Industrial
All Other Miscellaneous Wood Product Manufacturing
321999
3
0
-
-
-
Industrial
Pulp Mills
322110
18
3
-
-
62,843
20,948
Industrial
Paper (except Newsprint) Mills
322121
282
28
-
-
363,601
12,986
Industrial
Newsprint Mills
322122
7
1
-
-
15,247
15,247
Industrial
Paperboard Mills
322130
36
6
-
-
300,758
50,126
Industrial
Corrugated and Solid Fiber Box Manufacturing
322211
174
46
(78,453)
34,376
44,077
958
Industrial
Paper Bag and Coated and Treated Paper
Manufacturing
322220
17
2
-
-
47,596
23,798
Industrial
Coated and Laminated Paper ManufacturingA
322222
12
2
-
-
47,596
23,798
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
-
-
-
Industrial
All Other Converted Paper Product Manufacturing
322299
1
0
-
-
-
Industrial
Commercial Lithographic PrintingA
323110
1
1
-
-
15,247
15,247
Industrial
Commercial Printing (except Screen and Books)
323111
188
99
(1,718,671)
68,005
1,999,020
20,192
Industrial
Books Printing
323117
3
2
-
-
47,596
23,798
Industrial
Petroleum Refineries
324110
430
65
(2,577,684)
47,297
6,329,839
97,382
Industrial
Asphalt Shingle and Coating Materials Manufacturing
324122
3
0
-
-
-
Industrial
All Other Petroleum and Coal Products Manufacturing
324199
4
0
-
-
-
Industrial
Petrochemical Manufacturing
325110
597
190
(342,065)
169,420
3,036,605
15,982
Industrial
Industrial Gas Manufacturing
325120
4
1
-
-
15,247
15,247
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
-
-
-
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost ($)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs
of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
-
-
15,247
15,247
Industrial
Synthetic Organic Dye and Pigment ManufacturingA
325132
2
0
-
-
-
Industrial
Other Basic Inorganic Chemical Manufacturing
325180
10
2
-
-
47,596
23,798
Industrial
Alkalies and Chlorine Manufacturing"
325181
4
1
-
-
22,921
22,921
Industrial
Carbon Black Manufacturing"
325182
21
6
-
-
170,385
28,397
Industrial
All Other Basic Inorganic Chemical Manufacturing"
325188
93
24
-
-
676,787
28,199
Industrial
Cyclic Crude and Intermediate Manufacturing"
325192
1
0
-
-
-
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
-
-
47,596
23,798
Industrial
Cyclic Crude, Intermediate, and Gum and Wood
Chemical Manufacturing
325194
2
0
-
-
-
Industrial
All Other Basic Organic Chemical Manufacturing
325199
77
20
(530,241)
8,745
1,202,333
60,117
Industrial
Plastics Material and Resin Manufacturing
325211
857
197
(6,207,078)
336,475
6,534,541
33,170
Industrial
Synthetic Rubber Manufacturing
325212
22
2
(900)
2,186
13,961
6,981
Industrial
Artificial and Synthetic Fibers and Filaments
Manufacturing
325220
6
2
-
-
47,596
23,798
Industrial
Cellulosic Organic Fiber Manufacturing"
325221
1
0
-
-
-
Industrial
Noncellulosic Organic Fiber Manufacturing"
325222
8
2
-
-
53,618
26,809
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
4
-
-
253,162
63,290
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
2
-
-
47,596
23,798
Industrial
Pesticide and Other Agricultural Chemical
Manufacturing
325320
22
3
(146,667)
4,372
157,541
52,514
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
-
-
15,247
15,247
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
4
(5,511)
4,372
48,735
12,184
Industrial
Biological Product (except Diagnostic) Manufacturing
325414
1
0
-
-
-
Industrial
Paint and Coating Manufacturing
325510
48
18
(2,299,334)
34,978
2,311,952
128,442
Industrial
Adhesive Manufacturing
325520
4
1
-
-
15,247
15,247
Industrial
Surface Active Agent Manufacturing
325613
2
0
-
-
-
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
Industrial
Custom Compounding of Purchased Resins
325991
5
2
-
-
47,596
23,798
Industrial
Photographic Film, Paper, Plate, and Chemical
Manufacturing
325992
4
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Chemical Product and
Preparation Manufacturing
325998
10
2
-
-
47,596
23,798
Industrial
Plastics Packaging Film and Sheet (including
Laminated) Manufacturing
326112
5
2
-
-
47,596
23,798
Industrial
Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
326113
16
6
-
-
300,758
50,126
Industrial
Unlaminated Plastics Profile Shape Manufacturing
326121
12
0
-
-
-
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
0
-
-
-
Industrial
Laminated Plastics Plate, Sheet (except Packaging), and
Shape Manufacturing
326130
7
2
-
-
47,596
23,798
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs
of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Polystyrene Foam Product Manufacturing
326140
1
0
-
-
-
Industrial
Urethane and Other Foam Product (except Polystyrene)
Manufacturing
326150
19
13
(84,386)
5,639
139,439
10,726
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
0
-
-
-
Industrial
All Other Plastics Product Manufacturing
326199
148
46
(1,636,894)
28,398
1,956,851
42,540
Industrial
Tire Manufacturing (except Retreading)
326211
39
14
-
-
570,912
40,779
Industrial
Rubber and Plastics Hoses and Belting Manufacturing
326220
6
2
-
-
47,596
23,798
Industrial
Rubber Product Manufacturing for Mechanical Use
326291
2
0
-
-
-
Industrial
All Other Rubber Product Manufacturing
326299
14
3
-
-
62,843
20,948
Industrial
Pottery, Ceramics, and Plumbing Fixture
Manufacturing
327110
4
1
-
-
16,425
16,425
Industrial
Clay Building Material and Refractories Manufacturing
327120
76
41
(687,934)
73,284
614,649
14,991
Industrial
Clay Refractory Manufacturing"
327124
8
3
-
-
43,800
14,600
Industrial
Flat Glass Manufacturing
327211
2
0
-
-
-
Industrial
Other Pressed and Blown Glass and Glassware
Manufacturing
327212
17
5
(27,286)
3,575
86,554
17,311
Industrial
Cement Manufacturing
327310
6
2
-
-
47,596
23,798
Industrial
Lime Manufacturing
327410
38
1
-
-
15,247
15,247
Industrial
Gypsum Product Manufacturing
327420
1
0
-
-
-
Industrial
Abrasive Product Manufacturing
327910
4
1
-
-
15,247
15,247
Industrial
Mineral Wool Manufacturing
327993
13
3
(36,852)
1,787
82,661
27,554
Industrial
All Other Miscellaneous Nonmetallic Mineral Product
Manufacturing
327999
2
0
-
-
-
Industrial
Iron and Steel Mills and Ferroalloy Manufacturing
331110
73
37
(1,308,620)
62,560
1,293,657
34,964
Industrial
Iron and Steel MillsA
331111
50
2
-
-
47,596
23,798
Industrial
Electrometallurgical Ferroalloy Product
Manufacturing"
331112
1
0
-
-
-
Industrial
Iron and Steel Pipe and Tube Manufacturing from
Purchased Steel
331210
5
1
-
-
15,247
15,247
Industrial
Rolled Steel Shape Manufacturing
331221
6
1
-
-
15,247
15,247
Industrial
Primary Aluminum Production"
331312
2
0
-
-
-
Industrial
Alumina Refining and Primary Aluminum Production
331313
16
0
-
-
-
Industrial
Secondary Smelting and Alloying of Aluminum
331314
56
5
(42,747)
27,813
14,934
2,987
Industrial
Aluminum Sheet, Plate, and Foil Manufacturing
331315
6
1
-
-
15,247
15,247
Industrial
Aluminum Extruded Product Manufacturing"
331316
1
0
-
-
-
Industrial
Other Aluminum Rolling, Drawing, and Extruding
331318
2
0
-
-
-
Industrial
Nonferrous Metal (except Aluminum) Smelting and
Refining
331410
1
0
-
-
-
Industrial
Primary Smelting and Refining of Copper"
331411
0
0
-
-
-
Industrial
Primary Smelting and Refining of Nonferrous Metal
(except Copper and Aluminum)"
331419
2
0
-
-
-
Industrial
Copper Rolling, Drawing, Extruding, and Alloying
331420
3
0
-
-
-
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings) Requirements
Year 5
Cost/Entity
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
-
-
Industrial
Nonferrous Metal (except Copper and Aluminum)
331491
3
0
-
-
Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying of
331492
2
0
-
-
Nonferrous Metal (except Copper and Aluminum)
Industrial
Iron Foundries
331511
59
3
-
62,843
20,948
Industrial
Steel Foundries (except Investment)
331513
2
0
-
-
Industrial
Aluminum Die-Casting Foundries'^
331521
1
0
-
-
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
-
-
Industrial
Nonferrous Forging
332112
1
1
-
15,247
15,247
Industrial
Metal Crown, Closure, and Other Metal Stamping
332119
1
1
-
15,247
15,247
(except Automotive)
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
-
15,247
15,247
Industrial
Prefabricated Metal Building and Component
332311
1
1
-
15,247
15,247
Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
-
15,247
15,247
Industrial
Metal Window and Door Manufacturing
332321
5
4
-
253,162
63,290
Industrial
Sheet Metal Work Manufacturing
332322
1
1
-
15,247
15,247
Industrial
Metal Can Manufacturing
332431
14
8
(82,351) 1,495
381,614
47,702
Industrial
Other Metal Container Manufacturing
332439
4
2
-
47,596
23,798
Industrial
Bolt, Nut, Screw, Rivet, and Washer Manufacturing
332722
1
1
-
15,247
15,247
Industrial
Metal Heat Treating
332811
1
1
-
15,247
15,247
Industrial
Metal Coating, Engraving (except Jewelry and
332812
433
241
(11,349,410) 172,629
11,556,860
47,954
Silverware), and Allied Services to Manufacturers
Industrial
Electroplating, Plating, Polishing, Anodizing, and
332813
3
2
-
47,596
23,798
Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
-
15,247
15,247
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
-
15,247
15,247
Industrial
Ammunition (except Small Arms) Manufacturing
332993
3
2
-
47,596
23,798
Industrial
All Other Miscellaneous Fabricated Metal Product
332999
3
2
-
47,596
23,798
Manufacturing
Industrial
Farm Machinery and Equipment Manufacturing
333111
8
3
-
62,843
20,948
Industrial
Lawn and Garden Tractor and Home Lawn and Garden
333112
1
0
-
-
Equipment Manufacturing
Industrial
Construction Machinery Manufacturing
333120
64
27
(335,575) 44,686
338,486
12,537
Industrial
Mining Machinery and Equipment Manufacturing
333131
2
0
-
-
Industrial
Printing Machinery and Equipment ManufacturingA
333293
1
0
-
-
Industrial
Photographic and Photocopying Equipment
333316
1
0
-
-
Manufacturing
Industrial
Air-Conditioning and Warm Air Heating Equipment
333415
1
0
-
-
and Commercial and Industrial Refrigeration
Equipment Manufacturing
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings) Requirements
Year 5
Cost/Entity
Industrial
Machine Tool (Metal Cutting Types) Manufacturing"
333512
1
0
-
-
Industrial
Machine Tool (Metal Forming Types) Manufacturing"
333513
1
0
-
-
Industrial
Turbine and Turbine Generator Set Units
Manufacturing
333611
1
0
-
-
Industrial
Other Engine Equipment Manufacturing
333618
5
2
-
47,596
23,798
Industrial
Overhead Traveling Crane, Hoist, and Monorail System
Manufacturing
333923
1
0
-
-
Industrial
Welding and Soldering Equipment Manufacturing
333992
2
0
-
-
Industrial
Radio and Television Broadcasting and Wireless
Communications Equipment Manufacturing
334220
1
0
-
-
Industrial
Electron Tube Manufacturing"
334411
1
0
-
-
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
-
-
Industrial
Semiconductor and Related Device Manufacturing
334413
23
11
-
434,977
39,543
Industrial
Automatic Environmental Control Manufacturing for
Residential, Commercial, and Appliance Use
334512
1
0
-
-
Industrial
Blank Magnetic and Optical Recording Media
Manufacturing
334613
0
0
-
-
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
-
15,247
15,247
Industrial
Household Laundry Equipment Manufacturing
335224
13
8
(248,350) 4,484
291,462
36,433
Industrial
Other Major Household Appliance Manufacturing
335228
2
2
-
47,596
23,798
Industrial
Power, Distribution, and Specialty Transformer
Manufacturing
335311
1
1
-
15,247
15,247
Industrial
Motor and Generator Manufacturing
335312
2
2
-
47,596
23,798
Industrial
Storage Battery Manufacturing
335911
1
1
-
15,247
15,247
Industrial
Current-Carrying Wiring Device Manufacturing
335931
1
1
-
15,247
15,247
Industrial
Noncurrent-Carrying Wiring Device Manufacturing
335932
1
1
-
15,247
15,247
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
-
253,162
63,290
Industrial
Automobile Manufacturing
336111
66
10
(87,102) 1,495
433,962
43,396
Industrial
Light Truck and Utility Vehicle Manufacturing
336112
5
2
-
47,596
23,798
Industrial
Heavy Duty Truck Manufacturing
336120
8
2
-
47,596
23,798
Industrial
Motor Vehicle Body Manufacturing
336211
8
2
-
47,596
23,798
Industrial
Truck Trailer Manufacturing
336212
1
0
-
-
Industrial
Motor Vehicle Gasoline Engine and Engine Parts
Manufacturing
336310
2
0
-
-
Industrial
Carburetor, Piston, Piston Ring, and Valve
Manufacturing"
336311
1
0
-
-
Industrial
Gasoline Engine and Engine Parts Manufacturing"
336312
3
1
-
15,247
15,247
Industrial
Motor Vehicle Steering and Suspension Components
(except Spring) Manufacturing
336330
2
0
-
-
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
0
-
-
Industrial
Motor Vehicle Transmission and Power Train Parts
Manufacturing
336350
2
0
-
-
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs
of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Motor Vehicle Seating and Interior Trim Manufacturing
336360
1
0
-
-
-
Industrial
Motor Vehicle Metal Stamping
336370
1
0
-
-
-
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
3
-
-
62,843
20,948
Industrial
All Other Motor Vehicle Parts ManufacturingA
336399
2
0
-
-
-
Industrial
Aircraft Manufacturing
336411
125
89
(9,493,208)
62,027
9,731,939
109,348
Industrial
Aircraft Engine and Engine Parts Manufacturing
336412
8
2
-
-
47,596
23,798
Industrial
Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336413
10
3
-
-
62,843
20,948
Industrial
Guided Missile and Space Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
336415
1
0
-
-
-
Industrial
Railroad Rolling Stock Manufacturing
336510
1
0
-
-
-
Industrial
Ship Building and Repairing
336611
92
18
(860,000)
11,957
895,639
49,758
Industrial
Boat Building
336612
96
16
(247,105)
26,811
235,541
14,721
Industrial
Military Armored Vehicle, Tank, and Tank Component
Manufacturing
336992
2
0
-
-
-
Industrial
Wood Kitchen Cabinet and Countertop Manufacturing
337110
347
209
(1,822,150)
303,740
1,866,764
8,932
Industrial
Upholstered Household Furniture Manufacturing
337121
2
2
-
-
47,596
23,798
Industrial
Nonupholstered Wood Household Furniture
Manufacturing
337122
14
8
-
-
348,354
43,544
Industrial
Institutional Furniture Manufacturing
337127
1
1
-
-
15,247
15,247
Industrial
Wood Office Furniture Manufacturing
337211
5
4
-
-
253,162
63,290
Industrial
Office Furniture (except Wood) Manufacturing
337214
19
11
(248,659)
6,726
289,530
26,321
Industrial
Showcase, Partition, Shelving, and Locker
Manufacturing
337215
1
1
-
-
15,247
15,247
Industrial
Blind and Shade Manufacturing
337920
1
1
-
-
15,247
15,247
Industrial
Surgical and Medical Instrument Manufacturing
339112
2
0
-
-
-
Industrial
Surgical Appliance and Supplies Manufacturing
339113
1
0
-
-
-
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
-
-
-
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
-
-
-
Industrial
Office Supplies (except Paper) Manufacturing
339940
1
0
-
-
-
Industrial
Gasket, Packing, and Sealing Device Manufacturing
339991
2
0
-
-
-
Industrial
Burial Casket Manufacturing
339995
3
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
-
-
47,596
23,798
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
-
-
-
Commercial
Petroleum Bulk Stations and Terminals
424710
7
2
-
-
47,596
23,798
Commercial
Scheduled Passenger Air Transportation
481111
2
0
-
-
-
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
Energy
Pipeline Transportation of Crude Oil
486110
1
0
-
-
-
Energy
Pipeline Transportation of Natural Gas
486210
257
84
(150,218)
48,260
2,348,871
27,963
Energy
Pipeline Transportation of Refined Petroleum Products
486910
1
0
-
-
-
Commercial
Support Activities for Rail Transportation
488210
3
1
-
-
15,247
15,247
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
(continued)
-------
Table 3-5. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 1 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities
Facilities Under
Estimated Cost
Average
Subject to
Alternative
Estimated Costs
of Area Source
Avoided Costs Avoided
Sector
NAICS Descriptions
NAICS
MACT
Scenario 1
(Savings)
Requirements
Year 5
Cost/Entity
Commercial
General Warehousing and Storage
493110
180
53
(1,708,506)
393,645
1,314,861
24,809
Commercial
Other Warehousing and Storage
493190
6
2
-
-
47,596
23,798
Commercial
Lessors of Nonresidential Buildings (except
Mini warehouses)
531120
1
0
-
-
-
Commercial
Testing Laboratories
541380
2
0
-
-
-
Commercial
Research and Development in the Physical, Engineering
and Life Sciences (except Nanotechnology and
Biotechnology)^
541715
2
0
Commercial
All Other Support Services
561990
1
0
-
-
-
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
18
(1,629,400)
30,386
1,614,261
89,681
Waste Treatment
Solid Waste Landfill
562212
6
2
-
-
47,596
23,798
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
1
-
-
15,247
15,247
Waste Treatment
Remediation Services
562910
1
0
-
-
-
Educational
Colleges, Universities, and Professional Schools
611310
23
8
-
-
348,354
43,544
Services
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
Commercial
Industrial Launderers
812332
3
1
-
-
15,247
15,247
Notes:
Six source categories from the assessed categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subject to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories and they were excluded from the table.
For Table 3-5, two columns—Estimated Costs Savings and Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without completed RTR modeling files, we
only have the extrapolated cost or savings for facilities in year 5 (2025 and beyond) and not a breakdown of those cost savings by area source requirement costs or supporting statement cost savings. We
have included all of the cost information that is currently available.
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities eligible to obtain area source status.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and therefore, we have not included it in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1-2 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost
Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
NAICS 2012 and NAICS 2007 ('https://www.census.gov/eos/www/naics/downloadables/downloadables.html').
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of Facilities Under
Estimated Cost of
Facilities
Subject Alternative
Estimated Costs Area Source
Avoided Costs
Average Avoided
Sector
NAICS Descriptions
NAICS
toMACT
Scenario 2
(Savings) Requirements
Year 5
Cost/Entity
Agriculture
Postharvest Crop Activities (except Cotton Ginning)
115114
1
0
-
-
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
57
(326,049) 91,159
535,649
9,397
Energy
Natural Gas Liquid Extraction
211112
26
12
-
426,445
35,537
Industrial
Iron Ore Mining
212210
11
0
-
-
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
-
-
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
-
-
Industrial
All Other Metal Ore Mining
212299
1
0
-
-
Industrial
Industrial Sand Mining
212322
3
0
-
-
Industrial
Kaolin and Ball Clay Mining
212324
3
0
-
-
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
-
-
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
-
-
Energy
Support Activities for Oil and Gas Operations
213112
3
1
-
15,247
15,247
Utilities
Hydroelectric Power Generation
221111
1
1
-
15,247
15,247
Utilities
Fossil Fuel Electric Power Generation
221112
334
100
-
4,018,555
40,186
Utilities
Biomass Electric Power Generation
221117
5
4
-
253,162
63,290
Utilities
Other Electric Power Generation
221118
1
1
-
15,247
15,247
Utilities
Other Electric Power Generation"
221119
8
6
-
300,758
50,126
Utilities
Electric Power Distribution
221122
1
1
-
15,247
15,247
Utilities
Natural Gas Distribution
221210
13
9
-
363,601
40,400
Utilities
Water Supply and Irrigation Systems
221310
2
2
-
47,596
23,798
Utilities
Sewage Treatment Facilities
221320
17
12
(185) 189
268,404
22,367
Utilities
Steam and Air-Conditioning Supply
221330
22
15
-
490,519
32,701
Industrial
Other Animal Food Manufacturing
311119
1
0
-
-
Industrial
Wet Corn Milling
311221
16
0
-
-
Industrial
Soybean Processing"
311222
16
0
-
-
Industrial
Other Oilseed Processing"
311223
5
0
-
-
Industrial
Soybean and Other Oilseed Processing
311224
116
2
(74,149) 3,575
70,574
35,287
Industrial
Fats and Oils Refining and Blending
311225
2
0
-
-
Industrial
Beet Sugar Manufacturing
311313
11
0
-
-
Industrial
Cane Sugar Manufacturing
311314
3
0
-
-
Industrial
Frozen Fruit, Juice, and Vegetable Manufacturing
311411
2
0
-
-
Industrial
Fruit and Vegetable Canning
311421
1
0
-
-
Industrial
Specialty Canning
311422
2
0
-
-
Industrial
Cheese Manufacturing
311513
2
0
-
-
Industrial
Dry, Condensed, and Evaporated Dairy Product
Manufacturing
311514
3
0
-
-
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
-
-
Industrial
Commercial Bakeries
311812
2
0
-
-
Industrial
Other Snack Food Manufacturing
311919
1
0
-
-
Industrial
Coffee and Tea Manufacturing
311920
1
0
-
-
Industrial
Flavoring Syrup and Concentrate Manufacturing
311930
1
0
-
-
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Sector
NAICS Descriptions
NAICS
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Facilities Subject
to MACT
Number of
Facilities Under
Alternative
Scenario 2
Estimated Costs
(Savings)
Estimated Cost of
Area Source
Requirements
Avoided Costs
Year 5
Average Avoided
Cost/Entity
Industrial
Spice and Extract Manufacturing
311942
4
0
-
-
-
Industrial
All Other Miscellaneous Food Manufacturing
311999
6
0
-
-
-
Industrial
Breweries
312120
3
1
-
-
15,247
15,247
Industrial
Distilleries
312140
1
0
-
-
-
Industrial
Tobacco Manufacturing
312230
1
0
-
-
-
Industrial
Yarn Spinning MillsA
313111
1
1
-
-
15,247
15,247
Industrial
Thread MillsA
313113
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Mills
313210
2
2
-
-
47,596
23,798
Industrial
Narrow Fabric MillsA
313221
1
1
-
-
15,247
15,247
Industrial
Textile and Fabric Finishing Mills
313310
1
1
-
-
15,247
15,247
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
-
-
47,596
23,798
Industrial
Fabric Coating Mills
313320
50
32
(368,288)
20,177
616,520
19,266
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
-
-
-
Industrial
Leather and Hide Tanning and Finishing
316110
6
5
(9,562)
2,242
54,917
10,983
Industrial
Sawmills
321113
61
25
-
-
1,044,439
41,778
Industrial
Wood Preservation
321114
3
1
-
-
15,247
15,247
Industrial
Hardwood Veneer and Plywood Manufacturing
321211
3
1
-
-
15,247
15,247
Industrial
Softwood Veneer and Plywood Manufacturing
321212
29
11
-
-
411,198
37,382
Industrial
Engineered Wood Member (except Truss) Manufacturing
321213
6
2
-
-
47,596
23,798
Industrial
Reconstituted Wood Product Manufacturing
321219
315
126
(2,276,363)
169,736
2,723,390
21,614
Industrial
Wood Window and Door Manufacturing
321911
4
1
-
-
15,247
15,247
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Wood Product Manufacturing
321999
3
1
-
-
15,247
15,247
Industrial
Pulp Mills
322110
18
3
-
-
62,843
20,948
Industrial
Paper (except Newsprint) Mills
322121
282
43
(70,558)
1,787
542,812
12,624
Industrial
Newsprint Mills
322122
7
1
-
-
15,247
15,247
Industrial
Paperboard Mills
322130
36
9
-
-
363,601
40,400
Industrial
Corrugated and Solid Fiber Box Manufacturing
322211
174
68
(115,975)
50,817
65,158
958
Industrial
Paper Bag and Coated and Treated Paper Manufacturing
322220
17
3
-
-
62,843
20,948
Industrial
Coated and Laminated Paper ManufacturingA
322222
12
2
-
-
47,596
23,798
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
-
-
-
Industrial
All Other Converted Paper Product Manufacturing
322299
1
0
-
-
-
Industrial
Commercial Lithographic PrintingA
323110
1
1
-
-
15,247
15,247
Industrial
Commercial Printing (except Screen and Books)
323111
188
121
(2,115,287)
83,699
2,395,190
19,795
Industrial
Books Printing
323117
3
2
-
-
47,596
23,798
Industrial
Petroleum Refineries
324110
430
88
(3,441,264)
62,600
8,503,664
96,633
Industrial
Asphalt Shingle and Coating Materials Manufacturing
324122
3
0
-
-
-
Industrial
All Other Petroleum and Coal Products Manufacturing
324199
4
0
-
-
-
Industrial
Petrochemical Manufacturing
325110
597
260
(425,958)
198,816
5,241,203
20,158
Industrial
Industrial Gas Manufacturing
325120
4
1
-
-
15,247
15,247
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
-
-
-
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
-
-
15,247
15,247
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities Under
Estimated Cost of
Facilities Subject
Alternative
Estimated Costs
Area Source
Avoided Costs
Average Avoided
Sector
NAICS Descriptions
NAICS
toMACT
Scenario 2
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Synthetic Organic Dye and Pigment ManufacturingA
325132
2
0
-
-
-
Industrial
Other Basic Inorganic Chemical Manufacturing
325180
10
3
-
-
62,843
20,948
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
-
-
28,723
28,723
Industrial
Carbon Black ManufacturingA
325182
21
8
-
-
263,218
32,902
Industrial
All Other Basic Inorganic Chemical Manufacturing"
325188
93
37
-
-
1,188,548
32,123
Industrial
Cyclic Crude and Intermediate Manufacturing"
325192
1
0
-
-
-
Industrial
Ethyl Alcohol Manufacturing
325193
7
3
-
-
62,843
20,948
Industrial
Cyclic Crude, Intermediate, and Gum and Wood
Chemical Manufacturing
325194
2
0
-
-
-
Industrial
All Other Basic Organic Chemical Manufacturing
325199
77
28
(662,801)
10,931
1,490,743
53,241
Industrial
Plastics Material and Resin Manufacturing
325211
857
341
(11,710,033)
590,729
11,964,486
35,086
Industrial
Synthetic Rubber Manufacturing
325212
22
2
(900)
2,186
13,961
6,981
Industrial
Artificial and Synthetic Fibers and Filaments
Manufacturing
325220
6
2
-
-
47,596
23,798
Industrial
Cellulosic Organic Fiber Manufacturing"
325221
1
0
-
-
-
Industrial
Noncellulosic Organic Fiber Manufacturing"
325222
8
3
-
-
82,629
27,543
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
6
-
-
300,758
50,126
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
3
-
-
62,843
20,948
Industrial
Pesticide and Other Agricultural Chemical Manufacturing
325320
22
6
(366,667)
10,931
370,983
61,830
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
-
-
15,247
15,247
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
11
(22,044)
17,489
67,399
6,127
Industrial
Biological Product (except Diagnostic) Manufacturing
325414
1
0
-
-
-
Industrial
Paint and Coating Manufacturing
325510
48
26
(3,449,001)
52,467
3,444,130
132,467
Industrial
Adhesive Manufacturing
325520
4
1
-
-
15,247
15,247
Industrial
Surface Active Agent Manufacturing
325613
2
0
-
-
-
Industrial
Toilet Preparation Manufacturing
325620
2
0
-
-
-
Industrial
Explosives Manufacturing
325920
2
0
-
-
-
Industrial
Custom Compounding of Purchased Resins
325991
5
2
-
-
47,596
23,798
Industrial
Photographic Film, Paper, Plate, and Chemical
Manufacturing
325992
4
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Chemical Product and
Preparation Manufacturing
325998
10
3
-
-
62,843
20,948
Industrial
Plastics Packaging Film and Sheet (including Laminated)
Manufacturing
326112
5
4
-
-
253,162
63,290
Industrial
Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
326113
16
8
-
-
348,354
43,544
Industrial
Unlaminated Plastics Profile Shape Manufacturing
326121
12
1
-
-
15,247
15,247
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
1
-
-
15,247
15,247
Industrial
Laminated Plastics Plate, Sheet (except Packaging), and
Shape Manufacturing
326130
7
4
-
-
253,162
63,290
Industrial
Polystyrene Foam Product Manufacturing
326140
1
1
-
-
15,247
15,247
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities Under
Estimated Cost of
Facilities Subject
Alternative
Estimated Costs
Area Source
Avoided Costs
Average Avoided
Sector
NAICS Descriptions
NAICS
toMACT
Scenario 2
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Urethane and Other Foam Product (except Polystyrene)
Manufacturing
326150
19
16
(84,386)
5,639
231,191
14,449
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
2
-
-
47,596
23,798
Industrial
All Other Plastics Product Manufacturing
326199
148
81
(2,886,103)
50,070
3,469,275
42,831
Industrial
Tire Manufacturing (except Retreading)
326211
39
23
-
-
835,689
36,334
Industrial
Rubber and Plastics Hoses and Belting Manufacturing
326220
6
4
-
-
253,162
63,290
Industrial
Rubber Product Manufacturing for Mechanical Use
326291
2
2
-
-
47,596
23,798
Industrial
All Other Rubber Product Manufacturing
326299
14
6
-
-
300,758
50,126
Industrial
Pottery, Ceramics, and Plumbing Fixture Manufacturing
327110
4
3
-
-
38,514
12,838
Industrial
Clay Building Material and Refractories Manufacturing
327120
76
57
(922,838)
98,308
872,126
15,300
Industrial
Clay Refractory ManufacturingA
327124
8
4
-
-
62,045
15,511
Industrial
Flat Glass Manufacturing
327211
2
2
-
-
47,596
23,798
Industrial
Other Pressed and Blown Glass and Glassware
Manufacturing
327212
17
11
(68,214)
8,937
360,035
32,730
Industrial
Cement Manufacturing
327310
6
4
-
-
253,162
63,290
Industrial
Lime Manufacturing
327410
38
2
-
-
47,596
23,798
Industrial
Gypsum Product Manufacturing
327420
1
1
-
-
15,247
15,247
Industrial
Abrasive Product Manufacturing
327910
4
2
-
-
47,596
23,798
Industrial
Mineral Wool Manufacturing
327993
13
6
(73,704)
3,575
323,292
53,882
Industrial
All Other Miscellaneous Nonmetallic Mineral Product
Manufacturing
327999
2
2
-
-
47,596
23,798
Industrial
Iron and Steel Mills and Ferroalloy Manufacturing
331110
73
44
(1,570,344)
75,072
1,542,869
35,065
Industrial
Iron and Steel MillsA
331111
50
3
-
-
62,843
20,948
Industrial
Electrometallurgical Ferroalloy Product ManufacturingA
331112
1
0
-
-
-
Industrial
Iron and Steel Pipe and Tube Manufacturing from
Purchased Steel
331210
5
2
-
-
47,596
23,798
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
-
-
47,596
23,798
Industrial
Primary Aluminum ProductionA
331312
2
0
-
-
-
Industrial
Alumina Refining and Primary Aluminum Production
331313
16
2
(508,999)
1,787
522,459
261,229
Industrial
Secondary Smelting and Alloying of Aluminum
331314
56
8
(59,846)
38,938
36,155
4,519
Industrial
Aluminum Sheet, Plate, and Foil Manufacturing
331315
6
2
-
-
47,596
23,798
Industrial
Aluminum Extruded Product ManufacturingA
331316
1
0
-
-
-
Industrial
Other Aluminum Rolling, Drawing, and Extruding
331318
2
0
-
-
-
Industrial
Nonferrous Metal (except Aluminum) Smelting and
Refining
331410
1
0
-
-
-
Industrial
Primary Smelting and Refining of CopperA
331411
0
0
-
-
-
Industrial
Primary Smelting and Refining of Nonferrous Metal
(except Copper and Aluminum)A
331419
2
0
-
-
-
Industrial
Copper Rolling, Drawing, Extruding, and Alloying
331420
3
0
-
-
-
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
-
-
-
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Sector
NAICS Descriptions
NAICS
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Facilities Subject
toMACT
Number of
Facilities Under
Alternative
Scenario 2
Estimated Cost of
Estimated Costs Area Source
(Savings) Requirements
Avoided Costs
Year 5
Average Avoided
Cost/Entity
Industrial
Nonferrous Metal (except Copper and Aluminum)
331491
3
1
-
15,247
15,247
Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying of
331492
2
0
-
-
Nonferrous Metal (except Copper and Aluminum)
Industrial
Iron Foundries
331511
59
4
-
253,162
63,290
Industrial
Steel Foundries (except Investment)
331513
2
0
-
-
Industrial
Aluminum Die-Casting Foundries'^
331521
1
0
-
-
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
-
-
Industrial
Nonferrous Forging
332112
1
1
-
15,247
15,247
Industrial
Metal Crown, Closure, and Other Metal Stamping (except
332119
1
1
-
15,247
15,247
Automotive)
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
-
15,247
15,247
Industrial
Prefabricated Metal Building and Component
332311
1
1
-
15,247
15,247
Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
-
15,247
15,247
Industrial
Metal Window and Door Manufacturing
332321
5
5
-
285,511
57,102
Industrial
Sheet Metal Work Manufacturing
332322
1
1
-
15,247
15,247
Industrial
Metal Can Manufacturing
332431
14
11
(164,701) 2,989
477,717
43,429
Industrial
Other Metal Container Manufacturing
332439
4
3
-
62,843
20,948
Industrial
Bolt, Nut, Screw, Rivet, and Washer Manufacturing
332722
1
1
-
15,247
15,247
Industrial
Metal Heat Treating
332811
1
1
-
15,247
15,247
Industrial
Metal Coating, Engraving (except Jewelry and
332812
433
332
(15,668,904) 236,898
16,097,597
48,487
Silverware), and Allied Services to Manufacturers
Industrial
Electroplating, Plating, Polishing, Anodizing, and
332813
3
3
-
62,843
20,948
Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
-
15,247
15,247
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
-
15,247
15,247
Industrial
Ammunition (except Small Arms) Manufacturing
332993
3
3
-
62,843
20,948
Industrial
All Other Miscellaneous Fabricated Metal Product
332999
3
3
-
62,843
20,948
Manufacturing
Industrial
Farm Machinery and Equipment Manufacturing
333111
8
3
-
62,843
20,948
Industrial
Lawn and Garden Tractor and Home Lawn and Garden
333112
1
0
-
-
Equipment Manufacturing
Industrial
Construction Machinery Manufacturing
333120
64
30
(375,844) 50,048
373,392
12,446
Industrial
Mining Machinery and Equipment Manufacturing
333131
2
0
-
-
Industrial
Printing Machinery and Equipment ManufacturingA
333293
1
0
-
-
Industrial
Photographic and Photocopying Equipment
333316
1
0
-
-
Manufacturing
Industrial
Air-Conditioning and Warm Air Heating Equipment and
333415
1
0
-
-
Commercial and Industrial Refrigeration Equipment
Manufacturing
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Sector
NAICS Descriptions
NAICS
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of Facilities Under
Facilities Subject Alternative
to MACT Scenario 2
Estimated Costs
(Savings)
Estimated Cost of
Area Source
Requirements
Avoided Costs
Year 5
Average Avoided
Cost/Entity
Industrial
Machine Tool (Metal Cutting Types) ManufacturingA
333512
1
0
-
-
-
Industrial
Machine Tool (Metal Forming Types) ManufacturingA
333513
1
0
-
-
-
Industrial
Turbine and Turbine Generator Set Units Manufacturing
333611
1
0
-
-
-
Industrial
Other Engine Equipment Manufacturing
333618
5
2
-
-
47,596
23,798
Industrial
Overhead Traveling Crane, Hoist, and Monorail System
333923
1
0
-
-
-
Manufacturing
Industrial
Welding and Soldering Equipment Manufacturing
333992
2
0
-
-
-
Industrial
Radio and Television Broadcasting and Wireless
334220
1
0
-
-
-
Communications Equipment Manufacturing
Industrial
Electron Tube ManufacturingA
334411
1
0
-
-
-
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
-
-
-
Industrial
Semiconductor and Related Device Manufacturing
334413
23
15
-
-
610,184
40,679
Industrial
Automatic Environmental Control Manufacturing for
334512
1
0
-
-
-
Residential, Commercial, and Appliance Use
Industrial
Blank Magnetic and Optical Recording Media
334613
0
0
-
-
-
Manufacturing
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
-
-
15,247
15,247
Industrial
Household Laundry Equipment Manufacturing
335224
13
9
(289,742)
5,231
332,107
36,901
Industrial
Other Major Household Appliance Manufacturing
335228
2
2
-
-
47,596
23,798
Industrial
Power, Distribution, and Specialty Transformer
335311
1
1
-
-
15,247
15,247
Manufacturing
Industrial
Motor and Generator Manufacturing
335312
2
2
-
-
47,596
23,798
Industrial
Storage Battery Manufacturing
335911
1
1
-
-
15,247
15,247
Industrial
Current-Carrying Wiring Device Manufacturing
335931
1
1
-
-
15,247
15,247
Industrial
Noncurrent-Carrying Wiring Device Manufacturing
335932
1
1
-
-
15,247
15,247
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
-
-
253,162
63,290
Industrial
Automobile Manufacturing
336111
66
28
(566,161)
9,715
1,222,037
43,644
Industrial
Light Truck and Utility Vehicle Manufacturing
336112
5
4
-
-
253,162
63,290
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
-
-
285,511
57,102
Industrial
Motor Vehicle Body Manufacturing
336211
8
5
-
-
285,511
57,102
Industrial
Truck Trailer Manufacturing
336212
1
1
-
-
15,247
15,247
Industrial
Motor Vehicle Gasoline Engine and Engine Parts
336310
2
2
-
-
47,596
23,798
Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and Valve
336311
1
1
-
-
15,247
15,247
ManufacturingA
Industrial
Gasoline Engine and Engine Parts ManufacturingA
336312
3
2
-
-
47,596
23,798
Industrial
Motor Vehicle Steering and Suspension Components
336330
2
2
-
-
47,596
23,798
(except Spring) Manufacturing
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
1
-
-
15,247
15,247
Industrial
Motor Vehicle Transmission and Power Train Parts
336350
2
2
-
-
47,596
23,798
Manufacturing
Industrial
Motor Vehicle Seating and Interior Trim Manufacturing
336360
1
1
-
-
15,247
15,247
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities Under
Estimated Cost of
Facilities Subject
Alternative
Estimated Costs
Area Source
Avoided Costs
Average Avoided
Sector
NAICS Descriptions
NAICS
toMACT
Scenario 2
(Savings)
Requirements
Year 5
Cost/Entity
Industrial
Motor Vehicle Metal Stamping
336370
1
1
-
-
15,247
15,247
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
7
-
-
316,005
45,144
Industrial
All Other Motor Vehicle Parts Manufacturing"
336399
2
2
-
-
47,596
23,798
Industrial
Aircraft Manufacturing
336411
125
107
(10,865,720)
70,995
11,222,400
104,882
Industrial
Aircraft Engine and Engine Parts Manufacturing
336412
8
5
-
-
285,511
57,102
Industrial
Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336413
10
6
-
-
300,758
50,126
Industrial
Guided Missile and Space Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
336415
1
1
-
-
15,247
15,247
Industrial
Railroad Rolling Stock Manufacturing
336510
1
1
-
-
15,247
15,247
Industrial
Ship Building and Repairing
336611
92
67
(3,332,500)
46,333
3,571,678
53,309
Industrial
Boat Building
336612
96
35
(543,631)
58,985
532,243
15,207
Industrial
Military Armored Vehicle, Tank, and Tank Component
Manufacturing
336992
2
2
-
-
47,596
23,798
Industrial
Wood Kitchen Cabinet and Countertop Manufacturing
337110
347
263
(2,284,486)
380,808
2,489,948
9,467
Industrial
Upholstered Household Furniture Manufacturing
337121
2
2
-
-
47,596
23,798
Industrial
Nonupholstered Wood Household Furniture
Manufacturing
337122
14
11
-
-
586,270
53,297
Industrial
Institutional Furniture Manufacturing
337127
1
1
-
-
15,247
15,247
Industrial
Wood Office Furniture Manufacturing
337211
5
5
-
-
285,511
57,102
Industrial
Office Furniture (except Wood) Manufacturing
337214
19
17
(386,803)
10,462
439,184
25,834
Industrial
Showcase, Partition, Shelving, and Locker Manufacturing
337215
1
1
-
-
15,247
15,247
Industrial
Blind and Shade Manufacturing
337920
1
1
-
-
15,247
15,247
Industrial
Surgical and Medical Instrument Manufacturing
339112
2
0
-
-
-
Industrial
Surgical Appliance and Supplies Manufacturing
339113
1
0
-
-
-
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
-
-
-
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
-
-
-
Industrial
Office Supplies (except Paper) Manufacturing
339940
1
0
-
-
-
Industrial
Gasket, Packing, and Sealing Device Manufacturing
339991
2
0
-
-
-
Industrial
Burial Casket Manufacturing
339995
3
1
-
-
15,247
15,247
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
-
-
47,596
23,798
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
-
-
-
Commercial
Petroleum Bulk Stations and Terminals
424710
7
3
-
-
62,843
20,948
Commercial
Scheduled Passenger Air Transportation
481111
2
0
-
-
-
Commercial
Line-Haul Railroads
482111
1
0
-
-
-
Energy
Pipeline Transportation of Crude Oil
486110
1
0
-
-
-
Energy
Pipeline Transportation of Natural Gas
486210
257
123
(222,545)
71,497
3,473,519
28,240
Energy
Pipeline Transportation of Refined Petroleum Products
486910
1
0
-
-
-
Commercial
Support Activities for Rail Transportation
488210
3
1
-
-
15,247
15,247
Commercial
Marine Cargo Handling
488320
2
0
-
-
-
Commercial
General Warehousing and Storage
493110
180
65
(2,095,338)
482,773
1,612,565
24,809
Commercial
Other Warehousing and Storage
493190
6
2
-
-
47,596
23,798
(continued)
-------
Table 3-6. Year 5 Avoided Cost for Sources under ALTERNATIVE SCENARIO 2 (2017$) (continued)
Facilities
Year 5 (S/Year)
Cost (S)
Number of
Number of
Facilities Under
Estimated Cost of
Facilities Subject
Alternative
Estimated Costs
Area Source
Avoided Costs
Average Avoided
Sector
NAICS Descriptions
NAICS
to MACT
Scenario 2
(Savings)
Requirements
Year 5
Cost/Entity
Commercial
Lessors of Nonresidential Buildings (except
Mini warehouses)
531120
1
0
-
-
-
Commercial
Testing Laboratories
541380
2
0
-
-
-
Commercial
Research and Development in the Physical, Engineering
and Life Sciences (except Nanotechnology and
Biotechnology)^
541715
2
0
Commercial
All Other Support Services
561990
1
0
-
-
-
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
27
(2,396,177)
44,686
2,399,088
88,855
Waste Treatment
Solid Waste Landfill
562212
6
4
-
-
253,162
63,290
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
2
-
-
47,596
23,798
Waste Treatment
Remediation Services
562910
1
1
-
-
15,247
15,247
Educational
Colleges, Universities, and Professional Schools
611310
23
11
-
-
411,198
37,382
Services
Commercial
Amusement and Theme Parks
713110
1
0
-
-
-
Commercial
Linen and Uniform Supply
812330
1
0
-
-
-
Commercial
Industrial Launderers
812332
3
1
-
-
15,247
15,247
Notes:
Six source categories from the assessed categories were identified that would not be affected by the change in policy: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other
Chromium Electroplating, Secondary Lead, Wool Fiberglass, and Portland Cement.
Out of these six categories, four area source categories are subject to a MACT standard where area sources in these categories are subject to the same HAP requirement for major sources in these
categories: Decorative Chromium Electroplating, Hard Chromium Electroplating, Other Chromium Electroplating and Portland Cement. Because there are no differences in the requirements between
major and area sources for these categories, there is no impact of the MM2A policy change on these categories and they were excluded from the table.
For Table 3-6, two columns—Estimated Costs Savings based on supporting statement costs and the Estimated Cost of Area Source Requirements—are incomplete because for the cost categories without
RTR modeling files, we only have the extrapolated cost or savings for facilities in year 5 and not a breakdown of those cost savings by area source requirement costs or supporting statement cost
savings. We have included all of the cost information that is currently available.
The blank cells in the "Average Avoided Cost/Entity" column represent source categories for which there are zero facilities eligible to obtain area source status.
For not directly assessed Source Category "Pulp & Paper (non-combust) MACT" (NAICS 322121), one facility is extrapolated to obtain area source status. However, in the estimation of Extrapolated
Costs (Savings), "No facilities are expected to be area sources." We assume the same when calculating the number of facilities expected to obtain area source status for this not directly assessed
category.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census. Hence, we have not included them in this table.
NAICS 999999 is an unclassified code and therefore, we have not included it in this table.
Note: The total number of facilities estimated to obtain area source status in this table is less than the sum in Table 1-3 because our analysis excludes Public Administration (NAICS 922140, 927110, and
928110) and Unclassified NAICS Code (999999) because the Census does not report data for these NAICS codes.
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost
Analysis Memorandum, Compliance cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
NAICS 2012 and NAICS 2007 ("https://www.census.gov/eos/www/naics/downloadables/downloadables.html').
-------
3.3 Present Value and Equivalent Annualized Value Costs
To comply with EO 12866, the EPA also estimated the PV of the illustrative net cost
savings for each scenario. The PV is the value of a stream of impacts over time, discounted to the
current day. For this analysis, there is the presumption of an infinite time horizon, given that
there is no review period for this action in the Clean Air Act unlike that for most rulemakings
subject to that Act. In this analysis, we analyze the time stream of net cost savings for all
potential reclassifications from year 1 (2021) to year 4 (2024), and then analyze the time stream
of net cost savings from 2025 and beyond. The sum of the PVs for these two impact time streams
form the total PV for this analysis. The PV of the cost savings for the primary scenario is $0.86
billion (in 2017 dollars) at a discount rate of 7 percent, which is discounted to 2020. At a
discount rate of 3 percent, the PV is $1.50 billion (in 2017 dollars), again discounted to 2020.
These results are lower than those estimated for the proposal, where the PV of the cost savings
for the primary scenario was $2.9 billion (in 2017 dollars) at a discount rate of 7 percent and $6.2
billion at a discount rate of 3 percent (in 2017 dollars), discounted to 2020. The lower estimates
for the final rule primarily reflect the overall lower cost savings due to fewer major sources that
could potentially reclassify, and cost savings occurring later than estimated in the proposal.
A measure of the annual net cost savings is the EAV. This annual impact estimate is
calculated consistent with the PV, and is estimated as the sum of the EAVs of the two cost time
streams mentioned above. The EAV is $67 million (2017 dollars) at a 7 percent discount rate for
the primary scenario. At a 3 percent discount rate, the EAV is $75 million (2017 dollars) for the
primary scenario. The PVs for each alternative scenario and discount rate in 2017 dollars can be
found in Table 3-7; the EAVs are in Table 3-8. These results are lower than those for the
proposal ($167 million at a 7 percent discount rate and $173 million at a 3 percent discount rate
in 2017 dollars) for the same reasons that the PVs differ between the proposal and final analyses.
An explanation of why these estimates differ between the proposal and final analyses can be
found in section 1 of this RIA.
Table 3-7. Estimated Present Value of the Net Cost Savings for Each ALTERNATIVE
SCENARIO (billions of 2017$) *
PV of Cost Savings by Alternative Scenario**
7% Discount Rate
3% Discount Rate
ALTERNATIVE SCENARIO 1 (50%ofMST)
0.7
1.2
PRIMARY SCENARIO (75% of MST)
0.9
1.5
ALTERNATIVE SCENARIO 2 (125% of MST)
1.0
1.8
*These values can be converted to 2016 dollars by multiplying by 0.981 using the GDP implicit price deflators for
2016 and 2017. The value for 2016 is 105.770; the value for 2017 is 107.795, and these values can be found at
https://fred.stlouisfed.org/series/USAGDPDEFAISMEI. The values shown in the table will not change given the
rounding convention employed.
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** The calculations for these PV of net cost savings are found in 5 spreadsheets in the docket for this rulemaking.
They are: EO 13771 Workbook (2020)_MM2A_primaryscenario.xlsx, EO 13771 Workbook (2020)_
MM2Afinalforstreaml_50%MST_vf.xlsx, EO 13771 Workbook (2020)_
MM2Afinalforstream2_50%MST_vf.xlsx, EO 13771 Workbook (2020)_
MM2Afinalforstream 1 _ 12 5%MST_vf.xlsx, EO 13771 Workbook (2020)_
MM2A finalforstream2 125%MST vf..xlsx.
Table 3-8. Estimated Equivalent Annualized Value of the Net Cost Savings for Each
ALTERNATIVE SCENARIO (millions of 2017$)*
EAV of Net Cost Savings**
7% Discount Rate
3% Discount Rate
ALTERNATIVE SCENARIO 1(50% of MST)
35
42
PRIMARY SCENARIO (75% of MST)
67
75
ALTERNATIVE SCENARIO 2 (125% of MST)
77
86
*These values can be converted to 2016 dollars by multiplying by 0.981 using the GDP implicit price deflators for
2016 and 2017. The value for 2016 is 105.770; the value for 2017 is 107.795, and these values can be found at
https://fred.stlouisfed.org/series/USAGDPDEFAISMEI. The values shown in the table will change slightly given the
rounding convention employed. As an example, the EAV for the primary scenario in 2016 dollars is $51 million at a
7 percent discount rate and $64 million at a 3 percent discount rate.
**The calculations for these PV of net cost savings are found in 5 spreadsheets in the docket for this rulemaking.
They are: EO 13771 Workbook (2020) MM2A_primaryscenario.xlsx, EO 13771 Workbook (2020)_
MM2Afinalforstreaml_50%MST_vf.xlsx, EO 13771 Workbook (2020)_MM2Afinalforstream2_50%MST_vf.xlsx,
EO 13771 Workbook (2020)_MM2Afinalforstreaml_125%MST_vf.xlsx, EO 13771 Workbook (2020)_
MM2A finalforstream2 125%MST vf.xlsx.
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SECTION 4.
ILLUSTRATIVE EMISSIONS IMPACTS AND POTENTIAL CONTROL COST
IMPACTS
4.1 Estimating Number of Facilities per Source Category and the Fraction That Could
Potentially Obtain Area Source Status
This chapter provides an illustrative assessment of potential impacts associated with HAP
emissions in response to the MM2A rule to inform our analyses, including those of benefits or
disbenefits that is presented later in this RIA. As has been discussed at length in final rule's
documentation of the MM2A database and cost analysis, the assessment of facility response to
the rule is uncertain due to the voluntary nature of the action, and many other factors that are
specific to each facility. In this assessment, to illustrate the impacts of each analytical scenario
we make assumptions in order to characterize the potential response and impacts, and clearly
state how those assumptions impact the outcome of the assessment. In addition to approximating
the response to the MM2A rule, we present information regarding potential changes in HAP
emissions.
The assessment of facility participation in the MM2A action is transferred from the
facility count assessment in the MM2A database memo. The facility count and the estimates of
cost savings for facilities correspond with the emissions assessment presented here, however, in
several source categories we determine in the assessment that there will be a cost savings with no
impact on emissions.
In addition, we received numerous public comments stating that our analytical
assessment should be expanded to include an evaluation of the entire major source NESHAP
program rather than the subset of the source categories presented at proposal. Some commenters
suggest through analyses submitted with their public comments, that every source with actual
emissions below the major source threshold (MST) will reclassify, and every source will increase
emissions to the maximum level permissible as an area source (i.e., up to 10 tpy of a single HAP
or 25 tpy of a combination of HAP). The EPA disagrees with this characterization of impacts for
several reasons.
First, the decision to reclassify to area source status is not a mandate and depends on
many factors specific to the facility such as the ability to sustain emissions below the MST and
not risk unintentionally emitting above the MST. To ensure facilities sustain emissions below the
MST, they are likely to create operating plans that include a compliance margin {i.e., operate at a
reasonable level below the MST to guarantee they maintain area source status). Second, the
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choice to reclassify would be pursued only if the action is a financial return to the company that
weighs the costs of preparing for the reclassification action and the benefits of not having to
comply with one or more major source NESHAP. If it is not advantageous from a business
perspective for the source to undergo reclassification, they will not seek a change in status in
response to MM2A, thus not all facilities below the MST will reclassify. A third analytical
reason to not presume all facilities will emit up to the MST is the consideration that many
industries and areas of the country have other federal or state regulations the effect of which will
continue to limit HAP emissions after a source reclassifies to area source status. Finally, there
are economic limitations on production levels that can impact the level of potential emission
changes. To the extent that a source's emissions correlate with the level of production and the
level of competitiveness in the markets it is in, a source will face competition and limitations
associated with industry growth (which is linked to how much the product is demanded by
consumers) that will create rigidity in a source's efforts to increase production and hence
emissions. All of these factors will reduce opportunities to increase emissions to the maximum
level permissible under area source status. Therefore, simply assuming all facilities will increase
emissions (sometimes by more than lOOx their current levels) is inaccurate and must be
evaluated to properly characterize the response to the MM2A final rule and its impact on HAP
emissions. We recognize that the commenters' analyses demonstrate the concern for emission
changes in response to MM2A, and so the assessment for the final rule warrants an expansion
from the approach used at proposal.
Review of Reclassification Actions Issued Since January 2018
At proposal, the EPA reviewed the reclassification actions of 34 sources that reclassified
after January 2018. For the review of these reclassifications, the EPA evaluated the PTE and
conditions set in permits prior and post reclassification to assess the potential for emission
changes associated with the reclassification of the sources. For the final rule, the EPA expanded
the analysis to include the reclassifications of 35 additional sources. The analysis and results of
the EPA's review of these 69 reclassifications is detailed in the Technical Support Memorandum
"Review of Reclassification Actions for the Final Rulemaking "Reclassification of Major
Sources as Area Sources under Section 112 of the Clean Air Act" available in the docket of this
rulemaking. The EPA's findings from the permit review and emission evaluation are that sources
that had reclassified to area source status, in most cases, achieved and maintain area source status
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by operating the emission controls or continuing to implement the practices they used to comply
with the major source NESHAP requirements.
Illustration of Potential Impacts from Future Reclassifications for 72 Source Categories
At proposal, in addition to the review of actual reclassification actions, the EPA also
prepared an illustrative analysis for six source categories to evaluate the potential emission
impacts if facilities in those six categories were to reclassify to area source status under the
MM2A rule. In the illustrative analysis of the six source categories, we reviewed a sample of
operating permits in six source categories that represent a variety of industrial operations in the
NESHAP program, including: coatings, heavy industry, chemicals, and energy. For these
industries, we also evaluated control technologies employed to reduce HAP emissions and
considered other regulations that may continue to apply to the source and how those regulations
would impact HAP emissions.
For the final MM2A rule, we have updated the assessment conducted at proposal for the
six source categories and expanded our assessment to numerous additional source categories in
response to public comments (thus we assessed 72 categories in total). We identify several
source categories that are not likely to experience a change in emissions as a result of MM2A (65
categories in total). We also conduct an in-depth analysis of potential changes in emissions upon
reclassification for many source categories where we have information. We also review the
updated operating permits for a variety of industrial processes to interpret likely response to the
final MM2A rule.
4.1.1 Findings
Overall, out of the 114 source categories in the major source NESHAP program, we
evaluated the potential emission impacts for 72 source categories in total. We determined that 65
source categories will not change HAP emissions as a result of the MM2A rule.14 After
consideration of the information and data available for this analysis, we found that approximately
7.9 percent of the facilities in the primary scenario (or 3.1 percent of all facilities evaluated in the
72 source categories) assessed with data from available RTR modeling files in the MM2A
database could increase emissions as a result of the MM2A rule. Under alternative scenario 2, we
determined that some facilities operating between 75 and 125 percent of MST could decrease
emissions as a result of the MM2A rule. In most cases the change in emissions is modest and
14 Some of the notable source categories that are not likely to change emissions as a result of MM2A include: Dry
Cleaners, Integrated Iron and Steel Production, Municipal Solid Waste Landfills, Portland Cement
Manufacturing, and Coal- and Oil-Fired Electric Utility Steam Generating Units.
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limited by the factors discussed above. For those facilities, the total potential emission increase
under the primary scenario ranges from about 919 tpy to 956 tpy15. These estimates apply to
industrial source categories and assumes that facilities in the coatings sector will not reformulate
their coatings to a higher HAP content. However, under an alternative set of assumptions in the
coatings sector discussed in section 3.B of this memo, we add to the range presented above a
potential increase in emissions from 0 tpy to 302 tpy of combined HAP to reflect the findings
from one of the reclassification permits reviewed by the EPA that shows one facility could
possibly increase emissions. The total range of emissions increase is, therefore, 919 tpy to 1,258
tpy. Under alternative scenario 2, the MM2A rule could potentially reduce emissions by about
183 tpy.
4.2 Determining Source Categories for the Emissions Assessment
The most accurate evaluation of the impact on emissions from the MM2A rule would
require the latest detailed information about each source. Unfortunately, there are no known
databases that continually compile and update the facility status and detailed information about
these facilities, such as the PTE and limitations on emissions from other regulatory,
technological, economic specifications. To obtain detailed facility data for this rulemaking would
require a massive Information Collection Request (ICR) under CAA section 114 to be sent to the
7,000 or more facilities in the major source NESHAP program. Such an effort would be overly
burdensome and resource intensive, very costly to industry and the public, and time prohibited
(notwithstanding that any action to reclassify is completely voluntary).16 Another option is to
obtain and evaluate Title V permits for each major source, however, such a system currently
does not exist nationwide and therefore, this option is also resource prohibitive.17 Therefore, to
evaluate the facilities operating in the major source NESHAP program under CAA section 112,
we subdivide the analysis into the following segments using information available for each
source category:
15 In addition, some facilities analyzed in the primary scenario have an estimated PTE that is above the MST, yet
their actual emissions are well below 75 percent of the MST. These facilities might opt to reclassify by taking a
limit on their PTE down to a level below the MST. This reduction in emissions can be viewed as foregone
emissions under PTE. The foregone allowable emissions totals a reduction of about 193 tpy. Therefore, the net
change in emissions for the seven source categories is a net increase of 726-763 tpy.
16 Based on past experience issuing CAA section 114 surveys, we note that it could take up to 3 years to prepare a
section 114 notice, undergo review by OMB, issue a public notice, and gather the data.
17 In March 2020, EPA released the Electronic Permitting System for use by all states and EPA Regions. EPA is
currently working with individual states to gradually adopt the system through direct entry or connecting to
existing state electronic systems. In the future after full adoption of the system, the Electronic Permit System will
serve as a repository for all title V permits issued nationwide that are sent to EPA for review.
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(A) identify source categories that are not likely to be impacted by the MM2A final
rule,
(B) identify source categories that will not change emissions for regulatory, technical,
or economic reasons in response to the MM2A final rule,
(C) for source categories that may have emission impacts, conduct an in-depth
evaluation of data specific to each facility and source category, and
(D) for source categories without readily available detailed facility data, we
approximate the magnitude of potential impacts using broad assumptions and
extrapolation or transfer of general information from a variety of sources.
4.3 Characterization of Affected Industries
As a good approximation of current facility characterization, we compiled all available
data files used in recent Residual Risk and Technology Review (RTR) rulemaking efforts. For
many of the RTR files, EPA created a detailed file to characterize facilities in the source
category and their emissions for the purpose of assessing residual risk after compliance with the
major source NESHAP. The data files are commonly referred to as the "RTR modeling file(s)"
since the data is used to model risk and assess residual health risk to the public after compliance
with CAA section 112 maximum achievable control technology (MACT) standards. At the time
of this analysis, the EPA had the necessary data to evaluate 74 source categories.
There are many factors the EPA took into consideration in assessing the potential
emission impacts from the various NESHAP source categories if facilities in these source
categories were to reclassify to area source status. These include the consideration of backstop
measures from regulatory and technological limits, as well as limitations on growth for economic
reasons. As for regulatory reasons, the EPA assessed, if sources were to reclassify, whether they
would be subject to the same NESHAP requirements as before reclassification; whether new area
source NESHAP requirements will be applicable and how they impact emissions; whether there
are NSPS requirements that control emissions at the same levels as the major source NESHAP
requirements; and whether there are PSD/NSR/SIP requirements the effect of which we presume
will continue to control HAP emissions to the same extent. As for the technological and
economic reasons, the EPA reviewed whether the technology changes that have reduced
emissions and could be reversed if sources were to reclassify to area source status. This includes,
but is not limited to, changes in coating/adhesive formulations, fuel combustion technologies,
and some level of backstop for emissions from add-on control technologies. Commenters stated
that there are also other factors that will prevent emissions increases, including environmental
management systems with which sources are engaged that require them to identify
environmental impacts, to set performance objectives, to implement standards for training and
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work practices, to audit implementation of such standards, and to take corrective action when
deviations occur. Other commenters also mentioned that many sources are also required to meet
Leadership in Energy and Environmental Design standards that incentivize efficient operations
to minimize waste and energy usage, Occupational Safety and Health Administration
requirements that protect workers from exposures to HAP and other pollutants, and toxics release
inventory requirements. The commenters pointed that these regulatory requirements continue to
apply even if the source reclassifies, providing additional incentives for sources to not increase
emissions. The EPA agrees with the commenters that environmental management systems, even
though they are voluntary and not regulatory in nature, will also provide additional incentives for
some sources to maintain compliance with environmental legal obligations and not increase
emissions.
Using these assumptions, the EPA determined 39 source categories are not impacted by
the MM2A rule as detailed in the MM2A Database memo.18 We also determined that an
additional 26 source categories (or a total of 65 source categories) will not change their
emissions if they opt to reclassify under MM2A. For the remaining source categories for which
the EPA had in-depth RTR modeling file data, we then proceeded to estimate potential emission
changes for sources with actual emissions at or below our illustrative analytical scenarios. This
memo focuses the analysis on the primary scenario that includes sources with actual emissions
below 75 percent of MST (which also includes sources under alternative scenario 1 with actual
emissions below 50 percent of MST)19, and the incremental effect of sources operating in
alternative scenario 2 with emissions between 75 and 125 percent of the MST {i.e., incremental
from the primary scenario to alternative scenario 2).
A. Source Categories Anticipated to Have No Change in Emissions due to MM2A
Table 4-1 presents the source categories that based on the EPA's review of the facilities
included in the MM2A database, will not change HAP emissions as a result of MM2A. The EPA
determined that the source categories under segment (A) are not impacted by the MM2A rule
and facilities will not seek reclassification to area source status. Detailed information regarding
the source categories not impacted by the MM2A rule is detailed in the MM2A Database memo.
18 Eastern Research Group. Documentation of the Data for Analytical Evaluations & Summary of Industries
Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112
of the Clean Air Ac f. August 2020.
19 Some commenters on the proposed rule stated that the compliance margin assumed by the EPA of 25 percent in
the primary scenario is too large, and the EPA should analyze impacts at 90 percent of the MST. See the cost
memo in section 2 for more information regarding the EPAs reasoning for not assessing regulatory impacts at 90
percent of the MST.
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The EPA does not assign the cost of reclassification to these source categories. In addition, for
the source categories under segment (B) of this analysis, the EPA determined that while some
facilities may have the potential to seek reclassification and estimated the cost of reclassification
in the cost analysis20 (hereafter referred to as "the Cost Analysis Memo"), the EPA determined
that some facilities will not experience emission changes as a result of reclassification. Detailed
assessments to characterize the potential for emission changes are provided for several source
categories in Appendix A of the Illustrative Emissions Analysis memo.
20 See "Documentation of the compliance cost savings analysis for the final rulemaking "Reclassification of Major
Sources as Area Sources Under Section 112 of the Clean Air Act"" (Eastern Research Group, Inc, August 2020)
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Table 4-1. Source Categories Determined to have No Change in Emissions under the
MM2A Final Rule*
Source Categories Not Impacted by MM2A
Part 63
Subpart
Reasoning for Source Category Not Impacted
by MM2A
No
Major/Area NESHAP Emissions
NESHAP No sources standard too High to No Emission
the same in category applicable reclassify Change
Acetal Resins (GMACT I) YY
AMF (Acrylic/Modacrylic Fibers) LLLLLL
Asphalt Roofing LLLLL
Cellulose Products Manufacturing UUUU
Coke Ovens: Charging, Top Side, and Door Leaks L
Coke Ovens: Pushing, Quenching, & Battery CCCCC
Stacks
Commercial Sterilizers O
Cyanide Chemicals (GMACT II) YY
Decorative Chromium Electroplating N
Dry Cleaners M
Dry Cleaners M
Ethylene Production YY
Ferroalloys XXX
Friction QQQQQ
GMACT-HF YY
Halogenated Solvent Cleaning T
Hard Chromium Electroplating N
Hazardous Waste Combustors EEE
Hydrogen Fluoride (GMACT I) YY
Integrated Iron and Steel FFFFF
Iron and Steel Foundries (Major Sources) EEEEE
Lime Manufacturing AAAAA
Magnetic Tape EE
Mercury Cell Chlor-Alkali Plants IIIII
Municipal Solid Waste Landfills AAAA
Nutritional Yeast CCCCC
Other Chromium Electroplating- Chromic Acid N
Anodizing
Phosphate Fertilizer BB
Phosphoric Acid AA
Portland Cement LLL
Primary Copper QQQ
Primary Lead-facility closed TTT
Primary Magnesium Refining TTCTT
Secondary Lead X
Spandex (GMACT II) YY
Taconite Iron Ore Processing RRRRR
Turbines YYYY
Utility NESHAP UUUUU
Wool Fiberglass NNN
Source Categories with No Emission Change
Aerospace - Privately Owned / Aerospace - federal GG
government owned
Asphalt Processing LLLLL
Auto and Light Duty Truck IIII
Boat Manufacturing WW
Fabric OOOO
Flexible Foam Production III
Large Appliances NNNN
Leather TTTT
(continued)
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Table 4-1. Source Categories Determined to have No Change in Emissions under the
MM2A Final Rule* (continued)
Reasoning for Source Category Not Impacted
by MM2A
Source Categories Not Impacted by MM2A
Part 63
Subpart
No
Major/Area NESHAP Emissions
NESHAP No sources standard too High to No Emission
the same in category applicable reclassify Change
Metal Can KKKK
Metal Coil SSSS
Metal Furniture RRRR
Mineral Wool DDD
Misc. Metal Parts MMMM
Miscellaneous Coating Manufacturing HHHHH
Paper and Other Web Coatings: Surface Coating JJJJ
Plastic Parts PPPP
Plywood and Composite Wood Products DDDDD
POTW VVV
Primary Aluminum LL
Pulp and Paper Combustion Sources MM
Reinforced Plastic Composites WWWW
Secondary Aluminum RRR
Shipbuilding II
Vegetable Oil GGGG
Wood Building Products QQQQ
Wood Furniture JJ
*A "1" is used here as an identifier of why a source category is not included in the analysis.
Note: See section 3.B of the illustrative emissions memo for discussion regarding the permit review finding that one
source that uses coatings in their manufacturing process out of the 69 reclassifications (completed between March
2019 and February 2020) might increase emissions after becoming an area source. All other reclassifications
indicate no emissions change, 40 of which operate in the coatings sector. However, to acknowledge the possibility
of other coatings sources to be permitted to increase emissions, we reflect the potential for emission increases
under an alternative set of assumptions for the coatings sector.
4.4 Characterizing Potential Emission Impacts for Remaining Source Categories in the
MM2A Database
The remaining source categories in the MM2A database with facilities that have actual
emissions below the thresholds of the illustrative analytical scenarios described in the Cost
Analysis Memo. To gain more understanding of the magnitude of impact across the source
categories, we can further subdivide them into groupings defined by the number of facilities in
each source category in the primary scenario as shown in Table 4-2 below. The first grouping
includes industries in the major source program that have only one or two facilities affected (up
to 5 facilities). This grouping was reviewed by EPA source category technical leads who know a
great deal about individual facilities when the number of facilities is small. The second grouping
includes industries with fewer than 35 facilities in the primary scenario. This group requires
more speculation on the part of the EPA source category technical leads, but they continue to
have extensive knowledge on many of the facilities within these categories. Using readily
available information in the RTR project files along with the RTR modeling files, the technical
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leads provide insights to the regulatory, technological, and economic conditions that would
influence a facility's response to the MM2A rule. The characterization of each industry for
which we were able to obtain information from an EPA source category technical lead is
provided in Appendix A of the Illustrative Emissions Analysis Memo. The third grouping
includes large industrial categories many affected facilities in which knowledge of the individual
facilities is less likely, but modeling conducted by the EPA can inform the assessment.
Finally, the industries in the coatings sector have similar features to enable a grouping.
We also combine boat manufacturing and reinforced plastic composites into the fourth grouping
because they also have similar characteristics as the coatings sector. This grouping includes 18
source categories that constitute more than 60 percent of the total number of facilities potentially
impacted under the MM2A rule. This grouping along with the permit review of facilities that
have reclassified since January 2018 provide a thorough assessment of the coatings sector.21 We
evaluated the likely response to MM2A for a subset of the coatings sector at proposal. For the
final rule, we provided the MM2A database of information to the EPA technical leads for further
input. The conclusion is the same as at proposal - that the source categories in this sector use
formulations that are low-HAP and the majority of facilities are unlikely to reformulate at a
substantial cost to increase HAP. In addition, most reclassifications completed in 2018 and 2019
are in the coatings sector and our review shows that almost all continue to have as enforceable
condition after reclassification the use of low- or no- HAP coating formulations. Because all but
one of the reclassified coatings facilities did not change emissions, we also include an alternative
set of assumptions to evaluate the potential for some emission increase reflecting actions similar
to the single facility whose permit reflect a potential for coatings emission increases.
We describe the methods used to estimate changes in emissions later in this RIA chapter.
In general, the change in emissions is measured as the difference between PTE with compliance
with the major source NESHAP and 75 percent of MST (the maximum emissions assumed with
compliance margin for the primary scenario). Where the EPA does not have information on the
PTE, we are estimating the potential change in emissions as the difference between actual
emissions and 75 percent of the MST. Therefore, we measure increases or decreases to the
7.5/18.75 tpy level. However, in some cases it is inappropriate to assume changes from minimal
amounts of HAP (i.e., less than 1 tpy) up to a maximum of 7.5/18.75 tpy as it represents a 100-
times to 1000-times increase in emissions (and production to the extent that production and
21 Review of reclassification actions for the rule "Reclassification of Major Sources as Area Sources under Section
112 of the Clean Air Act. " U.S. EPA (August, 2020).
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emissions correlate). Given the production capacities at existing facilities22 along with economic
constraints on growth, it is highly unlikely a facility would seek to increase emissions (and hence
production) by 100-times to 1000-times. Most mature industries will not experience tremendous
economic growth, and some may experience a declining rate of production that impacts growth.
Therefore, we assume a conservative measure of increase for facilities operating at very low
levels of HAP of 10-times (e.g., a facility operating at 0.5 tpy with no information on PTE would
increase to 5 tpy). The measure for emission change in these instances could be higher or lower,
but we selected 10-times to demonstrate a conservatively high level of potential emissions
increase.
In addition, we measure the change in emissions based on a characterization of the
primary source category under which the facility is associated. For facilities that comply with
multiple major source NESHAP, we characterize the facility's emissions response based on the
primary industrial activity of the facility. This assumption ignores the potential for changing
HAP emissions from other emission points at the major source (i.e., combustion engines, boilers,
process vents, and other manufacturing operations in the facility). This assumption adds to the
litany of uncertainties associated with any assessment of the MM2A rule and further supports the
selection of the compliance margin assumed in our analysis. The more operations that exist at a
facility (i.e., the complexity), the more facilities will want to build in a reasonable compliance
margin to maintain area source status. Overall, owners and operators of major sources that opt to
apply for reclassification will weigh the benefits and costs of changing operations that affect
their emissions and will select the lowest-cost opportunities to sustain their emissions below the
MST including a reasonable compliance margin for the facility.
Our analysis of impacts from MM2A includes a reasonable compliance margin at which
the Agency has greater confidence that all sources analyzed could maintain their area source
status if they opt to reclassify. The selection of this compliance margin not only relates to the
performance of HAP control technologies, but also incorporates the factors above that limit a
sources ability to change emissions - the regulatory, financial, and economic considerations in
determining whether to reclassify.
Table 4-2 presents the number of facilities in source categories considered for evaluation
in the emissions analysis. The table includes all source categories considered for review,
however, we were unable to conduct a detailed assessment of emission changes for the following
categories: Brick, Pesticide Active Ingredients, Pharmaceuticals, Polycarbonates, Polyether
22 Modifications to a facility to increase capacity would face new source standards or PSD limits.
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Polyols, the source categories of Polymers and Resins, OSWRO, and Wood Building Products.
We present both the total number of facilities and the incremental number of facilities assessed
across the analytical threshold scenarios. As can be seen in Table 4-2, most facilities in the
MM2A database have actual emissions well below the MST (i.e., below 50 percent of the MST).
Table 4-2. Number of Facilities in Source Categories Included in Emissions Analysis:
Incremental Across Illustrative Scenarios23
Total Major
Total Number of
Incremental Number of Facilities
Source
Facilities
Across Illustrative Analytical
Facilities in
Included in
Scenarios
Source
Emissions
Source Category
Category
Analysis
50% 75% 125%
Group I: Source Categories with Fewer than Five Facilities Included in Emissions Analysis
Asphalt Processing
8
2
1
0
o**
HC1 Production
19
5
4
0
1
Leather
4
3
2
0
1
Mineral Wool
7
2
1
1
0
PAI (Pesticide Active Ingredient Production)*
18
5
2
2
1
Polycarbonates*
4
1
0
1
0
Primary Aluminum
13
1
0
1
0
Vegetable Oil
88
2
1
1
0
Wet Formed Fiberglass Mat
7
5
2
2
1
Group II: Source Categories with Five or More Facilities, But Fewer than 40 Facilities Included in Emissions Analy
sis
Engine Test Cells/Stands
59
28
25
1
2
Flexible Foam Production
12
11
11
0
0
OSWRO
38
25
17
4
4
Polymers & Resins Source Categories (15 Source
75
14
9
1
4
Categories)*
PEPO (Polyether Polyols Production)*
23
7
6
1
0
Pharmaceuticals*
26
10
2
4
4
Plywood and Composite Wood Products
233
82
13
12
57
POTW
10
7
6
1
0
Secondary Aluminum
52
7
5
1
1
Site Remediation
102
26
20
1
5
Steel Pickling
51
42
35
2
5
Wood Building Products
50
31
26
4
1
Group III: Source Categories with 40 or More Facilities
Brick
74
55
41
6
8
Marine Vessel Loading
152
99
85
5
9
Miscellaneous Organic Chemical Manufacturing
197
50
22
11
17
(MON)
Organic Liquids Distribution (Non-Gasoline)
178
65
53
4
8
(OLD)
Refineries (2 Source Categories)
142
27
20
4
3
Group IV: Source Categories in the Coatings Sector, plus Reinforced Plastic Products and Boat Manufacturing
Aerospace - Privately Owned / Aerospace - federal
144
124
106
12
6
government owned
(continued)
23 Facilities listed under the Alternative Scenario 1 (sources with actual emissions below 50 percent of the MST) are
included in the assessment of emission changes under the Primary Scenario (75 percent of MST). Facilities listed
under the Alternative Scenario 2 (125 percent of MST) are incremental to those listed at 75 percent of MST and
are evaluated based on that incremental number of facilities.
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Table 4-2. Number of Facilities in Source Categories Included in Emissions Analysis:
Incremental Across Illustrative Scenarios22 (continued)
Total Major Total Number of Incremental Number of Facilities
Source Facilities Across Illustrative Analytical
Source Category
Facilities in
Source
Category
Included in
Emissions
Analysis
50%
Scenarios
75%
125%
Auto and Light Duty Truck
43
13
2
3
8
Fabric
43
28
22
2
4
Large Appliances
10
7
6
1
0
Leather
4
3
2
0
1
Metal Can
5
4
2
1
1
Metal Coil
48
37
31
4
2
Metal Furniture
16
14
9
1
4
Misc. Metal Parts
368
291
200
33
48
Miscellaneous Coating Manufacturing
43
24
16
1
7
Paper and Other Web Coatings: Surface Coating
171
68
46
9
13
Plastic Parts
125
67
38
15
14
Printing and Publishing
172
113
91
10
12
Shipbuilding
84
62
16
34
12
Wood Building Products
50
31
26
4
1
Wood Furniture
333
252
201
23
28
*Note: The Source Category Characterization for these source categories can be found in Appendix A of the
illustrative emissions memo. We were unable to evaluate the following categories in-depth: Pesticide Active
Ingredients, Pharmaceuticals, Polycarbonates, Poly ether Polyols, the 5 source categories of Polymers and Resins,
OSWRO, and Wood Building Products.
**There is one facility in the database under alternative scenario 2 listed in Asphalt Processing, which also has
activities as a petroleum refinery. We do not include the facility as impacted under for alternative scenario 2 for
Asphalt Processing because this facility has not operated the asphalt portion of the facility in recent years, so
operations are more closely aligned with refining. The Refineries Emission Model indicates that any refinery that is
above the MST will not be able to reduce to below the 10/25 (See the source category characterization for Refineries
below for more information), therefore, will not opt to reclassify.
Estimation of Emission Impacts for Source Categories with Sufficient Information
To evaluate the potential response to the MM2A rule, we characterize technologies and
processes employed, regulatory limitations, PTE, and likelihood of emission increases
considering topics by considering the following questions:
Are the facilities identified in each illustrative analytical scenario likely to reclassify
to area source status?
If they reclassify, would they change how they operate and increase or decrease
emissions?
¦ What technologies do they employ, and will it be permissible to scaled back the use
of these technologies after reclassification?
¦ What other regulatory provisions may limit the ability to increase emissions?
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As discussed in the other documentation for this rule, there are numerous uncertainties in
determining whether a facility will seek reclassification under the MM2A rule. The decision to
reclassify is voluntary and conditions are specific to each individual facility. With regard to
determining a change in emissions, if a facility were to reclassify the main factor determining
any potential emissions increases is whether a facility could adjust the types of control
technology, formulations, and process controls used to comply with the major source NESHAP
requirements upon reclassifying. Specific considerations include:
Compliant Materials: We considered that pollution prevention measures (e.g., process
changes or switches to low-HAP surface coatings) as not adjustable. Source
categories employing those measures as their compliance strategy for the applicable
major source NESHAP could not readily increase or decrease emissions.
Add-on Control Equipment
- Non-adjustable Controls: We considered particulate controls for inorganic HAP
(e.g., fabric filters, electrostatic precipitators) as not adjustable. Source categories
employing those measures as their compliance strategy for the applicable major
source NESHAP could not readily increase or decrease emissions.
- Adjustable Controls: For adjustable controls (e.g., caustic scrubbers, RTOs), our
analysis considered two different sets of assumptions. The first derives from the
findings of our permit review presented above (sources continue to use the same
compliance strategy before and after reclassification, and add-on controls are not
adjusted to decrease control efficiency after the source is reclassified). The
alternative set of assumptions addresses the potential emissions impact if sources
taking PTE limitations were to be allowed to change the operating parameters of
adjustable add-on control upon reclassifying.
We made the following assumptions for the illustrative emissions analysis given the
plausibility that sources that reclassify might be allowed by their permitting authority to change
the operating parameters of adjustable add-on control technologies once they become area
sources.
It is assumed that facilities that utilize compliant materials (i.e., low-HAP coatings)
will not increase emissions.
¦ For a source category employing adjustable control technology, emissions could
potentially increase for facilities with actual emissions below 75 percent of the MST.
The baseline measure of emissions for the calculation of an emission change is
determined as the facility's maximum allowable emissions under the major source
NESHAP because facilities are permitted to emit up to the maximum level
permissible and remain in compliance with the NESHAP regardless of the MM2A
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rule. Often this is represented by the PTE, but in some circumstances the maximum
allowable emissions from the RTR modeling files are used.
¦ Where we are unable to obtain a measure of the maximum allowable emissions under
the NESHAP or PTE, we estimate the change in emissions from actual emissions
documented in the MM2A database, which will overestimate the change in emissions.
¦ Under the analysis of the primary scenario, a potential increase in emissions was
calculated for facilities operating an adjustable control technology in the following
manner:
- For sources with only a single HAP reported in the MM2A database and an
adjustable control, the emission increase is calculated as the difference between
7.5 tpy (or 75percent of the MST for a single HAP) and the estimate of the single
largest HAP emissions.
- Otherwise, the potential emissions increase was estimated as the larger difference
between 18.75 tpy and the estimate of total HAP emissions and between 7.5 tpy
and the single HAP emissions.
Some commenters on the proposed rule suggest through analyses submitted with their
public comments, that every source with actual emissions below the major source threshold
(MST) will reclassify, and every source will increase emissions to the maximum level
permissible as an area source (i.e., up to 10 tpy of a single HAP or 25 tpy of a combination of
HAP). This characterization of impacts is not accurate for several reasons. First, the decision to
reclassify to area source status is not a mandate and depends on many factors specific to the
facility such as the ability to sustain emissions below the MST and not risk unintentionally
emitting above the MST. The choice to reclassify would be pursued only if the action is a
financial return to the company that weighs the costs of preparing for the reclassification action
and the benefits of not having to comply with one or more major source NESHAP. If it is not
advantageous from a business perspective for the source to undergo reclassification, they will not
seek a change in status in response to MM2A, thus not all facilities below the MST will
reclassify. Also, to ensure facilities sustain emissions below the MST, they are likely to create
operating plans that include a compliance margin (i.e., operate at a reasonable level below the
MST to guarantee they maintain area source status). Another analytical reason to not presume in
our emission analysis that all facilities will emit up to the MST is the consideration that many
industries and areas of the country have other federal or state regulations the effect of which will
continue to limit HAP emissions after a source reclassifies to area source status. Finally, there
are economic limitations on production levels that can impact the level of potential emission
changes. To the extent that a source's emissions correlate with the level of production and the
level of competitiveness in the markets it is in, a source will face competition and limitations
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associated with industry growth (which is linked to how much the product is demanded by
consumers) that will create rigidity in a source's efforts to increase production and hence
emissions. All of these factors will reduce opportunities to increase emissions to the maximum
level permissible under area source status. Therefore, simply assuming in our emission analysis
that all facilities will increase emissions (sometimes by more than lOOx their current levels) is
inaccurate and must be evaluated to properly characterize the response to the MM2A final rule
and its impact on costs and HAP emissions.
Also, we measure the change in emissions based on a characterization of the primary
source category under which the facility's is associated. For facilities that comply with multiple
major source NESHAP, we characterize the facility's emissions response based on the primary
industrial activity of the facility. This assumption ignores the potential for reducing or increasing
HAP emissions from other emission points at the major source (i.e., combustion engines, boilers,
process vents, and other manufacturing operations in the facility).24 This assumption adds to the
litany of uncertainties associated with any assessment of the MM2A rule. Owners and operators
of major sources that opt to apply for reclassification will weigh the benefits and costs of each
emission point and the low-cost opportunities to sustain their emissions below the MST
including a reasonable compliance margin for the facility.
For the coatings sector, while the majority of facilities that have reclassified since
January 2018 will have no change in emissions as determine by a review of their permits, we
found one case in which there could be a potential for a change in emissions relating to the
coatings sector. Details of the review of each facility's emission requirements after
reclassification are included in the memo Review of reclassification actions for the rule
"Reclassification of Major Sources as Area Sources under Section 112 of the Clean Air Act. "
Because it is plausible for one facility out of the 69 included in our review to increase emissions
according to their permit, we are incorporating an alternative set of assumptions in our
conclusions of emissions impacts as well. We reviewed 69 operating permits for the sources that
reclassified since January 2018 and found that over 65 percent of the sources operate in the
coatings sector (46 out of the 69 sources). In the coatings sector, 40 out of the 46 reclassified
24 It should be noted that the determination of potential emission changes focuses on the primary source category of
business operations at each facility. Facilities with emission points in multiple source categories will employ a
combination of measures to maintain area source status at the lowest cost. Therefore, an indication of no
emission change in the primary source category of the business operation would not preclude the source from
increasing emissions from another source category. This analysis does not evaluate these secondary level
determinations of potential emission changes when a source operates in multiple source categories.
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facilities used reformulation for compliance prior to reclassification and 13 percent used add-on
control technologies to comply with their major source NESHAP.
The one facility that we found to have a potential emission increase in coatings emissions
requested approval to change from a no-HAP coating to the purchase of a low-HAP coating after
they were reclassified to area source status for another source category. The primary business
function of the establishment is fabrication of metal transformers, and coating the unit is one
element of the process. Therefore, this source would not be accounted for in the MM2A database
as a coating facility, but rather as electrical equipment manufacturing. We continue to affirm that
at most facilities with coatings as their primary business classification that reformulated their
product under MACT to reduce emissions will continue to utilize similar formulations and not
increase HAP. However, to account for the potential of some sources purchasing an alternative
coating from a coatings vendor that results in increased emissions, we have included in our
estimates a range of outcomes that incorporates this possibility. In this alternative outcome, we
assume that 1 of 40 coatings sector facilities change the formulation used in their process after
reclassification, representing 2.5 percent of all coatings facilities (along with the boat
manufacturing and reinforced plastics facilities) incurring a change in HAP content of coatings
from no HAP to HAP containing coatings. This results in an estimate of 27 coatings facilities (22
from surface coatings and 5 from Boat Manufacturing and Reinforced Plastic Composites) that
increase their HAP emissions after reclassifying. For this analysis, we take five random samples
of 27 facilities representing 2.5 percent of the coatings facilities in the MM2A database with
emissions below 75 percent of the MST. We then averaged the results to ensure the results are
not skewed by a single sample. We also assume that if the total HAP and single HAP emissions
for a facility were each less than 1 tpy, the emissions increase would be only 10 times the actual
emissions. For other facilities, we assumed the facility would increase emissions up to 18.75 tpy
of total HAP. The total estimated increase from 27 coating facilities would be 302 tpy of HAP.
The average increase per facility that increased emissions would be about 11.2 tpy of HAP.
Finally, to assess the potential for emission reductions, the illustrative emission analysis
assumes that facilities with emissions between the 75 and 125 percent of the MST, regardless of
the existing control employed for meeting the major source NESHAP standards, would need to
decrease emissions to 7.5 tpy of a single HAP and 18.75 tpy of combined HAP to reclassify to
area source status.
Source Category Characterizations and Findings
At proposal, EPA characterized the response to MM2A for a sample of six source
categories that represented a variety of industrial processes in the major source NESHAP
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program. Based on public comments requesting EPA expand the analysis to include all source
categories in the program, we have expanded the detailed source category characterization of
response to the MM2A final rule. Below is a summary characterization for each of the source
categories we were able to evaluate in-depth for the final rule. Each summary characterizes the
regulatory, technical and economic options that form our understanding of how facilities in the
source category will respond to the MM2A rule, including engineering considerations of
operations at the facility, control technologies employed, and magnitude and direction of
emission changes from a baseline of the maximum allowable emissions under the MACT
standard or the facilities PTE limits set in operating permits.
Where possible, we conduct detailed modeling to assess the PTE and the potential change
in emissions. This level of analysis was viable for the refining industry and is presented in more
detail below.
When detailed modeling is not available, we attempt to review each facility's operating
permit within a source category to determine the PTE allowable in the baseline. In many cases,
we obtained only a portion of operating permits for facilities in the source category. If we were
able to obtain the permits for all impacted facilities, we conduct a detailed assessment for each
individual facility and answer the questions above to determine the response to the regulation.
Then, for some source categories, the EPA source category technical lead with known
expertise in the industry from the assessments of the RTR and technology review provided an
overview of the industry and in some cases of each individual facility to determine how they
might respond to the MM2A final rule. In these cases, we are not able to define PTE through
modeling or permit review. Therefore, we calculate the change in emissions as 18.75 tpy (or 10
times the actual emissions) minus the actual emissions of total combined HAP listed in the
MM2A database.
Utilizing Industry Sector Emission Modeling
Refineries
For the two Refineries source categories, we ran the Refineries Emission Model (REM)
used in recent rulemakings. The Refinery Emission Model (REM) is an Access database model
used to characterize hazardous air pollutant (HAP) emissions from all processes typically present
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at a petroleum refinery.25 The REM provides source characteristics and HAP emission estimates
for each of the following emission sources:
¦ Process heaters and boilers
¦ Flares/thermal oxidizers (includes marine vessel loading emissions)
¦ Wastewater collection and treatment systems
Cooling towers
¦ Fugitive equipment leaks
Tanks (both storage and process tanks)
Truck and rail (product) loading operations
Catalytic reforming unit (CRU) catalyst regeneration vents
Catalytic cracking unit (CCU) catalyst regeneration vents
Sulfur recovery units (SRU) or sulfur plant vents.
The REM model is updated frequently with current data and has received considerable
public review during rulemaking efforts on the Refinery Sector Rule for air toxics issued in
2015. It presents each facility's PTE under the respective NESHAPs (i.e., the baseline of what is
permissible under the MACT standards) and calculates the potential increase in emissions as the
difference from the MACT maximum level of emissions permissible and the 75 percent
threshold of emissions (i.e., 18.75 tpy). We then calculate the change in emissions as the
difference between 18.75 tpy minus PTE. This represents the potential change in emissions from
the maximum level permitted in the baseline and post-regulation level of emissions from the
illustrative MM2A primary scenario which incorporates the compliance margin discussed above
(i.e., at 75 percent of the MST). For facilities where we are unable to calculate PTE, we assume
an emission change based on the difference between 18.75 tpy and the actual emissions in the
MM2A database, or 10 times emissions in a limited number of cases.
In addition, some facilities identified in the MM2A database in the primary scenario have
an estimated PTE in the REM that is above the MST, yet their actual emissions are well below
75 percent of the MST. These facilities might opt to reclassify by taking a limit on their PTE
25 Source: Petroleum Refinery Source Characterization and Emission Model for Residual Risk Assessment. Report
prepared by Research Triangle Institute for the U.S. Environmental Protection Agency, 2002. Available at:
https://www3.epa.gov/ttn/chief/efrac/protocoiyrefinerv RR model documentation Final.pdf.
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down to a level below the MST. For these facilities, we calculate the reduction in PTE that the
facility must take to modify their PTE down to 18.75 tpy. This reduction in emissions can be
viewed as forgone emissions under PTE. Actions taken to lower PTE are highly dependent on
the actions of the permitting authority and the facilities' demonstration of emission limits needed
to ensure they can sustain emissions below the MST. For the 24 facilities in the MM2A database
in the two source categories that represent refineries, the total potential increase in emissions is
about 113 tpy, and forgone allowable emissions under some facilities current PTE down to the
MST totals a reduction of about 205 tpy. Therefore, the net change in emissions for the refining
source categories if all 24 facilities reclassify is a reduction of 92 tpy. EPA determined that no
facilities in the alternative scenario 2 will opt to reclassify due to limited availability of
additional control options to reduce emissions below the MST. Table 4-3 provides estimates of
potential emissions changes at refineries under the primary scenario.
Table 4-3. Estimation of Potential Emission Change for Petroleum Refinery Facilities in
the PRIMARY SCENARIO
Forgone
Best Total HAP
Refineries
Allowable
Estimate in
Emission Model
Potential
Emissions under
MM2A Database
PTE Total HAP
Emission
PTE down to the
Refinery Facility Name
(tpy)
(tpy)
Increase (tpy)
MST (tpy)
AGE Refining & Manufacturing
13.35
24.90
0.00
Eagle Springs Refinery
6.29
7.40
11.35
Navajo Refining Co. - Lovington
2.91
NA
15.84
Silver Eagle Refining - Evanston
17.06
13.90
4.85
CITGO Refining & Chemicals Co., LP
2.59
NA
16.16
ConocoPhillips - Santa Maria
3.35
NA
15.40
Greka Energy
1.21
19.86
0.00
-1.11
VALERO - Wilmington (Asphalt Plant)
2.35
13.42
5.33
KERN Oil & Refining Company
11.25
36.11
0.00
-17.36
San Joaquin Refining Company, Inc.
8.25
37.06
0.00
-18.31
Lunday-Thagard Oil Co.
0.67
17.46
1.29
CITGO Asphalt Refining Company
10.89
16.04
2.71
BP Exploration (Alaska) Inc.
6.53
14.06
4.69
ConocoPhillips - Kuparuk Plant
3.71
16.03
2.72
Petro Star Inc. - North Pole
1.23
20.21
0.00
-1.46
Petro Star - Valdez Refinery
1.05
52.60
0.00
-33.85
Edgington Oil Company
0.56
NA
5.64
Big West Oil LLC (prev. Shell Oil Products US) 0.84
NA
8.37
Flint Hills Resources Alaska, LLC
15.42
87.86
0.00
-69.11
Calumet Lubricants Co. LP - Princeton
5.85
17.98
0.77
Ergon Refining, Inc.
10.91
17.37
1.38
Goodway Refining, LLC
0.35
6.34
12.41
Calcasieu Refining Co.
14.42
82.19
0.00
-63.44
Somerset Refinery
1.19
14.86
3.89
Total
112.79
-204.64
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Updated Illustrative Analysis of Source Categories Reviewed at Proposal
Hydrochloric Acid Production
We reviewed operating permits and found that under one set of assumptions for our
illustrative analysis, we could expect them to operate scrubbers to control emissions from HC1
and Cb at the same control level as MACT, resulting in no potential increases in emissions due
to the reclassification.
Under a second set of assumptions for our illustrative analysis, we reviewed whether
these four facilities could potentially be allowed to adjust the operating parameters to achieve
less than 99 percent reduction of HC1 and CI2.
Two facilities have requirements in their permits that would prevent changes in operating
parameters for HC1 control or would require the continued use of a scrubber. Therefore, we
assume the control technology will serve as a backstop for emissions and it is unlikely that they
will change emissions as a result of reclassification.
However, we calculate an emission change if one assumed the level of control is less than
99 percent.
One facility has a permit limit on annual HC1 emissions that is at least as stringent as
the NESHAP; this state requirement would prevent any potential for changes to the
operating parameters of the add-on controls. Based on this review, we would expect
no emissions increases if this facility were to reclassify.
One facility according to their 2016 permit, will no longer be manufacturing HC1 and
will be only storing purchased HC1 and the HC1 storage tanks will be vented to an
HC1 scrubber. The facility is also subject to the HON.
Permit reviews for another two facilities show no other requirements that would limit
emissions or that require capture and control systems that could serve as backstops, so we
calculate a change in emissions for these facilities. We calculate an emission change if one
assumed the level of control is less than 99 percent.
In conclusion, for the analysis of the primary scenario, we determine that there may not
be an emission increase for this source category. Under another set of assumptions, we
determined that if these four facilities were to reclassify and we assume HC1 and Cb are
controlled at a lower percentage reduction (less than 99 percent control), emissions could
increase by a total of 8.39 tpy for a single HAP or 22.31 tpy for combined HAP.
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We estimate one additional facility has emissions between 75 and 125 percent of the
MST. Based on this review, we would expect some emissions decrease (0.7 tpy HAP for a single
HAP) from this facility if it were to reclassify. As noted above, facilities will consider the costs
to reduce emissions as part of their decision to reclassify. We examine this in our analysis of the
illustrative alternative scenario 2 as applied to several source categories. This analysis can be
found later in this RIA.
Organic Liquids Distribution (OLD Non-Gasoline)
The technology basis of the major source NESHAP standard for storage tanks is a
floating roof or closed vent system and control device (combustion, scrubber, or adsorber) with a
95 percent reduction; for transfer racks, it is a closed vent system and control device
(combustion) with 98 percent destruction; for equipment leaks, it is an LDAR work practice; and
for transport vehicles, it is a vapor tightness or vapor collection certification work practice.
The MM2A database indicates 178 facilities in the OLD source category, and many are
subject multiple NESHAP. Based on our methodology to reduce double counting of facilities
that are subject to multiple NESHAP, 99 of those OLD facilities are counted in the MM2A
database under OLD instead of another NESHAP and 79 are associated with another source
category for the MM2A analysis (e.g., HON, MON, MCM,26 coating and printing).
Of the 99 OLD facilities identified, 23 facilities are also subject to NSPS 40 CFR part 60
subpart Kb ("Standards for Volatile Organic Liquid Storage Vessels, Including Petroleum Liquid
Storage Vessels, for Which Construction, Reconstruction, or Modification Commenced After
July 23, 1984.") and some could also be subject to state or local VOC standards if located in
ozone nonattainment areas.
We estimate 57 of the OLD facilities in the primary scenario and a subset of 12 of these
57 facilities are subject to NSPS subpart Kb, which would limit the ability to increase emissions.
Consistent with the findings of our permit review, under one set of assumptions for our
illustrative analysis, if these sources were to reclassify we could expect them to operate the
combustion devices to control emissions from organic HAP from tanks and transfer racks at the
same level as prior to reclassification, resulting in no potential increases in emissions due to the
reclassification.
26 HON = Hazardous Organic NESHAP (subparts F, G, H, and I), MON = Miscellaneous Organic NESHAP (subpart
FFFF), and MCM = Miscellaneous Coatings Manufacturing NESHAP (subpart HHHHH).
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Under a second set of assumptions for our illustrative analysis, we reviewed whether
these 57 facilities could be allowed to adjust the operating parameters to achieve less than 98
percent destruction of organic HAP. First, we determined which of these 57 facilities are in
ozone nonattainment areas. We then reviewed the permits for a sample of six facilities located in
ozone nonattainment areas to assess whether there are existing state rules or other permit
conditions that could prevent the facility from increasing emissions if the facility obtained area
source status.
Based on the permit review, at the 75 percent threshold three facilities would not be
expected to increase emissions because they are subject to state rules or permit requirements that
directly or indirectly affect HAP emissions. For the remaining 54 facilities, if these facilities
were to reclassify and the permit required organic HAP control at a lower percentage reduction
(rather than 95-98 percent control), there could be a potential emission increase of 659 tpy (for
combined HAP). However, if the NSPS subpart Kb acted as a backstop for 12 of these facilities,
the potential for emissions increases would be reduced to 480 tpy (for combined HAP), a
difference of 179 tpy of HAP. Another consideration, however, is that a portion of HAP
emissions (21 percent) at OLD facilities is from transfer racks and equipment leaks, which are
not regulated by the NSPS subpart Kb. Therefore, at the 12 facilities subject to NSPS subpart
Kb, transfer racks and equipment leaks may represent about 37 tpy of the potential HAP increase
(i.e., 21 percent of 179 tpy), and this increase would not be prevented by NSPS subpart Kb.
Therefore, the potential HAP emissions increase could be slightly higher because there is no
NSPS backstop on emissions from transfer racks, equipment leaks, or wastewater operations. In
conclusion, we estimate a total potential emission increase from the OLD source category in a
range from 480 - 517 tpy.
The MM2A database includes eight facilities in alternative scenario 2. Based on this
review, we would expect some emission decreases (18 tpy for combined HAP) from these
facilities if they were to reclassify.
Surface Coating of Metal Cans
The technology basis of the major source NESHAP standard is a combination of low-
HAP coatings and add-on controls (e.g., thermal oxidizers). Some facilities may be subject to
NSPS subpart WW (beverage can surface coating) and could be subject to state rules based on
CTG. Based on the MM2A database, five facilities are subject to this NESHAP, and three
facilities are in the primary scenario.
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We review the operating permits for all three facilities and determined they use thermal
oxidizers to comply with the NESHAP and they are required to capture and control VOC
separate from the NESHAP requirements. If these facilities reclassified, the state requirements
would necessitate them to continue to operate the control technologies as they have done in the
past. Based on this review, we would expect no emissions increases from these facilities if they
were to reclassify.
We estimate one facility in alternative scenario 2 and could potentially reclassify. Based
on this review, we would expect some potential for emission decreases (4 tpy for combined
HAP) from this facility if it opted to reclassify. As noted above, facilities will consider the costs
to reduce emissions as part of their decision to reclassify. We examine these costs in our analysis
of alternative scenario 2 as applied to several source categories. This analysis can be found later
in this section of the RIA.
Surface Coating of Miscellaneous Metal Parts and Products
The technology basis of the major source NESHAP standard is low-HAP coatings for all
subcategories (except magnet wire, for which the standard is based on the use of a catalytic
oxidizer that is part of the curing oven and is integral to the process).
Facilities in this source category are not subject to an NSPS, but they may be subject to
state rules based on 1978 and 2008 CTGs. Facilities that are area sources may be subject to the
area source NESHAP standard for paint stripping and miscellaneous surface coating operations
(subpart HHHHHH).
Based on the MM2A database, 368 facilities are subject to this NESHAP. We estimate
233 facilities in the primary scenario. Compliance with major source NESHAP can be
demonstrated by (1) compliant coatings; (2) an emission rate without add-on controls; or (3) an
emission rate with add-on controls. We reviewed the permits from 107 major source facilities
and determined that a majority of the facilities are using the first and second compliance options,
and approximately 30 percent of these facilities have add-on controls. Because they have either
already re-engineered their coatings or use emission controls (including controls that are integral
to their curing ovens) supports a conclusion they will continue to use low-HAP coatings and
controls to comply with any VOC coating limits. In conclusion, we expect no emissions increase
from these facilities if they were to reclassify.
The MM2A database includes 48 facilities in alternative scenario. We expect surface
coating sources would review their engineering calculations to ensure they are not over-
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estimating the annual HAP emissions they are reporting. They would also probably examine the
solvents used in their cleaning operations and consider replacing any HAP-containing solvents
with non-HAP solvents to reduce their emissions. Finally, they would speak to their coating
supplier to see if lower-HAP coatings are already on the market that could meet their
specifications without having to invest in "reformulation," so the only investment would be some
testing of the new coatings. Based on our review, we would expect some emission decreases (79
tpy of single HAP and 53 tpy for combined HAP) from these facilities if they were to reclassify
as area sources.
Wet-Formed Fiberglass Mat Production
The technology basis of the major source NESHAP standard is the use of thermal
oxidizers or similar controls (e.g., RTO, regenerative catalytic oxidizer) and the demonstration of
compliance with the percent-reduction requirement (96percent destruction efficiency of
formaldehyde). Formaldehyde-free resins are used in limited applications.
There are no individual state rules/NSPS/CTG that limit HAP from these sources, though
some may be subject to state VOC limits.
The MM2A database indicates seven facilities are subject to the NESHAP. We estimate
four facilities in the primary scenario. Based on permit reviews, two facilities have permit
requirements associated with VOC control. Because formaldehyde is a VOC, we assumed that if
these two facilities were to reclassify, the state requirements would prevent any potential for
changes to the operating parameters of the add-on controls. Based on this review, we would
expect no emissions increases if these two facilities were to reclassify.
In a review of a third facility's permit, we determined that it is not subject to any
NESHAP and is, therefore, not impacted by MM2A. The fourth facility's permit indicates that it
is not subject to other state rules limiting VOC or HAP emissions or that require operation and
maintenance of an emission capture and control system. The latter source demonstrates
compliance with the percent-reduction NESHAP standard, indicating >96 percent control, and
most of that level of control would be needed to maintain area source status.
As a result of a review of operating permits for this source category, we determined that
under one set of assumptions for our illustrative analysis, if these sources were to reclassify we
could expect them to operate the add-on controls at the same control level as prior to
reclassification, resulting in no potential increases in emissions due to the reclassification.
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Under a second set of assumptions for our illustrative analysis, we reviewed whether
these four facilities could potentially be allowed to adjust the operating parameters to achieve
less than 96 percent reduction of formaldehyde. We found that only one facility has a potential to
increase emissions under this set of assumptions. If it were to reclassify and the permit requires
control of formaldehyde at a lower percentage reduction (less than 96 percent control), emissions
could potentially increase (0.14 tpy for a single HAP or 9.5 tpy for combined HAP).
The MM2A database indicates one facility has emissions between 75 percent and 125
percent of the MST, and we estimate that emissions of a single HAP would be reduced by 0.6 tpy
if it opted to reclassify.
Wood Furniture Manufacturing
The technology basis of the major source NESHAP standard is low-HAP coatings and
high-efficiency application methods. The major source NESHAP limits formaldehyde content in
coatings and adhesives used in wood furniture manufacturing and prohibits the use of
conventional spray guns. The RTR confirmed that most facilities are using low- and no-
formaldehyde coatings and contact adhesives and found only one facility using an add-on
control.
These facilities are not subject to an NSPS, but they could be subject to state rules based
on a 1996 CTG,27 which is used in the establishment of reasonably available control technology
(RACT) for VOC for ozone nonattainment areas.
The MM2A database includes 333 facilities are subject to the NESHAP. We estimate 224
facilities in the primary scenario. If facilities were to reclassify, we expect they would continue
to comply with the limits on formaldehyde content in coatings and adhesives, and the prohibition
on the use of conventional spray guns. These facilities have already reformulated their coatings
and implemented spray application compliance requirements and would need to continue using
these measures to maintain area source status. Therefore, we would expect no emissions increase
from these facilities if they were to reclassify.
The MM2A database indicates 28 facilities in alternative scenario 2. Some of these
facilities may already be using low-HAP coatings but have high production volumes. Others may
rely on formulations that contain a higher percentage of HAP due to product specifications.
27 Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations. EPA-453/R-
96-007. April 1996.
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Based on this review, we would expect some potential for emission decreases (76 tpy single
HAP, and 17 tpy for combined HAP) if these facilities were to reclassify as area sources.
Inference of Response from Available Data and EPA Technical Leads
For the final rule, we expanded our analysis of source categories and the assessment of
emission changes in response to public comments. We utilize the same approach as is described
in section C of the illustrative emissions impact memo to determine the potential response from
the source category to the MM2A rule.
Asphalt Processing and Asphalt Roofing Manufacturing
The review includes two source categories related to asphalt production. The technology
basis of the major source NESHAP standard is use of thermal oxidizers to meet PAH emission
limits, or Electrostatic Precipitator (ESP) to meet alternative limits for PM. There is an area
source NESHAP for these source categories and an NSPS is applicable to facilities built after
1982.
The MM2A database includes one facility in the primary scenario under Asphalt
Processing. The Asphalt Roofing Manufacturing source category is not impacted by MM2A.
According to a memo from the EPA source category technical lead who reviewed the facility's
operating permit, the gaseous emissions are controlled by thermal oxidizers (afterburners) and
PM emissions are controlled by baghouse fabric filters. The source has enforceable conditions in
its permit requiring operation of afterburners and PM control equipment to achieve 95 percent
control efficiency to limit major source status for 40 CFR section 52.2, Prevention of Significant
Deterioration, which serves as a limit on their ability to increase emissions. As a result, this
facility will not increase emissions as a result of reclassification under MM2A.
The MM2A database indicates one facility in alternative scenario 2. We determined that
this facility is a petroleum refinery that also has dormant asphalt processing activities. The
Refineries Emission Model indicates that any refinery that is above the MST will not be able to
reduce to below the 10/25 (See the source category characterization for Refineries below for
more information).
Engine Test Cells
The technology basis of the major source NESHAP is the use of catalytic or thermal
incinerators (i.e., RTO). The NESHAP established four subcategories of engine test cell/stands
including those used for testing:
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internal combustion engines of 25 horsepower or more;
internal combustion engines of less than 25 horsepower;
combustion turbine engines; and
rocket engines.
Although the rule covers these four subcategories, it limits HAP only from new or
reconstructed engine test cells/stands used for testing internal combustion engines of 25
horsepower or more located at a facility considered a major source of air toxics emissions.
The MM2A database includes 26 facilities in the primary scenario. Of the 26 facilities,
only two facilities in the U.S. have controls being operated for purposes of the major source
NESHAP. Only one of those facilities is indicated as operating in the MM2A database under the
primary scenario with actual emissions of 1.4 tpy total HAP. According to the EPA source
category technical lead, this facility could potentially opt to reclassify under MM2A, however
any change in emissions would be limited by BACT requirements under state rules for Michigan.
The requirements limit the emissions of all non-VOC toxic air contaminants using CO as a
surrogate for air toxics. This facility currently operates an RTO. If the RTO were to be adjusted
to lower temperatures under BACT, emissions would increase. We are unable to determine the
exact change in emissions; therefore, we employ the approximation methods to determine
emissions change (e.g., actual emissions x 10 to illustrate maximum potential risk change) and
conclude that emissions could potentially increase by 14.1 tpy.
The MM2A database indicates two facilities in alternative scenario 2 that were not
assessed in the illustrative emissions analysis.
Iron and Steel Foundries
Facilities in the Iron and Steel Foundries source category are not likely to reclassify.
These sources have already installed add-on controls due to high emissions that the source will
need to continue to operate if they were to reclassify. These sources would not be exempt from
the monitoring and recordkeeping requirements, and it is unlikely that they would not want to
incur the cost of reopening their air permits. The industry is also cautious due to uncertainties
and the timing of the post-promulgation judicial review. As a result of this review, we concluded
that this source category would not be impacted (as reflected in the MM2A database memo).
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Leather Finishing Operations
Due to the substantial costs associated with reformulating a coating product and testing
for quality assurance, the facilities in the MM2A database are not likely to alter the low HAP
coatings currently in use. These facilities do not operate add-on pollution control technologies in
order to comply with the Leather Finishing Operations NESHAP, therefore, such technologies
are not a factor in determining if sources would alter their emissions as a result of the MM2A
rule. , The facilities in question would be limited in their ability to increase production (and
hence emissions) under the current plant structures. In addition, there are regulatory mechanisms
applied to some facilities to limit VOCs emitted to the air that would also limit production and
therefore HAP emissions. Finally, economic data indicates that the Leather industry is currently
slowing in their production levels with a annual growth rate at -4.6 percent (available at
IBISworld market research website, June 2020; www.ibisworld.com/united-states/market-
research-reports/leather-tanning-finishing-industry). This indicates that the industry would be
limited in its ability to increase production directly in response to the MM2A rule, and emissions
as well. In conclusion, with the likely continued use of low HAP coatings and slow market
growth in the industry, we conclude that emissions will not increase for this source category if
facilities decide it is beneficial for their business and choose to reclassify. For alternative
scenario 2, the EPA source category technical lead stated that there is a possibility of this facility
adjusting production levels between this facility and another facility in the primary scenario and
could reclassify. Because it would be a trade-off of emissions between facilities in the same
source category, we do not include this in our estimate of emission reductions.
Marine Tank Vessel Loading Operations
For this analysis based on the applicability criteria of the Marine Tank Vessels Loading
NESHAP, sources in the primary scenario are subject to the submerged fill standards for Cargo
Filling Lines. The cargo filling lines requirement will continue to apply to these sources in the
event they were to reclassify to area source status and no longer be subject to the NESHAP
because these requirements are also Coast Guard requirements.
In addition, we reviewed a sampling of state requirements in those states with the most
marine tank vessel loading (MVL)terminals are located. Many of these sources are located
within areas regulated for VOC emissions and any VOC requirements applicable to these sources
will also control HAP emissions. Below are some examples of VOC requirements applicable to
MVL in three states:
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Texas: Texas requires 90 percent control of MVL at marine terminals only in the
Houston/Galveston area counties (Brazoria, Chambers, Fort Bend, Galveston, Harris,
Liberty, Montgomery, and Waller Counties).
¦ Louisiana: Louisiana requires emission controls for MVL facilities with uncontrolled
PTE of 25 tpy or more of VOC in the parishes of Ascension, East Baton Rouge,
Iberville, Livingston, and West Baton Rouge, or 100 tpy or greater of VOC in any
other parish. When loading liquids with vapor pressure >1.5 psia, a vapor collection
and control system that reduces VOC 90 percent by weight must be used.
Alaska: Alaska requires that VOC loading sources located only in the Port of
Anchorage that have a design throughput of 15 million gallons (357,143 barrels) or
more per year reduce VOC emissions by operating a vapor collection system and
liquid product loading equipment that loads volatile liquid through submerged filling,
and processes the collected vapors in a control device that emits no more than 10
milligrams of organic vapors per liter of volatile liquid loaded.
Based on this review, we would expect no emissions increases if these facilities were to
reclassify to area source status.
The MM2A database indicates nine facilities in alternative scenario 2. Based on this
review, we would expect some emission decreases (23 tpy for combined HAP) from these
facilities if they were to reclassify. Analysis of potential control costs associated with these
emissions decreases from this source category is included in the illustrative analysis for
alternative scenario 2 for several source categories that is found earlier in this RIA.
Miscellaneous Organic Chemical NESHAP (MON)
The technology basis of the major source NESHAP standard are combustion control
devices operating at a 95 to 99 percent combustion efficiency depending on the emission point,
storage tank controls, and work practices for batch processes.
The MM2A database includes 197 facilities that are subject to the major source NESHAP
and indicates 33 facilities in the primary scenario (22 of which operate below 50 percent of the
MST). We reviewed the operating permits for the 33 facilities in the primary scenario. Our
permit review focused on the potential to emit (PTE) HAP for each facility. We used that
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information to calculate the maximum potential emission increase similar to the analysis
conducted for the refineries source category.28
Based on this review, it was determined that:
¦ Nine facilities are not likely to seek reclassification based on information contained in
their permit. We did not consider these facilities for our emission analysis.
Seven could potentially reclassify and it is highly likely that four of the facilities will
reclassify because their permit says they are minor sources that are subject to subpart
FFFF only because of the OIAI policy. Therefore, we consider these facilities in our
analysis of emission changes below.
For the remaining 17 facilities, we were unable to find the PTE information in their
permits. For these facilities it is more uncertain whether they would seek to reclassify
and how emissions might change as a result. (For this analysis, we assume they could
reclassify and measure emission change from actual emissions to 75 percent of the
MST or applied the alternative calculation of 10 times the actual emissions).
In addition, if MON facilities were to reclassify as area sources, they could potentially be
subject to the Chemical Manufacturing Area Sources NESHAP (CMAS), which was issued in
2009 and amended in 2012. CMAS is the area source equivalent to the Hazardous Organic
NESHAP (HON). The HON covers similar emission points at organic chemical facilities as the
MON. However, CMAS covers fewer emission points and fewer pollutants than the HON and
MON. While the MON requires control of all 187 listed HAP, CMAS only requires control of a
small subset of HAP, including: 1,3-butadiene; 1,3-dichloropropene; Acetaldehyde; Chloroform;
Ethylene dichloride; Hexachlorobenzene; Methylene chloride; Quinoline; Arsenic compounds;
Cadmium compounds; Chromium compounds; Lead compounds; Manganese compounds;
Nickel compounds; Hydrazine. There are also exemptions under CMAS if the affected systems
do not use certain HAP listed in 40 CFR subpart VVVVVV as feedstocks or if they do not
manufacture any listed HAP as byproducts or products.
Therefore, if the facilities detailed above were to reclassify (a total of 26 facilities), this
source category could potentially increase total HAP emissions by about 280 tpy.
In addition, some facilities identified in the MM2A database in the primary scenario have
an estimated PTE that is above the MST, yet their actual emissions are well below 75 percent of
28 Some MON facilities have reclassified since January 2018 and the EPA has reviewed their operating permits in
the memo, Review of reclassification actions for the rule "Reclassification of Major Sources as Area Sources
under Section 112 of the Clean Air Act" and concluded that emissions will not change for those that have already
reclassified.
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the MST. These facilities might opt to reclassify by taking a limit on their PTE down to a level
below the MST. For these facilities, we calculate the reduction in PTE that the facility must take
to modify their PTE to down to 18.75 tpy. This reduction in emissions can be viewed as foregone
emissions under PTE. Actions taken to lower PTE are highly dependent on the actions of the
permitting authority and the facilities' demonstration of emission limits needed to ensure they
can sustain emissions below the MST. For four facilities in the MM2A database in this category,
the foregone allowable emissions totals a reduction of about 22 tpy. Therefore, the net change in
emissions for the MON source category is a net increase of 258 tpy.
Seventeen facilities operate in alternative scenario 2 (seven of which are between 75 and
100 percent of the MST) with an estimated potential emission reduction of 59 tpy. Analysis of
potential control costs associated with the estimated potential emissions reduction for these 17
facilities can be found in the illustrative alternative scenario 2 control cost memo (US EPA,
Sorrels, August 2020).
4.5 Illustrative Source Category Cost Analyses for Alternative Scenario 2
The analysis of the illustrative 125 percent major source threshold (MST) scenario (or
alternative scenario 2) prepared for the MM2A action focuses on major sources with actual HAP
emissions at or above the major source emission thresholds (10 tons for one HAP, 25 tons for
two or more HAP) up to 25 percent higher than the MST. In order to be eligible to reclassify to
area source status, a source in this scenario will need to take enforceable PTE limitations below
the MST and reduce its actual HAP emissions accordingly. The cost analysis for this scenario
includes the positive permitting costs and the reduction in monitoring, recordkeeping and
reporting costs associated with the reclassification to area source status. In addition, the sources
in this scenario will incur cost (either operating & maintenance (O&M) or capital) to reduce
actual emissions below the MST.
This analysis presents an effort to determine if source categories with sources that could
be eligible to reclassify will be able to reduce emissions if necessary to reclassify, and then
calculate the potential control cost for reducing HAP emissions from these source categories.
This illustrative analysis is one way to characterize the potential control costs that a major source
with actual emissions above the MST will consider in order to determine whether to seek
reclassification to area source status. We analyze the control costs associated with the reduction
of HAP emissions sufficient for sources with emissions of up to the alternative scenario 2 to
reach the primary scenario (that is, emissions for the primary scenario for this final rule). Results
of this analysis are not meant to serve as representative of impacts for all source categories
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affected by this rule. This analysis is not applicable to sources at the other two scenarios
examined in this final action (alternative scenario 1 and primary scenario), because sources
affected by those scenarios have actual HAP emissions already below the MST.
The analysis is an update to the memo that was completed for the proposal MM2A.29 This
updated analysis reflects the revisions to the source inventory prepared for the cost and emission
analyses done for the final rule. Please refer to the final rule emissions technical support
memoranda (TSMs) on the MM2A database for more information on the revisions.
4.6 Source Categories Included in Analysis
To select the source categories for this analysis, we reviewed the results of the MM2A
illustrative emissions analysis for the final rule.30 The illustrative emissions analysis examined
the potential for sources in these categories that could reclassify, and the potential impacts on
emissions. The nature of this analysis is such that its serves to help define the selection of source
categories included in this illustrative alternative scenario 2 analysis.
At proposal, we presented this analysis for six source categories to illustrate the costs
some sources may decide to incur to if they opt to reclassify under MM2A. The source
categories evaluated at proposal have been updated and include hydrochloric acid production
(HC1), miscellaneous organic NESHAP (MON), organic liquids distribution (OLD), surface hat
coatings of miscellaneous metal parts, stationary turbines31, metal can, and wood furniture. We
received public comments requesting that we expand our analyses, including the alternative
scenario 2 analysis, to additional source categories. Some commenters expressed that this
illustrative analysis overestimated the potential for emission reductions from source categories,
given that findings from most of the proposed and final Residual Risk and Technology Reviews
(RTRs) have found no control technologies, whether due to technical infeasibility, or found not
to be cost-effective, or available to further reduce HAP emissions.32
29 U.S. EPA, Larry Sorrels, OAQPS/HEID/AEG. Analysis of Illustrative 125% Scenario for MM2A Proposal -
Potential Cost Impacts from HAP Major Sources Reducing Emissions as part of Reclassifying to HAP Area
Sources. EPA Docket No. EPA-HQ-OAR-2019-0282. May, 2019. Available at
https://www.epa.gov/sites/production/files/2Q19-
06/documents/mm2a proposal memorandum cost considerations 125percent scenario final.pdf and in the
docket for this rulemaking.
30 U.S. EPA. MM2A DataSpreadsheet_2020. Available in the docket for this rulemaking.
31 It is noted that the stationary turbines source category is not part of this analysis for the final rule, though this
category was included in the 125 percent scenario analysis at proposal. As described in the MM2A database
memo, the sources in this category could reclassify absent MM2A. Hence, this source category is not included in
this analysis.
32 U.S. EPA. Response to Comment (RTC) Document for MM2A. August 2020.
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To select the source categories for the final rule illustrative analysis, we reviewed the
results of the MM2A database update and facility count by source category under alternative
scenario 2 and the results of the illustrative emissions analysis for the final rule.33 There is a total
of 74 source categories in the MM2A database for which we have detailed RTR modeling file
data to determine which analytical scenarios they belong in. Sorting the MM2A database for
those facilities with actual emissions between the MST and 125 percent of the MST displays 39
source categories - 24 of source categories are in heavy industry and 15 source categories in the
coatings sector.
Then, we removed from consideration for this analysis those source categories for which
we were unable to analyze in the emission impacts analysis due to insufficient information,
specifically, Brick Manufacturing, OSWRO, P&R III, P&R IV (includes 5 categories), Pesticide
Active Ingredients, Pharmaceuticals, and Wood Building Products (see Table 2 of the Illustrative
Emissions memo) and focused on those source categories that might utilize add on control
technologies to reduce emissions further.34 The source categories left that have sources with
emissions between the MST and alternative scenario 2 are listed in Table 4-4.
Table 4-4. Source Categories Considered for Final Rule Illustrative Analysis of
ALTERNATIVE SCENARIO 2
Engine Test Cells/Stands
Petroleum Refineries (2 categories)
Leather Manufacturing
Secondary Aluminum
Marine Tank Vessel Loading
Steel Pickling
Plywood and Composite Wood Products
Wet-Formed Fiberglass
From the list of source categories in Table 4-4, we then determined that Leather
Manufacturing, Petroleum Refineries, Secondary Aluminum, and Wet-Formed Fiberglass would
not change emissions under alternative scenario 2 for reasons provided in the emissions memo
and documentation included in the docket. Therefore, the remaining four source categories
available for this analysis in addition to the source categories included at proposal are: Engine
test cells/stands, marine tank vessel loading, plywood and composite wood products (PCWP),
and steel pickling. According to relevant proposal or final RTRs, there are no add-on control
technologies to further reduce emissions in the Engine test cells/stands, PCWP, and steel
33 U.S. EPA. MM2A DataSpreadsheet_2020. Available in the docket for this rulemaking.
We presume that the coatings categories would rely on reformulations which would be too costly to pursue for
reclassification. However, after reviewing the operating permits for some coatings categories at proposal, we
found that some could reduce emissions and reclassify (i.e., wood furniture).
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pickling source categories.35"36 Thus, of the 8 source categories in Table 4-4 only the marine tank
vessel loading source category was added to the final illustrative alternative Scenario 2 analysis.
Table 4-5 provides a list of the remaining eight source categories and the number of
sources assessed under alternative scenario 2. These sources are in categories where one of more
sources might opt to reclassify under MM2A based on the results of the illustrative emissions
analysis that is included earlier in this RIA. These eight source categories are listed in
descending order of the number of sources eligible to reclassify. In addition, Table 4-5 includes
the amount of emissions change estimated for each source category indicated in the illustrative
emission impact analysis memo. For these eight source categories, all are expected to have HAP
emissions decreases if the facilities were to decide to reclassify.
Table 4-5. List of Source Categories with Sources Having Actual HAP Emissions Between
the PRIMARY SCENARIO and ALTERNATIVE SCENARIO 2
Emissions Change by Source
No. of Sources with Actual
Category Under
Emissions Between the MST and
ALTERNATIVE SCENARIO 2
Source Category
125% of the MST
(Tons Per Year)*
Miscellaneous Metal Parts
48
-79
Wood Furniture
28
-17
Miscellaneous Organic NESHAP(MON)
17
-59
Marine Tank Vessel Loadings
9
-23
Organic Liquid Distribution (OLD)
8
-18
Metal Can
1
-4
HC1 Production
1
-0.7
Wet Form Fiberglass
1
-0.6
*A negative sign denotes an emissions decrease.
We note that these eight source categories contain 113 sources that constitute 21 percent
of 542 major sources across all source categories with sources having emissions between the
primary scenario and alternative scenario 2. These eight source categories thus account for 21
percent of all the sources in the alternative scenario 2 and are listed in descending order of
number of sources in alternative scenario 2.
4.7 Illustrative Potential Cost Analysis Approach
In this illustrative effort, we perform a "break-even" analysis to help inform whether a
source would choose to apply add-on control devices and other control techniques to reduce
35 U.S. EPA. NESHAP: Plywood and Composite Wood Products Residual Risk and Technology Review. Proposal.
81 FR 47092. September 6, 2019. Available on the Internet at https://www. govinfo.gov/content/pkg/FR-2019-
09-06/pdf/2019-18827.pdf.
36 U.S. EPA. MM2A TSM Appendix A. August 2020.
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emissions under alternative scenario 2. We note that the impact on control costs was not a part of
the illustrative emissions analysis; that analysis was based on emissions control
technologies/techniques likely to be already in place on sources, and if non-HAP regulatory
requirements may exist to reduce or prevent the potential for reclassifying (e.g., fabric filters for
particulate matter (PM) control can also control metallic HAP), and other factors as mentioned
earlier in this RIA.
Our illustrative analysis accounts for the findings of technology reviews prepared as part
of recently proposed and promulgated Risk and Technology Reviews (RTRs). If a technology
review for one of the seven source categories listed in Table 4-5 finds that no control
technologies are available for additional control of HAP emissions, then our analysis does not
include any control for this category. With that as a basis, we do not include any HAP control as
part of the analysis of costs related to potential reclassification for the following four source
categories: HC1 production, Surface Coating of Metal Cans, and Miscellaneous Metal Parts. We
find that there are available control technologies and practices for the following four source
categories: MON, Marine Tank Vessel Loading Operations, Organic Liquid Distribution (OLD),
and the Wood Furniture coatings source categories, based on the findings of the technology
review for the final MON RTR,37technical documentation for the Marine Tank Vessel source
category, the final OLD RTR,38 and technical documentation for the Wood Furniture coatings
source category.
This analysis includes the use of HAP control cost-effectiveness (that is, annual cost/ton
HAP reduction) estimates for each of the relevant four source categories. These estimates can
reflect the costs of HAP regulations previously imposed on these source categories, or represent
EPA estimates of likely control options that sources could use to meet HAP emissions limits if
such options exist. These estimates are then used in our approach to examine if sources in these
source categories would apply representative control devices or techniques to reduce HAP
emissions as part of an effort to reclassify. The cost-effectiveness estimates used in this analysis
will include both capital (fixed) and O&M (variable) costs, for there was insufficient information
37 U.S. EPA. NESHAP for Miscellaneous Organic Chemical Manufacturing, Residual Risk and Technology Review.
Proposed Rule. 84 FR 69182. Published on December 17, 2019. Available at
https://www.federalregister.gOv/documents/2019/12/17/2019-24573/national-emission-standards-for-hazardous-
air-pollutants-miscellaneous-organic-chemical. Downloaded on February 18, 2020.
38 U.S. EPA. NESHAP for Organic Liquid Distribution, Residual Risk and Technology Review. Final Rule. Signed
on March 12, 2020. Available in pre-publication form for the Federal Register at https://www epa.gov/stationarv-
sources-air-pollutioii/final-amendments-air-toxics-standards-organic-liauids-distribution. Downloaded on May 5,
2020.
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in the documentation for these estimates to present a breakout of annual costs into these two
components.
We also derived, to the extent possible, cost-effectiveness estimates that do not include
any monitoring, recordkeeping, and reporting costs that are already found in the cost savings
analysis done for these source categories in order to limit double counting. The details of what
are included in these cost-effectiveness estimates are shown in Attachment C of this RIA. We
recognize that findings in the illustrative emissions memo show that the HAP control equipment
in place prior to reclassification continues to be operated after reclassification for a substantial
majority of these sources, which is discussed in more detail in Attachment B of this RIA.39
Hence, with the control costs continuing to be incurred, and thus no expectation that investment
in new or updated control equipment is needed, the most relevant cost for a determination of
what cost value is "break-even" for purposes of this analysis would be the O&M costs.
With this in mind, the financial decision facing a company with a HAP major source
having emissions above the MST and considering the choice of reclassifying to area source
status is whether the reduction in O&M control equipment costs will be sufficient to serve as an
incentive for the company to do so. This reduction in costs would have to be greater than the
costs associated with completing the reclassification process, which would include costs of
paperwork to submit (including meetings and interactions with officials) to the relevant
regulatory agency (state or local) and any opportunity cost to the company such as not pursuing
activities to improve its overall production efficiency from completing the reclassification
process. The company will likely assess the effects of reclassification not only over a short-term,
but long-term, depending on the typical investment life and discount rate (e.g., hurdle rate) that a
company chooses to invoke in its investment decision making. We note that review of the 69
sources that have reclassified indicated these sources continue to use their control equipment for
maintaining major source HAP status after reclassification.
Given the expectation of no change in capital expenditure as mentioned previously, using
these HAP cost-effectiveness estimates therefore could lead to an overstatement of the annual
cost per ton that could serve as a "break-even" value for a source to reduce emissions as part of
reclassifying from major to area source. Again, use of results from this analysis should only be
regarded as illustrative, for they do not reflect results from all, or most, source categories
39 U.S. EPA. Memorandum from Elineth Torres to Docket No. EPA-HQ-OAR-2019-0282. DRAFT Documentation
of the emission impacts analysis for the final rulemaking "Reclassification of Major Sources as Area Sources
under Section 112 of the Clean Air Act." August 2020.
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potentially affected by this final action. Thus, they should not be used to present a complete
analysis across all affected source categories included in the overall analysis, and that includes
control cost impacts for alternative scenario 2.
We also acknowledge that the costs in these estimates may not reflect true marginal costs
in that they presume the average costs of control, which are the types of costs available in the
documentation available to EPA, are suitable for "break-even" decision-making by major
sources considering reclassification.
4.8 Availability of HAP Control Technologies/Practices
We would expect that sources that experience reduced emissions if choosing to reclassify
to apply additional HAP control, either from use of the existing or new control technologies or
techniques, to reduce emissions according to the estimates from the illustrative emissions memo
in order to assure reclassification.
We presume in this analysis that major sources would not choose to apply new controls
that are available for installation but are deemed by the EPA to not be cost-effective in the
context of a proposed or promulgated RTR for the relevant source category. Because a decision
by a major source to reclassify is voluntary, a source could choose to incur control cost for HAP
emission reductions if the source's emissions are above the MST. Such a decision will be made
by the source's parent company based on a variety of factors, including the effect on profitability
and its ability to change its output. Table 4-6 presents the HAP cost-effectiveness estimate used
in this analysis for each of these source categories. All of these cost-effectiveness estimates are
in 2017 dollars in order to be consistent with the year dollars for the annual cost savings
estimates presented in the cost memo and RIA for this final action.
Table 4-6. HAP Cost-effectiveness Estimates for Source Categories with Available
Control Technologies and Practices Included in Illustrative Analysis of
ALTERNATIVE SCENARIO 2
HAP Cost-Effectiveness Estimate (annual cost/ton
Source Category
HAP reduction in 2017$)
Miscellaneous Organic NESHAP (MON)
36,572
Marine Tank Vessel Loading Operations
35,074
Organic Liquid Distribution (OLD)
2,958
Wood Furniture Coatings
33,645
Determination of the appropriate cost-effectiveness for each source category to use in this
analysis is not always a straightforward matter. There are often differences in the extent and
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timing of cost analyses for different source categories, and determination of an appropriate cost-
effectiveness may require more than trivial amounts of analysis in individual circumstances.
Below is a brief discussion of the cost-effectiveness estimates for each category that has
available control technologies and practices and how these estimates are derived.
4.9 Cost-Effectiveness Estimate Derivation for Source Categories
Wood Furniture coatings - The estimate was taken from an EPA cost memorandum
prepared in 2010 to examine HAP control options for facilities subject to the wood furniture
coatings MACT 40 The control option that is the basis for the cost-effectiveness estimate used in
the current analysis is the use of low VOC coatings. The VOC cost-effectiveness estimate for
this option is $15,000/ton; with the amount of VOC that is HAP estimated at one-half, the
resulting HAP cost-effectiveness is $30,000/ton. With this estimate in 2010 dollars, we escalated
the value to 2017 dollars by using the U.S. GDP implicit price deflator. This value is 1.120,
where the 2017 value is 107.789 and the 2010 value is 96. Ill41 Therefore, the cost-effectiveness
in 2017 dollars is $33,645/ton (30,000 * (107.789/96.111)).
Miscellaneous Organic NESHAP (MON)- The estimate was taken from the proposal
RTR Federal Register notice, in which the cost-effectiveness of several control options was
examined. There are two control options that were co-proposed in the RTR and have cost-
effectiveness that ranges from $32,586-$39,206/ton)42 in 2016 dollars. We use the midpoint of
the range to derive a cost-effectiveness for the current analysis of $35,896/ton in 2016 dollars.43
Escalation to 2017 dollars is accomplished the U.S. GDP implicit price deflator. This value is
1.019, where the 2016 value is 105.798 and the 2017 value is 107.789.44 Therefore, the cost-
effectiveness in 2017 dollars is $36,572/ton (35,896 *(107.789/105.798)).
40 U.S. EPA. Memorandum from Kaye Whitfield to Docket No. EPA-HQ-OAR-2010-0786. Cost Analyses for
Control Options. September 27, 2010. Prepared for the Wood Furniture Manufacturing Operations NESHAP,
Final Rule.
41 U.S. Federal Reserve Board, St Louis. Gross Domestic Product (GDP implicit price deflator). Index: 2012-100.
Annual Values. Available at https://fred.stlouisfed.org/series/A191RD3A086NBEA. Downloaded on May 14,
2019.
42 These estimates assume potential excess emission reductions from flares. See the MON RTR for more details.
43 U.S. EPA. Miscellaneous Organic NESHAP (MON), Final Rule. 68 FR 63852. Published in the Federal Register
on November 10, 2003. Available at https://www. govinfo. gov/content/pkg/FR-2003 -11 -10/pdf/03-22310.pdf.
Downloaded on May 14, 2019.
44 U.S. Federal Reserve Board, St. Louis. Gross Domestic Product (GDP implicit price deflator). Index: 2012-100.
Annual Values. Available at https://fred.stlouisfed.org/series/A191RD3A086NBEA. Downloaded on February
19, 2020,.
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Marine Tank Vessel Loading Operations - The estimate was taken from the preamble for
the final Marine Tank Vessel Loading Operation NESHAP published in September, 1995.45 The
estimate is based on the upper bound of estimated control costs ($60 to $100 million annually
nationwide) for this final NESHAP. No other information on costs or cost-effectiveness was
available from actions on this source category since 1995. This cost estimate is $21,906/ton
annually in 1992 dollars. Escalation to 2017 dollars is accomplished the U.S. Gross Domestic
Product (GDP) implicit price deflator. This value is 1.019, where the 1992 value is 67.321 and
the 2017 value is 107.789.46 Therefore, the cost-effectiveness in 2017 dollars is $/ton (21,906
*(107.789/67.321)) = $35,074/ton.
Organic Liquid Distribution (OLD) - The estimate was taken from the national impacts
memorandum for the final OLD RTR.47 The estimate includes the control costs for two types of
control techniques - lowering the vapor pressure threshold at storage tanks, and storage tank
degassing. We do not include other control techniques in this memorandum due to lack of
emission reduction estimates. This cost estimate is $2,903/ton annually in 2016 dollars.
Escalation to 2017 dollars is accomplished the U.S. GDP implicit price deflator. This value is
1.019, where the 2016 value is 105.798 and the 2017 value is 107.789.48 Therefore, the cost-
effectiveness in 2017 dollars is $/ton (2,903 *(107.789/105.798)) = $2,958/ton.
4.10 Results for Potential Cost Impact Analysis Considering the Illustrative Emissions
Analysis
The source categories in Table 4-6 are those included in both the illustrative emissions
analysis, which can be found in the cost memoranda and in the RIA, and this potential cost
analysis. The net change in HAP emissions for these source categories that is expected from
potential classifications is a decrease of 173 tons, with a decrease of 59 tons from the MON
45 Federal Register. U.S. EPA, Federal Standards for Marine Tank Vessel Loading Operations and National
Emission Standards for Hazardous Air Pollutants for Marine Tank Vessel Loading Operations. 60 FR 181.
September 19, 1995. Available at https://www.govinfo.gov/content/pkg/FR-1995-09-19/txlf/95-22725.txlf.
46 U.S. Federal Reserve Board, St. Louis. Gross Domestic Product (GDP implicit price deflator). Index: 2012-100.
Annual Values. Available at https://fred.stlouisfed.org/series/A191RD3A086NBEA. Downloaded on April 23,
2020.
47 ERG to Neil Feinberg, US EPA/OAQPS/SPPD. National Impacts of the 2020 Risk and Technology Review Final
Rule for the Organic Liquids Distribution (Non-Gasoline) Source Category. March 5, 2020. The cost estimate we
prepare here does not include enhanced monitoring for flares and removal of an exemption for control of transfer
racks, for emission reductions were not estimated for these two control techniques due to lack of data.
48 U.S. Federal Reserve Board, St. Louis. Gross Domestic Product (GDP implicit price deflator). Index: 2012-100.
Annual Values. Available at https://fred.stlouisfed.org/series/A191RD3A086NBEA. Downloaded on February
19, 2020.
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source category as the largest change in magnitude.49 It is these emission reductions that are
included in the analysis of potential control costs, calculated as those needed to meet the 75
percent MST (i.e., the primary scenario).
We then conduct an analysis to determine the annual cost to reduce emissions for the four
source categories with potential emissions decreases under alternative scenario 2 according to the
illustrative emissions analysis and having available HAP control technologies to achieve the
emissions decreases. We use cost-effectiveness estimates to calculate a potential annual cost of
control for reducing the emissions increases obtained by the illustrative emissions analysis for
the four source categories that could experience them. The cost-effectiveness estimates are
multiplied by the emissions change for each source category as indicated in Table 4-5 to obtain
the potential annual cost of control for that source category. Table 4-7 shows the potential annual
cost savings under the alternative scenario 2 in 2025 and beyond (the assumed time when all
potential reclassifications have taken place), the potential annual cost of control, and net annual
cost savings for each of these source categories.
Table 4-7. Potential Cost Impacts to HAP Source Categories with Sources Under
ALTERNATIVE SCENARIO 2 and Having Available HAP Control
Technologies or Techniques (2017$)*
Source Category
Annual Cost, $
Savings in 2025
and Beyond
Control
Net Savings
MON
8,053,774
2,160,502
5,809,272
Marine Tank Vessel Loadings
-37,180
806,700
- 843,820
OLD
1,612,570
53,240
1,559,330
Wood Furniture
1,903,678
571,965
1,331,713
* A minus sign denotes a negative number; no sign denotes a positive number. The net annual cost savings = annual
cost savings in 2025 and beyond - annual control costs.
These results show that there are positive net annual cost savings for three of the four
source categories applying control technologies as part of sources reclassifying from major HAP
to area HAP sources. Thus, this illustrative cost analysis suggests there may be some positive
return to sources in these categories that may choose to reclassify under alternative scenario 2, all
things considered.
49 U.S. EPA. Memorandum from Elineth Torres to Docket No. EPA-HQ-OAR-2019-0282. DRAFT Documentation
of the emission impacts analysis for the final rulemaking "Reclassification of Major Sources as Area Sources
under Section 112 of the Clean Air Act." August 2020.
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4.11 Limitations of This Analysis
This analysis of the alternative scenario 2 has three limitations that are important to
mention. First, as we indicate earlier in this memo, the cost-effectiveness estimates derived for
this analysis are likely to be overestimates of the potential cost of control that major HAP
sources at the alternative scenario 2 would incur to reduce emissions for purposes of
reclassifying to area source status for these estimates include capital costs, which may not be a
factor in reclassification decisions according to the review of reclassified major sources done for
this final action. Thus, the results of this "break-even" analysis may understate the potential for
additional emission reductions for reclassification purposes by overstating the "break-even" costs
for these source categories.
Second, we note that the extent of cost escalation in this analysis is often driven by the
vintage of the cost data that is the basis for the cost-effectiveness estimates. The estimate of costs
used for the wood furniture coatings category uses an escalation period is longer than five years.
This is not consistent with the recommendation in the EPA Air Pollution Control Cost Manual
that five years is the preferred duration for cost escalation.50 Given the age of the cost data,
however, we did not have an alternative to convert these costs into 2017 dollars.
Third, we acknowledge that the costs included in these estimates may not reflect true
marginal costs for major sources in that they presume the average costs of control that serve as
the basis for the cost-effectiveness estimates are suitable for "break-even" decision-making by
major sources considering reclassification, while decisions by sources to reduce emissions will
be made based on their marginal costs of control and production on the margin of their
affordability. No marginal cost data is available for HAP control technologies or techniques
applicable to the source categories included in this illustrative analysis.
50 U.S. EPA. EPA Air Pollution Control Cost Manual. Section I, Chapter 2. Cost Estimation: Costs and
Methodology. February I, 2018. Available at https://www.epa.gov/sites/production/files/2017-
12/documents/epaccmcostestimationmethodchapter 7thedition 2017.pdf. p. 19.
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SECTION 5.
BENEFITS/DISBENEFITS
5.1 Introduction
This section describes the human health impacts associated with the final rule. This final
rule may potentially result in both emission reductions and increases from a broad array of
existing sources. As described in Section 4, pollutant emissions that may be affected by the rule
include HAPs; VOCs, which are precursors to both PM2.5 and ozone; SO2, which is a precursor
to PM2.5; NOx, which is a precursor to both PM2.5 and ground-level ozone; organic HAP such as
benzene, ethylbenzene, toluene, and vinyl chloride; and methane, a GHG and a precursor to
ozone formation. As described in the subsequent sections, these pollutants are associated with
substantial health effects, climate effects, and other welfare effects.
Although the illustrative emissions analysis suggests that there may be both emission
increases and decreases from individual source categories, we are uncertain of the magnitude and
geographic distribution of the changes in emissions across the broad array of sources resulting
from this rulemaking, described more fully in Section 4. As such, we are unable to quantify the
changes in emissions across these sources and can neither simulate the change in air quality nor
characterize the impact of these changes. This is not to imply that changes in emissions will not
affect human health or ecological welfare. Rather, our approach reflects the challenges
associated with modeling the direct and indirect impacts of the reductions in emissions for these
sectors with the data currently available.
In place of quantitative estimates of the economic value of the pollutant changes, we
instead characterize these impacts in qualitative terms. In this section, we provide a qualitative
assessment of the health benefits associated with altering exposure to these pollutants and the
visibility impairment and ecosystem benefits.
5.2 PM2.5 Benefits/Disbenefits
This rulemaking may potentially alter directly emitted PM2.5 and/or precursors to PM2.5
including NOx and SO2. Changing these emissions would affect PM2.5 formation, human
exposure to PM2.5, and the incidence of PIVh.s-related health effects. Limits to data, resources,
and methods prevented the EPA from estimating the health impacts and monetized benefits of
the potentially altered PM2.5 concentrations resulting from this final rulemaking. However, we
provide the qualitative discussion below for context regarding potential implications of the final
rule.
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5.2.1 PM2 5 Health Effects
Changing PM2.5 precursors and directly emitted PM2.5 would alter human exposure to
PM2.5 and the incidence of PIVh.s-related health effects. Human health effects of PM2.5 exposure
include mortality and cardiovascular morbidity (U.S. EPA, 20019). More specifically,
researchers have associated PM2.5 exposure with adverse health effects in numerous
toxicological, clinical, and epidemiological studies. These health effects include premature
death; nonfatal heart attacks; irregular heartbeat; aggravated asthma; decreased lung function;
and increased respiratory symptoms, such as irritation of the airways, coughing, and difficulty
breathing (U.S. EPA, 2019). These health effects result in hospital and emergency room visits,
lost workdays, and restricted activity days. When adequate data and resources are available, the
EPA generally quantifies several health effects associated with exposure to PM2.5 {e.g., U.S.
EPA, 2019).
When the EPA quantifies PM2.5-related benefits, the EPA assumes that all fine particles,
regardless of their chemical composition, are equally potent in causing premature mortality
because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by
particle type (U.S. EPA, 2019). Based on our review of the current body of scientific literature,
the EPA estimates PM2.5-related mortality without applying an assumed concentration threshold.
This decision is supported by the data, which are quite consistent in showing effects down to the
lowest measured levels of PM2.5 in the underlying epidemiology studies.
Several significant ecological effects are associated with the deposition of organic
particles, including persistent organic pollutants, and polycyclic aromatic hydrocarbons (PAHs)
(U.S. EPA, 2019). This summary is from Section 6.6.1 of the 2012 PM National Ambient Air
Quality Standards (NAAQS) RIA (U.S. EPA, 2012b).
PAHs can accumulate in sediments and bioaccumulate in freshwater, flora, and fauna.
The uptake of organics depends on the plant species, site of deposition, physical and chemical
properties of the organic compound, and prevailing environmental conditions (U.S. EPA, 2019).
PAHs can accumulate to high enough concentrations in some coastal environments to pose an
environmental health threat that includes cancer in fish populations, toxicity to organisms living
in the sediment, and risks to those (e.g., migratory birds) that consume these organisms.
Atmospheric deposition of particles is thought to be the major source of PAHs to the sediments
of coastal areas of the United States. Deposition of PM to surfaces in urban settings increases the
metal and organic component of storm water runoff. This atmospherically associated pollutant
burden can then be toxic to aquatic biota. The contribution of atmospherically deposited PAHs to
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aquatic food webs was demonstrated in high-elevation mountain lakes with no other
anthropogenic contaminant sources.
The Western Airborne Contaminants Assessment Project is the most comprehensive
database available on contaminant transport and the effects of PM deposition on sensitive
ecosystems in the western United States. (Landers et al., 2008). In this project, the transport, fate,
and ecological impacts of anthropogenic contaminants from atmospheric sources were assessed
from 2002 to 2007 in seven ecosystem components (air, snow, water, sediment, lichen, conifer
needles, and fish) in eight core national parks. The study concluded that bioaccumulation of
semivolatile organic compounds occurred throughout park ecosystems, that an elevational
gradient in PM deposition exists with greater accumulation in higher altitude areas, and that
contaminants accumulate in proximity to individual agriculture and industry sources, which is
counter to the original working hypothesis that most of the contaminants would originate from
Eastern Europe and Asia.
5.2.2 Visibility Effects
Altering directly emitted and secondarily formed PM2.5 could affect visibility throughout
the United States. Fine particles with significant light-extinction efficiencies include sulfates,
nitrates, organic carbon, elemental carbon, and soil (Sisler, 1996). Suspended particles and gases
degrade visibility by scattering and absorbing light. Higher visibility impairment levels in the
East are due to higher concentrations of fine particles, particularly sulfates, and higher average
relative humidity levels. Visibility impairment has a direct impact on people's enjoyment of
daily activities and their overall sense of well-being. Good visibility increases the quality of life
where individuals live and work and where they engage in recreational activities. Previous
analyses (U.S. EPA, 2006b; 2009a; 201 la; 2012b) show that visibility benefits are a significant
welfare benefit category. However, without air quality modeling, we are unable to estimate
visibility-related benefits or disbenefits, nor are we able to determine whether PM2.5 precursor
emissions would likely have a significant impact on visibility in urban areas or Class I areas.
5.3 Ozone Effects
This rulemaking may potentially alter ground-level ozone concentrations. Ozone is not
emitted directly into the air but is created when its two primary components, VOC and NOx,
react in the presence of sunlight. In urban areas, compounds representing all classes of VOCs
and carbon monoxide are important compounds for ozone formation, but VOCs emitted from
vegetation tend to be more important compounds in nonurban vegetated areas (U.S. EPA, 2020).
Therefore, changing these emissions would impact ozone formation, human exposure to ozone,
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and the incidence of ozone-related health effects. However, we have not quantified the ozone-
related benefits in this analysis for several reasons. First, previous rules have shown that the
monetized benefits associated with reducing ozone exposure are generally smaller than PM-
related benefits, even when ozone is the pollutant targeted for control (U.S. EPA, 2010b; 2014a).
Second, the complex nonlinear chemistry of ozone formation introduces uncertainty to the
development and application of a benefit-per-ton estimate, particularly for sectors with
substantial new growth.
Third, the impact of changing VOC emissions is spatially heterogeneous depending on
local air chemistry. Urban areas with a high population concentration are often VOC limited,
which means that ozone is most effectively reduced by lowering VOC emissions. Rural areas
and downwind suburban areas are often NOx limited, which means that ozone concentrations are
most effectively reduced by lowering NOx emissions rather than lowering VOC emissions.
Between these areas, ozone is relatively insensitive to marginal changes in both NOx and VOC.
Because of data limitations such as the location and number of sources affected by this
rulemaking, we did not perform the air quality modeling for this rule needed to quantify the
ozone benefits/disbenefits associated with reducing VOC emissions. Because of the high degree
of variability in the responsiveness of ozone formation to VOC emission reductions and data
limitations regarding the location of the emissions changes, we are unable to estimate the effect
that changing VOC emissions will have on ambient ozone concentrations without air quality
modeling.
5.3.1 Ozone Health Effects
Human exposure to ambient ozone concentrations is associated with adverse health
benefits, including premature death and respiratory morbidity (U.S. EPA, 2010b). Researchers
have associated ozone exposure with adverse health effects in numerous toxicological, clinical,
and epidemiological studies (U.S. EPA, 2020). When adequate data and resources are available,
the EPA generally quantifies several health effects associated with exposure to ozone (e.g., U.S.
EPA, 2010b; 201 la). These health effects include respiratory morbidity, such as asthma attacks;
hospital and emergency department visits; lost school days and premature mortality. The
scientific literature also suggests that exposure to ozone is associated with chronic respiratory
damage and premature aging of the lungs.
5.3.2 Ozone Vegetation Effects
Exposure to ozone is associated with a wide array of vegetation and ecosystem effects in
the published literature (U.S. EPA, 2020). Sensitivity to ozone is highly variable across species,
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with over 66 vegetation species identified as "ozone-sensitive," many of which are found in state
and national parks and forests. These effects include those that damage or impair the intended
use of the plant or ecosystem. Such effects are considered adverse to the public welfare and can
include reduced growth and/or biomass production in sensitive trees, reduced yield and quality of
crops, visible foliar injury, changes to species composition, and changes in ecosystems and
associated ecosystem services.
5.3.3 Ozone Climate Effects
Ozone is a well-known short-lived climate-forcing GHG (U.S. EPA, 2006a).
Stratospheric ozone (the upper ozone layer) is beneficial because it protects life on Earth from
the sun's harmful ultraviolet radiation. In contrast, tropospheric ozone (ozone in the lower
atmosphere) is a harmful air pollutant that adversely affects human health and the environment
and contributes significantly to regional and global climate change. Because of its short
atmospheric lifetime, tropospheric ozone concentrations exhibit large spatial and temporal
variability (U.S. EPA, 2009b). The Intergovernmental Panel on Climate Change Fifth
Assessment Report estimated that the contribution to current warming levels of increased
tropospheric ozone concentrations resulting from human methane, NOx, and VOC emissions was
0.5 W/m2, or about 30 percent as large a warming influence as elevated CO2 concentrations
(IPCC, 2014). This quantifiable influence of ground-level ozone on climate leads to increases in
global surface temperature and changes in hydrological cycles.
5.4 NO2 Health Effects
In addition to being a precursor to PM2.5 and ozone, NOx emissions are linked to a variety
of adverse health effects associated with direct exposure. Following a comprehensive review of
health evidence from epidemiologic and laboratory studies, the Integrated Science Assessment
for Oxides of Nitrogen —Health Criteria (NOx ISA) (U.S. EPA, 2016) concluded that a causal
relationship exists between respiratory health effects and short-term exposure to NO2. These
epidemiologic and experimental studies encompass several endpoints, including emergency
department visits and hospitalizations, respiratory symptoms, airway hyper-responsiveness,
airway inflammation, and lung function. The NOx ISA also concluded that the relationship
between short-term NO2 exposure and premature mortality was "suggestive but not sufficient to
infer a causal relationship" (U.S. EPA, 2016, page 5-343) because it is difficult to attribute the
mortality risk effects to NO2 alone. Although the NOx ISA stated that studies consistently
reported a relationship between NO2 exposure and mortality, the effect was generally smaller
than that for other pollutants such as PM. However, because of methodology and data
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limitations, we were unable to estimate the health co-benefits/disbenefits associated with altered
NO2 emissions or exposure in this final rule.
5.5 SO2 Health Effects
In addition to being a precursor to PM2.5, SO2 emissions are linked to a variety of adverse
health effects associated with direct exposure. We were unable to estimate the health co-benefits
associated with reduced SO2 in this analysis. Therefore, this analysis only provides a qualitative
discussion of the PM2.5 co-benefits associated with the reductions in SO2 emissions.
Following an extensive evaluation of health evidence from epidemiologic and laboratory
studies, the Integrated Science Assessment for Oxides of Sulfur—Health Criteria (SO2 ISA)
concluded that a causal relationship exists between respiratory health effects and short-term
exposure to SO2 (U.S. EPA, 2017). The immediate effect of SO2 on the respiratory system in
humans is bronchoconstriction. Asthmatics are more sensitive to the effects of SO2 likely
resulting from preexisting inflammation associated with this disease. A clear concentration-
response relationship has been demonstrated in laboratory studies following exposures to SO2 at
concentrations between 20 and 100 ppb, both in terms of increasing severity of effect and
percentage of asthmatics adversely affected. Based on our review of this information, we
identified three short-term morbidity endpoints that the SO2 ISA identified as a "causal
relationship": asthma exacerbation, respiratory-related emergency department visits, and
respiratory-related hospitalizations. The differing evidence and associated strength of the
evidence for these different effects are described in detail in the SO2 ISA. The SO2 ISA also
concluded that the relationship between short-term SO2 exposure and premature mortality was
"suggestive of a causal relationship" (U.S. EPA, 2017, page 5-277) because it is difficult to
attribute the mortality risk effects to SO2 alone. Although the SO2 ISA stated that studies are
generally consistent in reporting a relationship between SO2 exposure and mortality, the
observed associations to adjustment for other pollutants lacked robustness. We did not quantify
these co-benefits because of data constraints.
5.6 NO2 and SO2 Health Co-Benefits/Co-Disbenefits
As described in the Integrated Science Assessment for Oxides of Nitrogen and Sulfur—
Ecological Criteria (NOx/SOx ISA) (U.S. EPA, 2008), SO2 and NOx emissions also contribute to
a variety of adverse welfare effects, including those associated with acidic deposition, visibility
impairment, and nutrient enrichment. Deposition of nitrogen causes acidification, which can
cause a loss of biodiversity of fishes, zooplankton, and macroinvertebrates in aquatic
ecosystems, as well as a decline in sensitive tree species, such as red spruce (Picea rubens) and
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sugar maple (Acer saccharum) in terrestrial ecosystems. In the northeastern United States, the
surface waters affected by acidification are a source of food for some recreational and
subsistence fishermen and for other consumers and support several cultural services, including
aesthetic and educational services and recreational fishing. Biological effects of acidification in
terrestrial ecosystems are generally linked to aluminum toxicity, which can cause reduced root
growth, restricting the ability of the plant to take up water and nutrients. These direct effects can,
in turn, increase the sensitivity of these plants to stresses, such as droughts, cold temperatures,
insect pests, and disease, leading to increased mortality of canopy trees. Terrestrial acidification
affects several important ecological services, including declines in habitat for threatened and
endangered species (cultural), declines in forest aesthetics (cultural), declines in forest
productivity (provisioning), and increases in forest soil erosion and reductions in water retention
(cultural and regulating) (U.S. EPA, 2008).
Deposition of nitrogen is also associated with aquatic and terrestrial nutrient enrichment.
In estuarine waters, excess nutrient enrichment can lead to eutrophication. Eutrophication of
estuaries can disrupt an important source of food production, particularly fish and shellfish
production, and a variety of cultural ecosystem services, including water-based recreational and
aesthetic services. Terrestrial nutrient enrichment is associated with changes in the types and
number of species and biodiversity in terrestrial systems. Excessive nitrogen deposition upsets
the balance between native and nonnative plants, changing the ability of an area to support
biodiversity. When the composition of species changes, fire frequency and intensity can also
change, as non-native grasses fuel more frequent and more intense wildfires (U.S. EPA, 2008).
Changes in emissions of NO2 and SO2 would impact the levels of visibility and increases
in emissions would degrade the levels of visibility throughout the United States because these
gases (and the particles of nitrate and sulfate formed from these gases) impair visibility by
scattering and absorbing light (U.S. EPA, 2019). Visibility is also referred to as visual air quality,
and it directly affects people's enjoyment of a variety of daily activities (U.S. EPA, 2019). Good
visibility increases quality of life where individuals live and work and where they travel for
recreational activities, including sites of unique public value, such as the Great Smoky
Mountains National Park (U.S. EPA, 2019).
5.7 Hazardous Air Pollutant (HAP) Health Impacts
Because of methodology and resource limitations, we did not attempt to estimate the
impacts associated with changes in emissions of HAP in this analysis. Instead, we provide a
qualitative analysis of the health effects associated with the various HAP that may be affected by
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this rule. The EPA remains committed to improving methods for estimating HAP
benefits/disbenefits by continuing to explore additional concepts of benefits, including changes
in the distribution of risk. The EPA's Science Advisory Board Health Effects Subcommittee
concluded that "the challenges for assessing progress in health improvement as a result of
reductions in emissions of HAP are daunting ... due to a lack of exposure-response functions,
uncertainties in emissions inventories and background levels, the difficulty of extrapolating risk
estimates to low doses and the challenges of tracking health progress for diseases, such as
cancer, that have long latency "periods" (EPA-SAB, 2008, page i). In 2009, the EPA convened a
workshop to address the inherent complexities, limitations, and uncertainties in current methods
to quantify the benefits of reducing HAP. Recommendations from this workshop included
identifying research priorities, focusing on susceptible and vulnerable populations, and
improving dose-response relationships (Gwinn et al., 2011).
In the subsequent sections, we describe the health effects associated with the main HAP
of concern from the various sectors included in this rulemaking: benzene, ethylbenzene, toluene,
and vinyl chloride. With the data available, it was not possible to estimate the tons of each
individual HAP that would be reduced or increased in response to the final rule.
5.7.1 Benzene
The EPA's Integrated Risk Information System (IRIS) database lists benzene as a known
human carcinogen (causing leukemia) by all routes of exposure and concludes that its exposure
is associated with additional health effects, including genetic changes in both humans and animals,
and increased proliferation of bone marrow cells in mice (U.S. EPA, 2000a; International Agency
for Research on Cancer [IARC], 1982; Irons, Stillman, Colagiovanni, and Henry, 1992). The
EPA states in its IRIS database that data indicate a causal relationship between benzene exposure
and acute lymphocytic leukemia and suggest a relationship between benzene exposure and chronic
nonlymphocytic leukemia and chronic lymphocytic leukemia. IARC has determined that benzene
is a human carcinogen, and the U.S. Department of Health and Human Services has characterized
benzene as a known human carcinogen (IARC, 1987; U.S. Department of Health and Human
Services, 2016).
Several adverse non-cancer health effects, including blood disorders such as preleukemia
and aplastic anemia, have also been associated with long-term exposure to benzene (Aksoy,
1989; Goldstein, 1988).
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5.7.2 Ethylbenzene
Ethylbenzene is a major industrial chemical produced by alkylation of benzene. The pure
chemical is used almost exclusively for styrene production. It is also a constituent of crude
petroleum and is found in gasoline and diesel fuels. Acute (short-term) exposure to ethylbenzene
in humans results in respiratory effects such as throat irritation and chest constriction, irritation
of the eyes and neurological effects such as dizziness. Chronic (long-term) exposure of humans
to ethylbenzene may cause eye and lung irritation, with possible adverse effects on the blood.
Animal studies have reported effects on the blood, liver, kidneys and endocrine system from
chronic inhalation exposure to ethylbenzene. No information is available on the developmental
or reproductive effects of ethylbenzene in humans, but animal studies have reported
developmental effects, including birth defects in animals exposed via inhalation.
Studies in rodents reported increases in the percentage of animals with tumors of the
nasal and oral cavities in male and female rats exposed to ethylbenzene via the oral route
(Maltoni, Conti, Giuliano, andBelpoggi, 1985; Maltoni, Ciliberti, Pinto, Soffritti, Belpoggi, and
Menarini, 1997). The reports of these studies lacked detailed information on the incidence of
specific tumors, statistical analysis, survival data, and information on historical controls; thus,
the results of these studies were considered inconclusive by the IARC (2000) and the National
Toxicology Program (NTP) (1999). The NTP (1999) carried out a chronic inhalation bioassay in
mice and rats and found clear evidence of carcinogenic activity in male rats and some evidence
in female rats, based on increased incidences of renal tubule adenoma or carcinoma in male rats
and renal tubule adenoma in females. NTP (1999) also noted increases in the incidence of
testicular adenoma in male rats. Increased incidences of lung alveolar/bronchiolar adenoma or
carcinoma were observed in male mice and liver hepatocellular adenoma or carcinoma in female
mice, which provided some evidence of carcinogenic activity in male and female mice (NTP,
1999). IARC (2000) classified ethylbenzene as Group 2B, possibly carcinogenic to humans,
based on the NTP studies.
5.7.3 Toluene51
Under the 2005 Guidelines for Carcinogen Risk Assessment, there is inadequate
information to assess the carcinogenic potential of toluene because studies of humans chronically
exposed to toluene are inconclusive, and toluene was not carcinogenic in adequate inhalation
cancer bioassays of rats and mice exposed for life (Chemical Industry Institute of Toxicology
[CUT], 1980; NTP, 1990; Huff, 2003). Increased incidences of mammary cancer and leukemia
51 All health effects language for this section came from U.S. EPA (2005).
157
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were reported in a lifetime rat oral bioassay (Maltoni, Ciliberti, Pinto, el at., 1997); however, this
evidence was considered equivocal because cancers were observed at the low dose tested (500
mg/kg/day) but not at the higher dose tested (800 mg/kg/day). In support of the EPA's cancer
classification, IARC has classified toluene as Group 3 {not classifiable as to its carcinogenicity
in humans) with a supporting statement that there is inadequate evidence in humans and evidence
suggesting a lack of carcinogenicity of toluene in experimental animals (IARC, 1999). The
central nervous system (CNS) is the primary target for toluene toxicity in both humans and
animals for acute and chronic exposures. CNS dysfunction (which is often reversible) and
narcosis have been frequently observed in humans acutely exposed to low or moderate levels of
toluene by inhalation; symptoms include fatigue, sleepiness, headaches, and nausea. CNS
depression has been reported to occur in chronic solvent abusers exposed to high levels of
toluene. Symptoms include ataxia; tremors; cerebral atrophy; nystagmus (involuntary eye
movements); and impaired speech, hearing and vision. Chronic inhalation exposure of humans to
toluene also causes irritation of the upper respiratory tract, eye irritation, dizziness, headaches,
and difficulty with sleep.
Human studies have also reported developmental effects, such as CNS dysfunction,
attention deficits, and minor craniofacial and limb anomalies, in the children of women who
abused toluene during pregnancy. A substantial database exists that examines the effects of
toluene in subchronic and chronic occupationally exposed humans exists. The weight of
evidence from these studies indicates neurological effects {i.e., impaired color vision, impaired
hearing, decreased performance in neurobehavioral analysis, changes in motor and sensory nerve
conduction velocity, headache, and dizziness) as the most sensitive endpoint.
5.7.4 Vinyl Chloride52
Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products.
Acute (short-term) exposure to high levels of vinyl chloride in air has resulted in CNS effects,
such as dizziness, drowsiness and headaches in humans. Chronic (long-term) exposure to vinyl
chloride through inhalation and oral exposure in humans has resulted in liver damage. Cancer is
a major concern from exposure to vinyl chloride via inhalation, because vinyl chloride exposure
has been shown to increase the risk of a rare form of liver cancer in humans. The EPA (2000b)
has classified vinyl chloride as a Group A human carcinogen. IARC (2000) has classified vinyl
chloride as carcinogenic to humans (Group 1).
52 Source for this section is U.S. EPA (2000).
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5.7.5 Other Air Toxics
In addition to the compounds described above, other air toxic compounds might be
potentially affected by this rule. Information regarding the health effects of those compounds can
be found in the EPA's IRIS database.
159
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SECTION 6.
IMPACTS OF REGULATORY RELIEF
This final rulemaking should be viewed as regulatory relief for major sources of HAP
that may be eligible to reclassify as area sources and choose to do so. This RIA illustrates the net
administrative burden costs avoided as a result of this rule. The costs for state permitting
authorities for the issuance of area source permits are also reported. To estimate the net avoided
administrative costs, the EPA estimated the permitting costs to the facilities and the state
agencies, the estimated annual compliance cost savings from not having to comply with major
source NESHAP requirements, and the estimated costs of the area source rule requirements as
mentioned earlier in this RIA.
The EPA also estimated the impacts of avoided cost to sales which are separate estimates
from those of cost savings. The EPA estimated avoided cost-to-sales ratios by comparing the
estimated net avoided cost per facility in the first and fifth years to industry average revenues per
establishment. The EPA also estimated cost-to-sales ratios by comparing net avoided costs to
revenues of establishments at different employment size categories. Small business impacts were
estimated by computing avoided cost-to-sales ratios for small entities using establishment
(facility)-level data given its availability.
6.1 Method for Analyzing Avoided Small Entity Impacts
The EPA used avoided cost-to-sales comparisons to evaluate the potential impacts to
sources affected by this final rule. Because this regulatory action will provide regulatory relief,
these avoided cost-to-sales ratios represent the potential impacts that may be avoided for
facilities as a result of this final rule. For all regulatory actions, to comply with the Regulatory
Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act
(SBREFA) the EPA must determine whether a rule will have a significant economic impact on a
substantial number of small entities. This final rule will provide regulatory relief to affected
sources that choose to reclassify and has positive and small negative impacts on small entities
depending on the analysis year and NAICS code. Because this final rule is expected to yield no
adverse impacts to small entities in year 1 (2021) and no adverse cost impacts to any small
entities in year 5 (2025 - the year by which all reclassifications from major to area sources are
assumed to have taken place) and beyond, the EPA is not required to provide a small entity
analysis. However, the EPA has the discretion to do so. The approach for estimating the avoided
economic impacts and the small entity analysis is the same for this analysis. The steps followed
include gathering data to characterize the affected establishments by employment size categories,
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selecting and describing the measures used in the analysis including cost-to-sales ratios for the
affected sector categories.
If changes in compliance costs, which are key inputs to an economic impact analysis, are
not substantial or are relatively trivial, the impact analysis could consist of a calculation of
annual (or annualized) costs as a percent of sales for affected parent companies. This latter type
of analysis is called a screening analysis and is applied when a partial equilibrium or more
complex economic impact analysis approach is considered to be less appropriate given the
expected limited size of the impacts and available information. Historically EPA has relied on
this method due to data availability issues.
The analysis employed for this final rule is a "sales test" that computes the annualized
compliance costs as a share of sales for each company. With the cost impact of this final rule
being a savings in costs (and, thus, avoided costs), the "sales test" measures the avoided cost of
compliance as a percentage of sales, whether for an affected industry or a company. In this
analysis, data are available by establishment (a place of business) and industry, but not by
company.
The "sales test" is the impact methodology the EPA employs in economic impact
analysis such as this one as opposed to a "profits test," in which annualized compliance costs are
calculated as a share of profits.53 This is because revenues or sales data are commonly available
data for entities normally impacted by EPA regulations and profits data normally made available
are often accounting but not the true economic profits earned by firms due to accounting and tax
considerations. In addition, EPA would need to invoke further assumptions about cost pass
through for both sales and profit tests.
While a "sales test" can provide some insight as to the economic impact of an action such
as this one, it assumes that the impacts of a rule are solely incident on a directly affected firm
(therefore, no impact to consumers of affected product), or solely incident on consumers of
output directly affected by this action (therefore, no impact to companies that are producers of
affected product). Thus, an analysis such as this one is best viewed as providing insight on the
polar examples of economic impacts: maximum impact to either directly affected companies or
their consumers. A "sales test" analysis does not consider shifts in supply and demand curves to
reflect intermediate economic outcomes that are much more likely to occur than polar examples
53 More information on sales and profit tests as used in analyses done by the EPA can be found at
http://www.epa.gov/sbrefa/documents/rfaguidanceli-00-Q6.pdf. pp. 32-33.
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of impacts. Use of partial equilibrium or computable general equilibrium (CGE) economic
impact models such as US EPA's SAGE model will provide more robust analyses of economic
impacts for regulatory actions as appropriate and if data and resources permit their use.54 EPA
recognizes that models such as SAGE will likely require more data but it also recognizes that the
costs associated with data are decreasing. EPA also recognizes that a screening analysis such as a
"sales test" provide limited insights in comparison to models such as SAGE. EPA will evaluate
on a case-by-case basis in the near term the usefulness of SAGE vs. screening analysis tools such
as "sales test" as the agency collects and refines data to operationalize more complete economic
impact assessment tools in order to rely less on screening analysis tools. As stated in the 2017
Science Advisory Board's guidance to US EPA on economy-wide modeling, "a prima facie case
can be made for economy-wide modeling for policies with wide impacts" as long as the size of
impacts are large relative to the precision of the model."55
6.1.1 Identifying A ffected Sectors and Entities
The industrial, commercial, and other sectors covered by the final rule were identified
during the development of the cost analysis for the rule. For these sectors, the affected sources
are summarized with applicable six-digit NAICS codes in Tables 6-1 through 6-3.
6.1.2 Data Used to Characterize Affected Entities by Size
The Census Bureau's 2012 Economic Census data provide national information on the
distribution of economic variables by industry and size.56 Specifically, the tables report data for
each industry on the number of establishments (Table 6-1), employment (Table 6-2), and receipts
(Table 6-3) by enterprise size category in affected sectors. The 2012 Economic Census
definitions in these data elements are as follows:
¦ Establishment. An establishment is a single physical location where business is
conducted and/or services are provided.
54 U.S. EPA, 2019. SAGE stands for SAGE is an Applied General Equilibrium Model. Discussion and
documentation of SAGE can be found at https://www.epa.gov/environmental-economics/cge-modeling-
regulatory-analysis
55 U.S. Environmental Protection Agency, Science Advisory Board (SAB). SAB Advice on the Use of Economy-
Wide Models in Evaluating the Social Costs, Benefits, and Economic Impacts of Air Regulations. September 29,
2017. p. 34. Available on the Internet at
https://vosemite.epa. gov/sab/SABPROPUCT.NSF/0/4B3BAF6C9EA6F503852581AA0057P565/$File/EPA-
SAB-17-012.pdf.
56 The 2012 Economic Census is the most recent version that is complete and publicly available. The 2017
Economic Census started being released in stages from September 2019 and will continue to be released until
December 2021. Because all of the data for the 2017 Economic Census are not yet released, the EPA chose to
use the complete datasets from the 2012 Economic Census. See https://www.census, gov/programs-
survevs/economic-census/news-updates/releases.html for more details.
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¦ Employment. Employment includes all employees at the establishment who worked
or received pay for the part of the pay period including the 12th of the specified
months (March, June, September, and December). Included are employees on paid
sick leave, paid holidays, and paid vacations; not included are proprietors and
partners of unincorporated businesses.
¦ Receipts (varies by NAICS code):
- Revenue: This includes revenue from all business activities whether or not
payment was received in the census year (excluding sales and other taxes
collected from customers and paid directly to a local, state, or federal agency).
(NAICS 22, NAICS 48-49)
- Revenue: This includes revenue from all business activities whether or not
payment was received in the census year, including commissions and fees from
all sources, rents, net investment income, interest, dividends, and royalties.
Revenue from leasing property marketed under operating leases is included. It
also includes the total value of service contracts, amounts received for work
subcontracted to others, and rents from real property sublet to others. It does not
include sales and other taxes collected from customers and paid directly by the
firm to a local, state, or federal tax agency. (NAICS 53)
- Total value of shipments and receipts for services: This item covers the received
or receivable net selling values, f.o.b. plant (exclusive of freight and taxes), of all
products shipped, both primary and secondary, as well as all miscellaneous
receipts. (NAICS 21, NAICS 31-33)
- Receipts: This includes gross receipts from customers or clients for services
provided, from the use of facilities, and from merchandise sold in the census year,
whether or not payment was received in the census year and are net after
deductions for refunds and allowances for merchandise returned by customers. It
excludes sales and other taxes collected directly from customers and paid directly
to a local, state, or federal tax agency. (NAICS 56)
- Receipts/revenue: This includes gross receipts/revenue from customers or clients
for services provided, from the use of facilities, and from merchandise sold in the
census year, whether or not payment was received in the census year. Includes
amounts received from the rental and leasing of vehicles, equipment, instruments,
and tools; the total value of service contracts; market value of compensation
received in lieu of cash; amounts received for work subcontracted to others; and
dues and assessments from members and affiliates. Receipts/revenue from
services performed for foreign parent firms, subsidiaries, and branches included.
(NAICS 54, NAICS 71, NAICS 81)
- Sales: This includes merchandise sold for cash or credit by establishments
primarily engaged in wholesale trade. Net after reductions for refunds and
allowances for merchandise returned by customers. Do not include carrying or
other credit charges; sales and other taxes collected from customers and
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forwarded to taxing authorities; and non-operating income from such sources as
investments, rental or sales of real estate, and interest. (NAICS 41)
Enterprise: An enterprise is a business organization consisting of one or more
domestic establishments that were specified under common ownership or control. The
enterprise and the establishment are the same for single-establishment firms. Each
multi-establishment company forms one enterprise—the enterprise employment and
annual payroll are summed from the associated establishments. Enterprise size
designations are determined by the summed employment of all associated
establishments.
The Small Business Administration (SBA) small business size standard(s) is provided for
each industry group to facilitate comparisons. Our analysis is focused on the establishment level
instead of the firm level because the 2012 Economic Census did not sufficiently report the
relevant data for firm employment size categories. Most but not all establishment employment
size categories were available for number of establishments, employment, and receipts. The
receipt data are reported in 2012 dollars. Therefore, to adjust receipt data for comparison to costs
estimated in 2017 dollars, the EPA used the St. Louis Federal Reserve's Gross Domestic Product
Implicit Price Deflator to adjust 2012 dollars to 2017 dollars.
All receipt and other industry data used in the economic impact analysis can be found in
the Final MM2ARIAdataspreadsheetAugust_2020.xls, a spreadsheet that is available in the
docket for this rulemaking.
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Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Agriculture
Postharvest Crop Activities (except
Cotton Ginning)
115114
$27.5 million
1,062
696
283
78
1
Energy
Crude Petroleum and Natural Gas
Extraction
211111
1250 (Feb 2016 Size Standards)
6,398
5,306
815
234
25
15 3
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size Standards)
337
104
110
28
5
Industrial
Iron Ore Mining
212210
750
21
5
3
3
4
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size Standards)
16
3
5
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size Standards)
39
8
5
11
7
3
Industrial
All Other Metal Ore Mining
212299
750
26
9
7
Industrial
Industrial Sand Mining
212322
500
140
44
62
5
Industrial
Kaolin and Ball Clay Mining
212324
750
30
3
15
6
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
750
25
5
5
Industrial
All Other Nonmetallic Mineral Mining
212399
500
171
60
43
Energy
Support Activities for Oil and Gas
Operations
213112
$38.5 million
9,659
2,895
2,213
573
47
15 4
Utilities
Hydroelectric Power Generation
221111
500
405
342
48
0
Utilities
Fossil Fuel Electric Power Generation
221112
750
1,416
674
466
227
Utilities
Biomass Electric Power Generation
221117
250
107
69
29
0
Utilities
Other Electric Power Generation
221118
250
18
14
4
0
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
Standards)
716
Utilities
Electric Power Distribution
221122
1,000
7,402
4,157
2,420
616
Utilities
Natural Gas Distribution
221210
1,000
2,419
1,564
589
188
Utilities
Water Supply and Irrigation Systems
221310
$27.5 million
4,039
3,496
292
43
Utilities
Sewage Treatment Facilities
221320
$20.5 million
712
597
74
3
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
95
50
42
0
Industrial
Other Animal Food Manufacturing
311119
500
1,391
921
446
23
1
Industrial
Wet Corn Milling
311221
1,250
64
24
23
15
2
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
108
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
42
Industrial
Soybean and Other Oilseed Processing
311224
1,000
150
55
74
21
Industrial
Fats and Oils Refining and Blending
311225
1,000
126
55
37
34
Industrial
Beet Sugar Manufacturing
311313
750
31
1
10
16
4
Industrial
Cane Sugar Manufacturing
311314
1,000
47
14
12
19
2
Industrial
Frozen Fruit, Juice, and Vegetable
Manufacturing
311411
1,000
220
59
63
82
15
1
Industrial
Fruit and Vegetable Canning
311421
1,000
690
380
161
134
14
1
Industrial
Specialty Canning
311422
1,250
112
65
20
19
7
1
Industrial
Cheese Manufacturing
311513
1,250
541
251
156
121
10
3
Industrial
Dry, Condensed, and Evaporated Dairy
Product Manufacturing
311514
750
194
64
82
45
3
(continued)
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Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Rendering and Meat Byproduct
Processing
311613
750
213
89
97
27
Industrial
Commercial Bakeries
311812
1,000
2,672
1,819
517
316
19
1
Industrial
Other Snack Food Manufacturing
311919
1,250
374
203
89
76
5
1
Industrial
Coffee and Tea Manufacturing
311920
750
449
338
72
36
2
1
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1,000
146
81
42
23
Industrial
Spice and Extract Manufacturing
311942
500
373
219
104
47
3
Industrial
All Other Miscellaneous Food
Manufacturing
311999
500
604
401
147
48
7
1
Industrial
Breweries
312120
1,250
874
707
120
28
18
1
Industrial
Distilleries
312140
1,000
251
200
29
22
Industrial
Tobacco Manufacturing
312230
1,500
114
53
30
25
3
3
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
188
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
46
Industrial
Broadwoven Fabric Mills
313210
1,000
328
214
57
51
5
1
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
148
Industrial
Textile and Fabric Finishing Mills
313310
1,000
869
652
162
53
2
Industrial
Broadwoven Fabric Finishing MillsA
313311
1000 (2007 Size Standards)
509
Industrial
Fabric Coating Mills
313320
1,000
183
100
67
16
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
10
Industrial
Leather and Hide Tanning and Finishing
316110
500
198
158
29
11
Industrial
Sawmills
321113
500
2,928
2,154
606
168
Industrial
Wood Preservation
321114
500
421
295
117
9
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
500
240
126
71
43
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
1,250
100
32
28
35
5
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
750
107
69
33
5
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
218
82
77
59
Industrial
Wood Window and Door Manufacturing
321911
1,000
1,139
768
267
95
4
5
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
989
637
307
44
1
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
500
1,752
1,404
323
25
Industrial
Pulp Mills
322110
750
32
4
6
18
4
Industrial
Paper (except Newsprint) Mills
322121
1,250
166
14
35
73
33
11
Industrial
Newsprint Mills
322122
750
17
1
3
12
1
Industrial
Paperboard Mills
322130
1,250
156
9
54
76
16
1
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
1,264
450
503
311
(continued)
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Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Paper Bag and Coated and Treated Paper 322220
750
816
378
280
152
5
1
Manufacturing
Industrial
Coated and Laminated Paper
322222
500 (2007 Size Standards)
463
ManufacturingA
Industrial
Sanitary Paper Product Manufacturing
322291
1,500
142
47
43
42
9
1
Industrial
All Other Converted Paper Product
322299
500
521
296
184
40
1
Manufacturing
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
10,464
Industrial
Commercial Printing (except Screen and
323111
500
20,847
17,281
2,865
660
37
4
Books)
Industrial
Books Printing
323117
1,250
476
330
79
59
6
2
Industrial
Petroleum Refineries
324110
1,500
158
23
18
68
37
12
Industrial
Asphalt Shingle and Coating Materials
324122
750
223
114
83
26
Manufacturing
Industrial
All Other Petroleum and Coal Products
324199
500
110
70
30
10
Manufacturing
Industrial
Petrochemical Manufacturing
325110
1,000
55
16
15
20
4
Industrial
Industrial Gas Manufacturing
325120
1,000
451
315
126
9
1
Industrial
Synthetic Dye and Pigment
325130
1,000
158
83
48
25
2
Manufacturing
Industrial
Inorganic Dye and Pigment
325131
1000 (2007 Size Standards)
80
ManufacturingA
Industrial
Synthetic Organic Dye and Pigment
325132
750 (2007 Size Standards)
78
ManufacturingA
Industrial
Other Basic Inorganic Chemical
325180
1,000
645
336
220
78
7
4
Manufacturing
Industrial
Alkalies and Chlorine Manufacturing"
325181
1000 (2007 Size Standards)
53
Industrial
Carbon Black Manufacturing"
325182
500 (2007 Size Standards)
28
Industrial
All Other Basic Inorganic Chemical
325188
1000 (2007 Size Standards)
564
ManufacturingA
Industrial
Cyclic Crude and Intermediate
325192
750 (2007 Size Standards)
28
ManufacturingA
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
222
43
169
10
Industrial
Cyclic Crude, Intermediate, and Gum
325194
1,250
86
42
25
18
1
and Wood Chemical Manufacturing
Industrial
All Other Basic Organic Chemical
325199
1,250
865
440
282
119
20
3 1
Manufacturing
Industrial
Plastics Material and Resin
325211
1,250
1,144
498
511
123
5
6 1
Manufacturing
Industrial
Synthetic Rubber Manufacturing
325212
1,000
147
75
54
18
Industrial
Artificial and Synthetic Fibers and
325220
1,000
124
49
33
37
4
1
Filaments Manufacturing
On
00
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1000 (2007 Size Standards)
11
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
1000 (2007 Size Standards)
113
Industrial
Nitrogenous Fertilizer Manufacturing
325311
1,000
189
123
50
16
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
78
45
18
12
2
1
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1,000
210
126
50
31
2
1
Industrial
Medicinal and Botanical Manufacturing
325411
1,000
427
245
110
61
8
3
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1,250
1,165
623
295
194
35
12 6
Industrial
Biological Product (except Diagnostic)
Manufacturing
325414
1,250
321
150
97
52
15
6 1
Industrial
Paint and Coating Manufacturing
325510
1,000
1,162
762
312
84
4
Industrial
Adhesive Manufacturing
325520
500
543
292
202
49
Industrial
Surface Active Agent Manufacturing
325613
750
145
81
50
13
1
Industrial
Toilet Preparation Manufacturing
325620
1,250
907
597
189
103
15
3
Industrial
Explosives Manufacturing
325920
750
77
36
21
19
1
Industrial
Custom Compounding of Purchased
Resins
325991
500
452
243
171
37
1
Industrial
Photographic Film, Paper, Plate, and
Chemical Manufacturing
325992
1,500
320
253
43
20
1
2 1
Industrial
All Other Miscellaneous Chemical
Product and Preparation Manufacturing
325998
500
1,163
803
275
80
5
Industrial
Plastics Packaging Film and Sheet
(including Laminated) Manufacturing
326112
1,000
401
118
184
93
5
1
Industrial
Unlaminated Plastics Film and Sheet
(except Packaging) Manufacturing
326113
750
590
268
203
113
5
1
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
406
208
136
61
1
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
474
192
240
42
Industrial
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
326130
500
240
147
64
25
4
Industrial
Polystyrene Foam Product
Manufacturing
326140
1,000
429
184
183
57
4
1
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
650
274
299
76
1
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
394
243
115
36
Industrial
All Other Plastics Product
Manufacturing
326199
750
6,464
3,522
1,995
898
40
9
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Tire Manufacturing (except Retreading)
326211
1,500
111
44
22
18
10
16 1
Industrial
Rubber and Plastics Hoses and Belting
Manufacturing
326220
750
256
123
78
51
4
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
455
215
152
83
5
Industrial
All Other Rubber Product
Manufacturing
326299
500
701
379
243
76
2
1
Industrial
Pottery, Ceramics, and Plumbing Fixture
Manufacturing
327110
1,000
669
558
82
26
2
1
Industrial
Clay Building Material and Refractories
Manufacturing
327120
750
574
278
250
46
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
138
Industrial
Flat Glass Manufacturing
327211
1,000
62
14
15
32
1
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1,250
440
350
55
29
4
2
Industrial
Cement Manufacturing
327310
1,000
241
134
50
57
Industrial
Lime Manufacturing
327410
750
94
43
36
14
1
Industrial
Gypsum Product Manufacturing
327420
1,500
216
124
70
22
Industrial
Abrasive Product Manufacturing
327910
750
303
177
103
20
3
Industrial
Mineral Wool Manufacturing
327993
1,500
271
163
68
38
2
Industrial
All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
327999
500
458
295
144
19
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
406
75
161
123
26
17 4
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size Standards)
380
Industrial
Electrometallurgical Ferroalloy Product
ManufacturingA
331112
750 (2007 Size Standards)
26
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331210
1,000
206
37
90
70
6
3
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
180
99
63
17
1
Industrial
Primary Aluminum ProductionA
331312
1000 (2007 Size Standards)
26
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
45
12
17
9
7
Industrial
Secondary Smelting and Alloying of
Aluminum
331314
750
115
40
61
14
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
104
52
18
22
10
2
Industrial
Aluminum Extruded Product
ManufacturingA
331316
750 (2007 Size Standards)
212
Industrial
Other Aluminum Rolling, Drawing, and
Extruding
331318
750
275
100
85
86
4
Industrial
Nonferrous Metal (except Aluminum)
Smelting and Refining
331410
1,000
207
130
48
24
5
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Primary Smelting and Refining of
CopperA
331411
1000 (2007 Size Standards)
12
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper and
Aluminum)A
331419
750 (2007 Size Standards)
195
Industrial
Copper Rolling, Drawing, Extruding,
and Alloying
331420
1,000
252
86
103
59
3
1
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1000 (2007 Size Standards)
129
Industrial
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and
Extruding
331491
750
310
183
85
35
6
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal (except
Copper and Aluminum)
331492
750
260
146
86
27
1
Industrial
Iron Foundries
331511
1,000
401
152
137
101
10
1
Industrial
Steel Foundries (except Investment)
331513
500
208
97
65
41
4
1
Industrial
Aluminum Die-Casting Foundries'^
331521
500 (2007 Size Standards)
299
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
424
259
121
44
Industrial
Nonferrous Forging
332112
750
61
24
18
15
4
Industrial
Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332119
500
1,501
823
557
117
4
Industrial
Hand and Edge Tool ManufacturingA
332212
500 (2007 Size Standards)
900
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
643
420
160
62
1
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
3,081
1,997
909
170
3
2
Industrial
Metal Window and Door Manufacturing
332321
750
1,081
665
301
104
9
2
Industrial
Sheet Metal Work Manufacturing
332322
500
4,120
2,797
1,139
181
2
1
Industrial
Metal Can Manufacturing
332431
1,500
173
39
50
84
Industrial
Other Metal Container Manufacturing
332439
500
342
204
112
23
3
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
500
826
462
264
96
4
Industrial
Metal Heat Treating
332811
750
815
480
304
30
1
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
2,527
1,814
643
70
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
2,429
1,687
656
84
2
Industrial
Other Fabricated Metal Manufacturing
332990
NA
Industrial
Small Arms Ammunition Manufacturing
332992
1,250
111
87
12
6
2
3 1
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
55
28
7
15
4
1
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
3,737
2,864
738
131
4
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
1,124
724
283
94
14
7 2
Industrial
Lawn and Garden Tractor and Home
Lawn and Garden Equipment
Manufacturing
333112
1,500
155
103
27
14
8
3
Industrial
Construction Machinery Manufacturing
333120
1,250
781
412
259
84
15
10 1
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
298
155
104
36
1
2
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
350
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
225
168
48
9
Industrial
Air-Conditioning and Warm Air Heating
Equipment and Commercial and
Industrial Refrigeration Equipment
Manufacturing
333415
1,250
886
438
236
177
22
13
Industrial
Machine Tool (Metal Cutting Types)
ManufacturingA
333512
500 (2007 Size Standards)
331
Industrial
Machine Tool (Metal Forming Types)
ManufacturingA
333513
500 (2007 Size Standards)
162
Industrial
Turbine and Turbine Generator Set Units
Manufacturing
333611
1,500
183
29
80
54
12
6 2
Industrial
Other Engine Equipment Manufacturing
333618
1,500
331
168
74
68
15
6
Industrial
Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333923
1,250
291
167
86
34
2
2
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
342
237
78
23
4
Industrial
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
334220
1,250
841
530
205
84
9
7 6
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
83
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
562
320
177
62
3
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
862
562
155
97
29
13 6
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
295
197
73
21
3
1
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Blank Magnetic and Optical Recording
Media Manufacturing
334613
1,000
76
64
11
1
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
67
28
17
20
2
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
4
1
1
1
1
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
25
9
6
1
7
2
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
259
137
74
43
4
1
Industrial
Motor and Generator Manufacturing
335312
1,250
469
258
129
74
6
2
Industrial
Storage Battery Manufacturing
335911
1,250
133
52
27
50
3
1
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
418
203
141
68
5
1
Industrial
Noncurrent-Carrying Wiring Device
Manufacturing
335932
1,000
167
78
44
42
1
2
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
155
78
46
30
1
Industrial
Automobile Manufacturing
336111
1,500
185
135
18
7
2
11
12
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
78
45
9
3
3
7
11
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
84
36
14
17
7
9
1
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
754
406
245
91
11
1
Industrial
Truck Trailer Manufacturing
336212
1,000
419
223
130
56
8
2
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
845
619
112
88
23
3
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
107
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
738
Industrial
Motor Vehicle Steering and Suspension
Components (except Spring)
Manufacturing
336330
1,000
249
128
46
62
10
2
1
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
194
84
42
60
6
2
Industrial
Motor Vehicle Transmission and Power
Train Parts Manufacturing
336350
1,500
510
263
112
110
14
10
1
Industrial
Motor Vehicle Seating and Interior Trim
Manufacturing
336360
1,500
403
179
89
111
22
2
Industrial
Motor Vehicle Metal Stamping
336370
1,000
775
249
304
189
25
8
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
1,521
884
325
262
42
8
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
1,448
Industrial
Aircraft Manufacturing
336411
1,500
288
155
52
46
10
9
16
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
468
204
120
121
13
6
4
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
886
505
199
144
25
7
6
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit
Parts Manufacturing
336415
1,250
28
4
5
10
4
5
Industrial
Railroad Rolling Stock Manufacturing
336510
1,500
237
100
81
43
10
2
1
Industrial
Ship Building and Repairing
336611
1,250
697
414
172
82
17
5
7
Industrial
Boat Building
336612
1,000
884
655
152
72
4
1
Industrial
Military Armored Vehicle, Tank, and
Tank Component Manufacturing
336992
1,500
43
7
15
14
5
2
Industrial
Wood Kitchen Cabinet and Countertop
Manufacturing
337110
750
6,839
6,211
516
98
12
2
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
1,229
925
195
83
20
5
1
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
2,425
2,184
186
50
3
2
Industrial
Institutional Furniture Manufacturing
337127
500
718
423
221
73
1
Industrial
Wood Office Furniture Manufacturing
337211
1,000
378
275
68
32
3
Industrial
Office Furniture (except Wood)
Manufacturing
337214
1,000
252
138
62
45
4
2
1
Industrial
Showcase, Partition, Shelving, and
Locker Manufacturing
337215
500
1,100
744
268
84
4
Industrial
Blind and Shade Manufacturing
337920
1,000
357
273
58
23
3
Industrial
Surgical and Medical Instrument
Manufacturing
339112
1,000
1,337
787
296
212
28
13
1
Industrial
Surgical Appliance and Supplies
Manufacturing
339113
750
2,079
1,475
406
171
12
12
3
Industrial
Jewelry and Silverware Manufacturing
339910
500
2,050
1,809
203
34
2
2
Industrial
Sporting and Athletic Goods
Manufacturing
339920
750
1,629
1,312
246
64
4
3
Industrial
Office Supplies (except Paper)
Manufacturing
339940
750
521
416
82
22
1
Industrial
Gasket, Packing, and Sealing Device
Manufacturing
339991
500
567
319
176
66
5
1
Industrial
Burial Casket Manufacturing
339995
1,000
110
81
21
7
1
Industrial
All Other Miscellaneous Manufacturing
339999
500
6,292
5,817
419
51
3
2
Commercial
Grain and Field Bean Merchant
Wholesalers
424510
200
4,889
4,036
549
(continued)
-------
Table 6-1. Number of Establishments by Industry and Enterprise Size: 2012 (continued)
Number of Establishments by Employee Size Categories
20-
100- 500- 1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499 999 2499 >2500
Commercial
Petroleum Bulk Stations and Terminals
424710
200
4,305
3,231
858
Commercial
Scheduled Passenger Air Transportation
481111
1,500
2,231
1,022
636
Commercial
Line-Haul Railroads
482111
1,500
Energy
Pipeline Transportation of Crude Oil
486110
1,500
658
503
129
Energy
Pipeline Transportation of Natural Gas
486210
$27.5 million
2,118
1,717
232
Energy
Pipeline Transportation of Refined
Petroleum Products
486910
1,500
580
496
65
Commercial
Support Activities for Rail
Transportation
488210
$15 million
1,275
847
308
Commercial
Marine Cargo Handling
488320
$38.5 million
460
217
129
Commercial
General Warehousing and Storage
493110
$27.5 million
10,243
5,679
2,660
Commercial
Other Warehousing and Storage
493190
$27.5 million
2,505
1,764
482
Commercial
Lessors of Nonresidential Buildings
(except Mini warehouses)
531120
$27.5 million
34,551
27,668
1,146
Commercial
Testing Laboratories
541380
$15 million
6,613
4,623
1,255
Commercial
Research and Development in the
Physical, Engineering and Life Sciences
(except Nanotechnology and
Biotechnology)^
541715
1,000
Commercial
All Other Support Services
561990
$11 million
12,940
9,657
1,334
Waste
Hazardous Waste Treatment and
562211
$38.5 million
849
527
203
Treatment
Disposal
Waste
Solid Waste Landfill
562212
$38.5 million
1,275
1,004
180
Treatment
Waste
Solid Waste Combustors and
562213
$38.5 million
109
36
56
Treatment
Incinerators
Waste
Remediation Services
562910
$20.5 million
4,070
2,536
854
Treatment
Educational
Colleges, Universities, and Professional
611310
$27.5 million
4,329
1,745
1,011
799 356
Services
Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
442
104
58
Commercial
Linen and Uniform Supply
812330
NA
Commercial
Industrial Launderers
812332
$38.5 million
1,310
461
599
Notes:
Blank cells represent unreported data in the category. N/A represent it is not a valid 2012 NAICS code thus SBA Size Standards is not available. When sub-categories are aggregated to the reported size
categories, we treated unreported data as zero since no establishments were reported in the sub-category. When zero was explicitly reported for a size category, we report zero in the table.
A These source categories have a 2007 NAICS description because they are not defined in the 2012 Census. The 2012 Census provides establishment and revenue data for these source categories on
2007 NAICS basis, as a total figure for all establishments and revenues. It does not provide a breakdown by employment size.
The following NAICS report aggregate data for other top employee size categories and thus are not reported in the table: 115114, 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320,
221330, 424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380, 561990, 562211, 562212, 562213, 562910, 611310, 713110, and 812332.
For the following NAICS, total establishments include establishments which operated entire year and not operated entire year whereas the breakdown into categories is done for establishments operated
entire year: 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320, 221330, 424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380,
561990, 562211, 562212, 562213, 562910, 713110, and 812332.
-------
For NAICS 115114, Post Harvest Crop Activities, the data is from County Business Patterns. Geography Area Series: County Business Patterns by Employment Size Class more information 2012
Business Patterns
332990 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. Also, the size standards for this NAICS code are not available in the 2007, 2016, or 2017 SBA
size standards. There is not even a description of this NAICS code in any of the SBA size standards. It could be a 2002 NAICS code. We found its description as a 2002 NAICS Code in the Survey of
Current Business: Volume 88, Issues 1-6, January 1, 2008, U.S. Department of Commerce
482111 NAICS code (line-haul railroad) is excluded from the Economic Census; therefore, no data are available.
/VA541715 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. Four industries in the 2012 NAICS structure have been expanded for 2017. 541712 - Research
and Development in the Physical, Engineering and Life Sciences (except Biotechnology) has been expanded to include 541713 - Research and Development in Nanotechnology 541715 - Research and
Development in the Physical, Engineering and Life Sciences (except Nanotechnology)
For NAICS 611310, Colleges and Universities the data are from County Business Patterns. Geography Area Series: County Business Patterns by Employment Size Class more information 2012
Business Patterns
812330 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. This code seems to be not a NAICS code but an IRS Statistics of Income (SOI) Program Industry
Code for coding the industrial activities of corporations filing returns (https://www.irs.gov/irm/partl/irm 01-013-007). The SOI codes correspond to NAICS codes such as 812330 corresponds to
812332 Industrial Launderers and 812331 Linen Supply but is a different code.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are governmentpublic administration NAICS codes not covered by
the Census.
NAICS 999999 is an unclassified code and therefore no data is available for it
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, SBA February 2016 Size Standards, SBA 2007 Size Standards.
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Agriculture
Postharvest Crop Activities (except
Cotton Ginning)
115114
$27.5 million
39,759
4,000
13,387
15,393
500-999
Energy
Crude Petroleum and Natural Gas
Extraction
211111
1250 (Feb 2016 Size Standards)
161,685
17,387
35,114
50,386
17,240
21,743 10,000-
24,999
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size Standards)
14,537
1,094
4,989
5,001
3,241
Industrial
Iron Ore Mining
212210
750
6,021
20-99
79
1,208
2,500-4,999
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size Standards)
2,218
26
500-999
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size Standards)
12,555
40-198
100-249
3,127
4,806
2,500-4,999
Industrial
All Other Metal Ore Mining
212299
750
3,824
90
1,902
Industrial
Industrial Sand Mining
212322
500
4,168
492
2,871
736
Industrial
Kaolin and Ball Clay Mining
212324
750
2,405
20-99
603
1,048
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
750
5,109
36
3,739
Industrial
All Other Nonmetallic Mineral Mining
212399
500
2,790
622
1,654
Energy
Support Activities for Oil and Gas
Operations
213112
$38.5 million
323,523
29,106
96,295
114,543
32,014
22,687 10,000-
24,999
Utilities
Hydroelectric Power Generation
221111
500
3,464
1,396
2,051
0
Utilities
Fossil Fuel Electric Power Generation
221112
750
82,071
4,652
20,767
46,503
Utilities
Biomass Electric Power Generation
221117
250
1,424
374
1,025
0
Utilities
Other Electric Power Generation
221118
250
224
43-122
120-348
0
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
Standards)
9,812
Utilities
Electric Power Distribution
221122
1,000
362,844
26,966-
29,465
109,403
123,223
Utilities
Natural Gas Distribution
221210
1,000
83,937
9,854
25,647
36,677
Utilities
Water Supply and Irrigation Systems
221310
$27.5 million
36,352
15,641-
11,268
6,789-
18,140
9,288
Utilities
Sewage Treatment Facilities
221320
$20.5 million
6,849
3,228-
2,835
500-999
3,477
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
2,086
399-478
1,599
0
Industrial
Other Animal Food Manufacturing
311119
500
27,958
6,669-
16,363
3,730
500-999
7,168
Industrial
Wet Corn Milling
311221
1,250
6,606
152-380
976
4,323
1,000-2,499
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
6,504
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
1,319
Industrial
Soybean and Other Oilseed Processing
311224
1,000
7,823
333-482
3,864
3,320-
3,819
Industrial
Fats and Oils Refining and Blending
311225
1,000
9,006
246-404
1,899
6,764
Industrial
Beet Sugar Manufacturing
311313
750
6,367
0-19
541-690
3,687
2,115
Industrial
Cane Sugar Manufacturing
311314
1,000
6,683
50-208
719-798
4,622
1,000-2,499
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
Industrial
Frozen Fruit, Juice, and Vegetable
Manufacturing
311411
1,000
33,766
335-414
3,269
19,480
9,491
1,000-2,499
Industrial
Fruit and Vegetable Canning
311421
1,000
48,840
1,542-
1,791
8,265
28,767
8,899
1,000-2,499
Industrial
Specialty Canning
311422
1,250
11,850
139-237
819
4,567
4,915
1,000-2,499
Industrial
Cheese Manufacturing
311513
1,250
44,374
1,387
8,219
25,325
6,279
3,165
Industrial
Dry, Condensed, and Evaporated Dairy
Product Manufacturing
311514
750
15,701
373-601
4,259
9,357
1,000-2,499
404
Industrial
Rendering and Meat Byproduct
Processing
311613
750
9,065
669
4,614
3,782
Industrial
Commercial Bakeries
311812
1000
115,634
7,403-
8,902
24,584
66,387
12,344
Industrial
Other Snack Food Manufacturing
311919
1250
27,297
911-1,160
4,514
16,961
3,855
1,000-2,499
Industrial
Coffee and Tea Manufacturing
311920
750
15,340
1,180-
1,329
3,096
7,292
1,000-2,499
1,000-2,499
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1000
7,043
418
1,918
4,707
Industrial
Spice and Extract Manufacturing
311942
500
16,417
1,200
5,122
8,389
1,706
Industrial
All Other Miscellaneous Food
Manufacturing
311999
500
23,922
1,892-
2,391
7,185
9,361
4,371
1,000-2,499
Industrial
Breweries
312120
1250
26,336
2,033-
2,781
5,583
5,805
11,471
1,000-2,499
Industrial
Distilleries
312140
1000
6,989
725-874
962-1,211
5,056
Industrial
Tobacco Manufacturing
312230
1500
14,127
60-297
1,416
3,756-
5,255
2,164
5,000-9,999
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
Industrial
Broadwoven Fabric Mills
313210
1000
18,364
919-1,168
2,860
10,248
3,250
1,000-2,499
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
148
Industrial
Textile and Fabric Finishing Mills
313310
1000
22,970
2,931-
3,430
7,518
10,959
1,000-2,499
Industrial
Broadwoven Fabric Finishing MillsA
313311
1000 (2007 Size Standards)
13,442
Industrial
Fabric Coating Mills
313320
1000
6,675
577-726
3,393
2,637-
2,886
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
1,915
Industrial
Leather and Hide Tanning and Finishing
316110
500
3,510
634-1,032
1,017-
1,516
1,565
Industrial
Sawmills
321113
500
64,743
11,078
27,188
26,478
Industrial
Wood Preservation
321114
500
8,061
1,544-
1,793
4,957
1,409-
1,908
Industrial
Hardwood Veneer and Plywood
321211
500
11,734
829
3,454
7,453
>2500
^1
00
2,500-
4,999
Manufacturing
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
1250
13,739
102-260
1,452
9,167
2,500-4,999
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
750
2,854
481-709
1,452
869
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
13,531
455
4,060
9,017
Industrial
Wood Window and Door Manufacturing
321911
1000
46,713
4,492
11,233
20,163
2,358
8,468
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
24,358
4,183
13,175
6,442-
6,941
500-999
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
500
25,547
7,374
13,143
5,031
Industrial
Pulp Mills
322110
750
7,728
0-57
200-498
4,673
2,773
Industrial
Paper (except Newsprint) Mills
322121
1250
60,217
40-217
2,057
19,290
24,560
14,180
Industrial
Newsprint Mills
322122
750
3,573
0-19
40-198
2,746
500-999
Industrial
Paperboard Mills
322130
1250
34,910
20-137
3,444
18,989
11,236
1,000-2,499
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1250
76,372
3,266
28,392
44,714
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
50,481
2,256-
2,754
14,037
29,303
3,094
1,000-2,499
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
25,182
Industrial
Sanitary Paper Product Manufacturing
322291
1500
18,071
268-426
2,265
8,749
5,679
1,000-2,499
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
16,455
1,486-
1,735
7,634
6,614
500-999
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
215,340
Industrial
Commercial Printing (except Screen and
Books)
323111
500
352,659
77,438
124,583
121,445
10,000-
24,999
2,500-4,999
Industrial
Books Printing
323117
1250
24,104
1,365-
1,614
3,708
12,875
3,810
1,000-2,499
Industrial
Petroleum Refineries
324110
1500
62,542
199-278
969
18,775
25,000-
49,999
16,392
Industrial
Asphalt Shingle and Coating Materials
Manufacturing
324122
750
9,094
786-935
4,404
3,816-
4,062
Industrial
All Other Petroleum and Coal Products
Manufacturing
324199
500
3,337
174-402
1,372
1,603-
1,852
Industrial
Petrochemical Manufacturing
325110
1000
8,582
40-217
703
4,894
2,911
Industrial
Industrial Gas Manufacturing
325120
1000
9,723
2,169
5,072
1,668-
2,167
500-999
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1000
9,064
451-679
2,209
5,227
1,000-2,499
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
5,455
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20- 100- 500- 1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Synthetic Organic Dye and Pigment
325132
750 (2007 Size Standards)
3,608
ManufacturingA
Industrial
Other Basic Inorganic Chemical
325180
1000
37,114
2,339
10,514
14,238
5,133
4,893
Manufacturing
Industrial
Alkalies and Chlorine ManufacturingA
325181
1000 (2007 Size Standards)
6,879
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
1,714
Industrial
All Other Basic Inorganic Chemical
325188
1000 (2007 Size Standards)
28,521
ManufacturingA
Industrial
Cyclic Crude and Intermediate
325192
750 (2007 Size Standards)
3,052
ManufacturingA
Industrial
Ethyl Alcohol Manufacturing
325193
1000
10,391
186-414
7,790
2,367
Industrial
Cyclic Crude, Intermediate, and Gum
325194
1250
5,646
196-354
1,265
3,084-
500-999
and Wood Chemical Manufacturing
3,333
Industrial
All Other Basic Organic Chemical
325199
1250
67,751
2,796-
13,802
23,491
12,301
5,526
5,000-
Manufacturing
3,794
9,999
Industrial
Plastics Material and Resin
325211
1250
66,325
3,847-
24,667
23,319
3,477
7,091
2,500-
Manufacturing
4,096
4,999
Industrial
Synthetic Rubber Manufacturing
325212
1000
7,115
424
2,506
4,185
Industrial
Artificial and Synthetic Fibers and
325220
1000
13,664
346-504
1,683
7,779
2,527
1,000-2,499
Filaments Manufacturing
Industrial
Cellulosic Organic Fiber
325221
1000 (2007 Size Standards)
1,455
ManufacturingA
Industrial
Noncellulosic Organic Fiber
325222
1000 (2007 Size Standards)
12,209
ManufacturingA
Industrial
Nitrogenous Fertilizer Manufacturing
325311
1000
5,255
644-793
2,144
2,346-
9 SCK
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
6,582
248-406
605
z, jy j
3,234
1,000-2,499
1,000-2,499
Industrial
Pesticide and Other Agricultural
325320
1000
11,397
722
2,311
6,011
1,000-2,499
1,000-2,499
Chemical Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
1000
27,879
1,238
5,507
10,898
5,116
5,122
Industrial
Pharmaceutical Preparation
325412
1250
147,595
3,648
13,401
49,539
23,501
18,103
39,404
Manufacturing
Industrial
Biological Product (except Diagnostic)
325414
1250
40,485
988-1,286
3,915
12,326
10,490
9,201
2,500-
Manufacturing
4,999
Industrial
Paint and Coating Manufacturing
325510
1000
34,148
4,063-
A S£9
13,530
13,558
2,500-4,999
Industrial
Adhesive Manufacturing
325520
500
19,503
Lt, joz
1,934
9,454
8,116
Industrial
Surface Active Agent Manufacturing
325613
750
5,490
343-571
2,295
2,156-
9 AOS
500-999
Industrial
Toilet Preparation Manufacturing
325620
1250
48,520
2,876
9,175
21,673
10,222
4,575
Industrial
Explosives Manufacturing
325920
750
6,180
265-423
996
4,028
500-999
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Custom Compounding of Purchased
Resins
325991
500
16,938
1,294-
1,543
8,047
7,025
500-999
Industrial
Photographic Film, Paper, Plate, and
Chemical Manufacturing
325992
1500
13,927
992
2,217
4,524
500-999
1,000-2,499
2,500-
4,999
Industrial
All Other Miscellaneous Chemical
Product and Preparation Manufacturing
325998
500
33,681
4,380
12,039
13,821
3,441
Industrial
Plastics Packaging Film and Sheet
(including Laminated) Manufacturing
326112
1000
30,792
970-1,119
9,272
16,430
2,500-4,999
1,000-2,499
Industrial
Unlaminated Plastics Film and Sheet
(except Packaging) Manufacturing
326113
750
36,664
1,471-
1,720
9,927
21,234
2,714
1,000-2,499
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
19,002
1,191-
1,440
6,485
10,691
500-999
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
20,947
1,459
11,652
7,837
Industrial
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
326130
500
10,787
755
3,064
4,443
2,526
Industrial
Polystyrene Foam Product
Manufacturing
326140
1000
24,088
1,246-
1,395
7,922
10,445
2,922
1,000-2,499
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
28,498
1,910-
2,159
13,735
12,220
500-999
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
14,512
1,636
5,416
7,460
Industrial
All Other Plastics Product
Manufacturing
326199
750
328,389
21,785
95,108
173,474
26,783
11,241
Industrial
Tire Manufacturing (except Retreading)
326211
1500
43,197
152-380
824-1,073
3,722-
5,221
7,608
27,203
2,500-
4,999
Industrial
Rubber and Plastics Hoses and Belting
Manufacturing
326220
750
18,748
644-1,042
3,863-
5,362
11,312
2,626
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
28,414
1,499
7,251
16,746
2,919
Industrial
All Other Rubber Product
Manufacturing
326299
500
30,971
2,443
11,264
14,638
1,000-2,499
1,000-2,499
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1000
13,097
2,156
3,670
4,860
1,000-2,499
1,000-2,499
Industrial
Clay Building Material and Refractories
Manufacturing
327120
750
21,273
1,917
11,486
7,870
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
4,389
Industrial
Flat Glass Manufacturing
327211
1000
9,022
53-151
500-998
7,650
500-999
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1250
14,856
1,365-
1,614
2,691
6,018
2,420
1,000-2,499
Industrial
Cement Manufacturing
327310
1000
11,957
671-820
3,230
7,901-
8,150
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
Sector
NAICS Descriptions
NAICS SBA Size Standards (2017)
20-
100-
500-
1000-
Total
<19
99
499
999
2499
4,363
157-315
1,658
1,899
500-999
7,761
558-707
3,964
3,180-
3,429
12,701
1,216
4,668
4,796
2,022
13,950
1,016-
2,965
8,538
1,265
10,728
1,922
5,563
3,245
102,974
620-1,347
7,432-
31,169
18,318
28,579
9,931
99,246
3,728
26,400
290-697
4,731
13,514
3,892
3,909
6,780
531-780
2,978
2,516-
500-999
2,765
6,874
8,818
72-91
792-1,041
2,774
5,103
5,592
214-293
3,162
2,024-
2,273
17,108
137-295
1,132-
4,750
7,788
2,500-4,999
1,281
24,480
545
4,695
16,739
2,501
10,969
668
2,094
4,994
3,215
>2500
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Lime Manufacturing 327410
Gypsum Product Manufacturing 327420
Abrasive Product Manufacturing 327910
Mineral Wool Manufacturing 327993
All Other Miscellaneous Nonmetallic 327999
Mineral Product Manufacturing
Iron and Steel Mills and Ferroalloy 331110
Manufacturing
Iron and Steel MillsA 331111
Electrometallurgical Ferroalloy Product 331112
ManufacturingA
Iron and Steel Pipe and Tube 331210
Manufacturing from Purchased Steel
Rolled Steel Shape Manufacturing 331221
Primary Aluminum Production" 331312
Alumina Refining and Primary 331313
Aluminum Production
Secondary Smelting and Alloying of 331314
Aluminum
Aluminum Sheet, Plate, and Foil 331315
Manufacturing
Aluminum Extruded Product 331316
Manufacturing"
Other Aluminum Rolling, Drawing, and 331318
Extruding
Nonferrous Metal (except Aluminum) 331410
Smelting and Refining
Primary Smelting and Refining of 331411
Copper"
Primary Smelting and Refining of 331419
Nonferrous Metal (except Copper and
Aluminum)"
Copper Rolling, Drawing, Extruding, 331420
and Alloying
Copper Wire (except Mechanical) 331422
Drawing"
Nonferrous Metal (except Copper and 331491
Aluminum) Rolling, Drawing, and
Extruding
750
1500
750
1500
500
1500
1000 (2007 Size Standards)
750 (2007 Size Standards)
1000
1000
1000 (2007 Size Standards)
1000
750
1250
750 (2007 Size Standards)
750
1000
1000 (2007 Size Standards)
750 (2007 Size Standards)
1000
1000 (2007 Size Standards)
750
2,143
8,826
21,378
10,719
17,428
457-685 5,465
854-1,003 4,121
12,010
6,853
2,237
4,163
10,000-
24,999
1,000-2,499
1,000-2,499
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
Sector
NAICS Descriptions
NAICS SBA Size Standards (2017)
Total
<19
20-
99
100-
499
500-
999
1000-
2499
>2500
Industrial
Secondary Smelting, Refining, and
331492
750
10,958
871-1,020
3,974
5,242
500-999
Alloying of Nonferrous Metal (except
Copper and Aluminum)
Industrial
Iron Foundries
331511
1000
38,637
921-1,070
7,305
21,878
7,357
1,000-2,499
Industrial
Steel Foundries (except Investment)
331513
500
17,568
476-774
3,434
9,738
2,675
1,000-2,499
Industrial
Aluminum Die-Casting Foundries"
331521
500 (2007 Size Standards)
23,319
Industrial
Aluminum Foundries (except Die-
331524
500
15,416
1,457
5,616
8,344
Casting)
Industrial
Nonferrous Forging
332112
750
6,964
155-313
906
3,014
2,857
Industrial
Metal Crown, Closure, and Other Metal
332119
500
53,219
5,556
25,435
19,580
2,650
Stamping (except Automotive)
Industrial
Hand and Edge Tool ManufacturingA
332212
500 (2007 Size Standards)
23,342
Industrial
Prefabricated Metal Building and
332311
750
21,712
1,969-
7,496
11,412
500-999
Component Manufacturing
2,218
Industrial
Fabricated Structural Metal
332312
500
87,923
12,523
38,851
30,902
1,000-2,499
2,500-4,999
Manufacturing
Industrial
Metal Window and Door Manufacturing
332321
750
45,665
3,504-
13,957
19,812
5,734
1,000-2,499
Industrial
Sheet Metal Work Manufacturing
332322
500
99,904
4,UU3
19,211
48,064
29,443
1,000-2,499
1,000-2,499
Industrial
Metal Can Manufacturing
332431
1500
17,296
170-328
3,078
13,977
Industrial
Other Metal Container Manufacturing
332439
500
11,789
1,174
5,139
3,790
1,688
Industrial
Bolt, Nut, Screw, Rivet, and Washer
332722
500
36,321
3,108
11,929
18,233
3,052
Manufacturing
Industrial
Metal Heat Treating
332811
750
22,199
4,193-
A /l/IO
12,182
5,096
500-999
Industrial
Metal Coating, Engraving (except
332812
500
49,633
4,44 Z
10,485
27,762
11,386
Jewelry and Silverware), and Allied
Services to Manufacturers
Industrial
Electroplating, Plating, Polishing,
332813
500
52,698
10,394-
27,607
12,700
1,000-2,499
Anodizing, and Coloring
11,893
Industrial
Other Fabricated Metal Manufacturing
332990
NA
Industrial
Small Arms Ammunition
332992
1250
10,413
260-339
350-748
1,379-
1,000-2,499
2,500-4,999
2,500-
Manufacturing
2,878
4,999
Industrial
Ammunition (except Small Arms)
332993
1500
11,003
60-297
120-348
3,469
2,777
2,500-
Manufacturing
4,999
Industrial
All Other Miscellaneous Fabricated
332999
750
70,421
15,423
29,755
22,290
2,954
Metal Product Manufacturing
Industrial
Farm Machinery and Equipment
333111
1250
63,643
3,368-
12,232
21,317
9,796
9,256
5,000-
Manufacturing
5,366
9,999
Industrial
Lawn and Garden Tractor and Home
333112
1500
15,345
300-747
1,408
3,087
5,355
5,000-9,999
Lawn and Garden Equipment
Manufacturing
00
LtJ
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Construction Machinery Manufacturing
333120
1250
62,302
2,342-
2,591
12,265
18,149
9,666
16,753
2,500-
4,999
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
17,280
1,044-
1,193
4,806
8,011
500-999
2,500-4,999
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
7,866
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1000
5,376
704
2,170
2,503
Industrial
Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing
333415
1250
86,110
2,712
11,341
40,169
15,862
16,029
Industrial
Machine Tool (Metal Cutting Types)
ManufacturingA
333512
500 (2007 Size Standards)
16,078
Industrial
Machine Tool (Metal Forming Types)
ManufacturingA
333513
500 (2007 Size Standards)
8,607
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1500
36,955
140-447
4,163
11,246
7,822
7,825
5,000-
9,999
Industrial
Other Engine Equipment Manufacturing
333618
1500
38,195
1,051
3,513
14,321
10,194
9,117
Industrial
Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333923
1250
17,862
1,089
4,121
7,224
1,000-2,499
2,500-4,999
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1250
14,874
1,189
3,516
3,952
6,218
Industrial
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
334220
1250
73,195
2,852
9,519
17,278
5,760
11,163
26,623
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
5,222
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
24,165
1,829
8,601
11,053
2,683
Industrial
Semiconductor and Related Device
Manufacturing
334413
1250
102,570
3,174
7,495
22,441
19,559
19,875
30,027
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
11,199
970-1,219
3,017
3,410
2,055
1,000-2,499
Industrial
Blank Magnetic and Optical Recording
Media Manufacturing
334613
1000
1,207
153-381
404-553
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1250
6,494
140-447
948
4,134
1,000-2,499
Industrial
Household Laundry Equipment
Manufacturing
335224
1250
5,000-
9,999
20-99
500-999
1,000-2,499
2,500-
4,999
Industrial
Other Major Household Appliance
Manufacturing
335228
1000
8,772
20-118
243-392
100-249
5,351
2,500-4,999
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Power, Distribution, and Specialty
335311
750
19,333
522-820
3,696
10,044
2,427
1,000-2,499
Transformer Manufacturing
Industrial
Motor and Generator Manufacturing
335312
1250
31,600
1,499-
1 1A%.
6,006
16,514
4,554
2,500-4,999
Industrial
Storage Battery Manufacturing
335911
1250
20,383
1, Iho
140-447
1,308
11,011
1,805
5,000-
9,999
Industrial
Current-Carrying Wiring Device
335931
500
25,909
1,244-
6,924
12,856
3,305
1,000-2,499
Manufacturing
1,393
Industrial
Noncurrent-Carrying Wiring Device
335932
1000
14,237
453
2,488
8,275
500-999
1,000-2,499
Manufacturing
Industrial
Carbon and Graphite Product
335991
750
8,992
429-508
2,201
5,694
500-999
Manufacturing
Industrial
Automobile Manufacturing
336111
1500
69,285
521
937
1,061-
i n^n
1,000-2,499
19,113
46,033
Industrial
Light Truck and Utility Vehicle
336112
1500
58,658
125-283
472
j,UOU
328
1,000-2,499
14,317
41,216
Manufacturing
Industrial
Heavy Duty Truck Manufacturing
336120
1500
29,275
120-367
350-748
3,531
4,406
15,708
2,500-
4,999
Industrial
Motor Vehicle Body Manufacturing
336211
1000
41,176
2,611-
-2110
11,016
18,841
7,406
1,000-2,499
Industrial
Truck Trailer Manufacturing
336212
1000
27,670
J, 11U
1,338-
1 ^87
6,166
11,603
5,511
2,500-4,999
Industrial
Motor Vehicle Gasoline Engine and
336310
1000
48,566
1, JO /
2,530
4,977
20,618
17,236
3,207
Engine Parts Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and
336311
500 (2007 Size Standards)
Valve ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
750 (2007 Size Standards)
ManufacturingA
Industrial
Motor Vehicle Steering and Suspension
336330
1000
29,282
752
2,154
13,432
6,893
1,000-2,499
2,500-
Components (except Spring)
4,999
Manufacturing
Industrial
Motor Vehicle Brake System
336340
1250
23,130
401-550
2,165
13,657
4,048
2,500-4,999
Manufacturing
Industrial
Motor Vehicle Transmission and Power
336350
1500
59,908
1,197-
5,330
24,750
9,868
16,054
2,500-
Train Parts Manufacturing
1,446
4,999
Industrial
Motor Vehicle Seating and Interior Trim 336360
1500
50,452
922-1,071
4,809
27,116
14,670
2,500-4,999
Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1000
83,680
1,970
15,545
39,713
15,601
10,851
Industrial
Other Motor Vehicle Parts
336390
1000
120,977
4,873
16,215
60,297
29,019
10,575
Manufacturing
Industrial
All Other Motor Vehicle Parts
336399
750 (2007 Size Standards)
ManufacturingA
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Aircraft Manufacturing
336411
1500
171,749
910
2,099
10,481
6,565
13,127
138,569
Industrial
Aircraft Engine and Engine Parts
336412
1500
79,125
1,204
5,377
26,809
8,537
8,624
28,575
Manufacturing
Industrial
Other Aircraft Parts and Auxiliary
336413
1250
106,935
3,024
10,114
32,132
16,828
12,271
32,567
Equipment Manufacturing
Industrial
Guided Missile and Space Vehicle
336415
1250
12,530
5-24
120-348
1,798-
2,165
8,035
Propulsion Unit and Propulsion Unit
2,297
Parts Manufacturing
Industrial
Railroad Rolling Stock Manufacturing
336510
1500
28,372
733
3,624
9,204
6,638
2,500-4,999
2,500-
A QQQ
Industrial
Ship Building and Repairing
336611
1250
105,192
2,370
8,026
18,580
10,784
7,483
57,949
Industrial
Boat Building
336612
1000
28,081
2,873-
6,480
15,021
2,365
1,000-2,499
Industrial
Military Armored Vehicle, Tank, and
336992
1500
9,956
J,J IA
20-137
612-861
2,817
3,830
2,500-4,999
Tank Component Manufacturing
Industrial
Wood Kitchen Cabinet and Countertop
337110
750
77,649
24,676-
20,020
20,707
7,864
2,500-4,999
Manufacturing
29,675
Industrial
Upholstered Household Furniture
337121
1000
55,557
4,476-
9,189
17,217
13,803
7,180
2,500-
Manufacturing
5,975
4,999
Industrial
Nonupholstered Wood Household
337122
750
31,423
8,834
7,605
9,791
1,000-2,499
2,500-4,999
Furniture Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
500
26,119
2,549-
1 7Q8
9,874
12,619
500-999
Industrial
Wood Office Furniture Manufacturing
337211
1000
13,774
Z, /70
1,358-
1 £«T7
3,225
6,913
1,000-2,499
Industrial
Office Furniture (except Wood)
337214
1000
22,528
l,OU /
513-811
2,611
9,414
3,122
2,500-4,999
2,500-
Manufacturing
4,999
Industrial
Showcase, Partition, Shelving, and
337215
500
33,357
4,006
12,039
14,824
2,490
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1000
11,569
1,359
2,526
5,711
1,974
Industrial
Surgical and Medical Instrument
339112
1000
105,419
4,053-
14,278
46,482
18,851
18,966
2,500-
Manufacturing
7,051
4,999
Industrial
Surgical Appliance and Supplies
339113
750
99,091
7,089-
18,583
36,930
7,680
17,484
10,000-
Manufacturing
8,588
24,999
Industrial
Jewelry and Silverware Manufacturing
339910
500
26,026
6,835
8,379
6,720
1,000-2,499
2,500-4,999
Industrial
Sporting and Athletic Goods
339920
750
36,968
5,960
11,001
12,751
2,674
4,582
Manufacturing
Industrial
Office Supplies (except Paper)
339940
750
10,517
1,739-
3,700
4,143
500-999
Manufacturing
1,988
Industrial
Gasket, Packing, and Sealing Device
339991
500
29,140
2,253-
8,355
14,382
2,904
1,000-2,499
Manufacturing
2,502
(continued)
-------
Table 6-2. Number of Employees by Industry and Enterprise Size: 2012 (continued)
Number of Employees by Employee Size Categories
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
20-
99
100- 500- 1000-
499 999 2499
Industrial
Burial Casket Manufacturing
339995
1000
3,751
467-616
945
1,157- 500-999
Industrial
All Other Miscellaneous Manufacturing
339999
500
53,872
23,152
15,197
1,0 JO
9,848 1,000-2,499 2,500-4,999
Commercial
Grain and Field Bean Merchant
424510
200
49,603
25,751
18,933
Wholesalers
Commercial
Petroleum Bulk Stations and Terminals
424710
200
73,309
22,824
31,690
Commercial
Scheduled Passenger Air Transportation
481111
1500
398,335
7,029-
7
28,440
Commercial
Line-Haul Railroads
482111
1500
/,jZO
Energy
Pipeline Transportation of Crude Oil
486110
1500
11,299
3,107
5,050
Energy
Pipeline Transportation of Natural Gas
486210
$27.5 million
29,597
10,539
8,368
Energy
Pipeline Transportation of Refined
486910
1500
6,233
2,442-
1,500-
Petroleum Products
3,589
3,498
Commercial
Support Activities for Rail
488210
$15 million
32,100
5,751
12,738
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
53,313
1,414
5,845
Commercial
General Warehousing and Storage
493110
$27.5 million
599,384
39,356
117,612
Commercial
Other Warehousing and Storage
493190
$27.5 million
66,767
10,255-
15,087-
14,253
20,086
Commercial
Lessors of Nonresidential Buildings
531120
$27.5 million
170,381
92,430
40,932
(except Miniwarehouses)
Commercial
Testing Laboratories
541380
$15 million
115,018
28,410
50,663
Commercial
Research and Development in the
541715
1000
Physical, Engineering and Life Sciences
(except Nanotechnology and
Biotechnology)^
Commercial
All Other Support Services
561990
$11 million
148,019
45,598
53,251
Waste Treatment
Hazardous Waste Treatment and
562211
$38.5 million
27,782
3,566
8,810
Disposal
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
16,209
6,678
6,332
Waste Treatment
Solid Waste Combustors and
562213
$38.5 million
4,784
243-322
2,816
Incinerators
Waste Treatment
Remediation Services
562910
$20.5 million
78,027
17,113
34,649
Educational Services
Colleges, Universities, and Professional
611310
$27.5 million
1,805,199
10,711
49,461
194,356 256,266
Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
116,148
619
2,777
Commercial
Linen and Uniform Supply
812330
NA
Commercial
Industrial Launderers
812332
$38.5 million
60,452
3,886
28,406
Notes:
Blank cells represent unreported data in the category. NA means it is not a valid 2012 NAICS code thus an SBA Size Standard is not available. When sub-categories are aggregated to the reported size
categories, we treated unreported data as zero since no employment was reported in the sub-category. When zero was explicitly reported for a size category, we report zero in the table.
A These source categories have a 2007 NAICS description because they are not defined in the 2012 Census. The 2012 Census provides establishment and revenue data for these source categories on
2007 NAICS basis, as a total figure for all establishments and revenues. It does not provide a breakdown by employment size.
-------
The following NAICS report aggregate data for other top employee size categories and thus are not reported in the table: 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320, 221330,
424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380, 561990, 562211, 562212, 562213, 562910, 713110, and 812332.
For the following NAICS, total receipts include establishments that operated the entire year and not operated the entire year, whereas the breakdown into categories is done for establishments operated
the entire year: 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320, 221330, 424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380,
561990, 562211, 562212, 562213, 562910, 713110, and 812332.
For NAICS 115114, Post harvest Crop Activities, the data are from County Business Patterns, but there are no revenue data. Geography Area Series: County Business Patterns by Employment Size
Class more information 2012 Business Patterns.
332990 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. Also, the size standards for this NAICS code are not available in the 2007, 2016, or 2017 SBA
Size Standards. There is not even a description of this NAICS code in any of the SBA Size Standards. It could be a 2002 NAICS code. We found its description as a 2002 NAICS Code in the Survey of
Current Business: Volume 88, Issues 1-6, January 1, 2008, U.S. Department of Commerce.
482111 NAICS code (line-haul railroad) is excluded from the Economic Census; therefore, no data are available.
541715 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. Four industries in the 2012 NAICS structure have been expanded for 2017. 541712—Research
and Development in the Physical, Engineering and Life Sciences (except Biotechnology) has been expanded to include 541713 - Research and Development in Nanotechnology 541715—Research and
Development in the Physical, Engineering and Life Sciences (except Nanotechnology).
812330 is not a valid 2012 NAICS code; therefore, no data are available in the 2012 Economic Census. This code seems to be not a NAICS code but an IRS SOI Program Industry Code for coding the
industrial activities of corporations filing returns (https://www.irs.gov/irm/part 1 /irm 01-013-007). The SOI codes correspond to NAICS codes such as 812330 corresponds to 812332 Industrial
Launderers and 812331 Linen Supply but is a different code.
For NAICS 611310, Colleges and Universities establishment and employment data are from County Business Patterns but there are no revenue data. Geography Area Series: County Business Patterns
by Employment Size Class more information 2012 Business Patterns.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census.
NAICS 999999 is an unclassified code and therefore no data are available for it.
Sources: 2012 Economic Census, 2017 SBA Size Standards, SBA February 2016 Size Standards, SBA 2007 Size Standards, Federal Reserve Bank of St. Louis Economic Research.
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Agriculture
Postharvest Crop Activities (except
Cotton Ginning)
115114
$27.5 million
Energy
Crude Petroleum and Natural Gas
Extraction
211111
1250 (Feb 2016 Size Standards)
292,272
D
72,875
81,714
58,538
37,553 D
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size Standards)
42,913
6,602
17,760
11,674
6,004
Industrial
Iron Ore Mining
212210
750
5,141
D
45
1,082
D
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size Standards)
1,812
D
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size Standards)
11,581
D
D
D
3,732
D
Industrial
All Other Metal Ore Mining
212299
750
1,648
D
758
Industrial
Industrial Sand Mining
212322
500
1,868
191
1,239
410
Industrial
Kaolin and Ball Clay Mining
212324
750
919
D
197
490
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
750
3,129
D
2,163
Industrial
All Other Nonmetallic Mineral Mining
212399
500
759
D
374
Energy
Support Activities for Oil and Gas
Operations
213112
$38.5 million
91,396
6,440
21,676
28,626
11,158
12,782 D
Utilities
Hydroelectric Power Generation
221111
500
2,643
Q
Q
Q
Utilities
Fossil Fuel Electric Power Generation
221112
750
87,821
Q
Q
Q
Utilities
Biomass Electric Power Generation
221117
250
778
Q
Q
Q
Utilities
Other Electric Power Generation
221118
250
47
Q
Q
Q
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
Standards)
7,795
Utilities
Electric Power Distribution
221122
1,000
323,472
Q
Q
Q
Utilities
Natural Gas Distribution
221210
1,000
96,546
Q
Q
Q
Utilities
Water Supply and Irrigation Systems
221310
$27.5 million
10,173
Q
Q
Q
Utilities
Sewage Treatment Facilities
221320
$20.5 million
1,484
Q
Q
Q
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
1,540
Q
Q
Q
Industrial
Other Animal Food Manufacturing
311119
500
39,196
D
22,711
D
D
Industrial
Wet Corn Milling
311221
1,250
13,996
D
1,529
9,918
D
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
40,769
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
2,880
Industrial
Soybean and Other Oilseed Processing
311224
1,000
43,649
D
25,313
D
Industrial
Fats and Oils Refining and Blending
311225
1,000
18,069
D
5,258
D
Industrial
Beet Sugar Manufacturing
311313
750
5,018
D
D
D
1,489
Industrial
Cane Sugar Manufacturing
311314
1,000
6,358
D
D
4,396
D
Industrial
Frozen Fruit, Juice, and Vegetable
Manufacturing
311411
1,000
13,130
D
D
7,245
D
D
Industrial
Fruit and Vegetable Canning
311421
1,000
25,361
D
3,850
15,598
D
D
Industrial
Specialty Canning
311422
1,250
10,240
D
D
D
4,108
D
Industrial
Cheese Manufacturing
311513
1,250
44,453
1,162
7,384
27,805
4,691
3,411
Industrial
Dry, Condensed, and Evaporated Dairy
Product Manufacturing
311514
750
21,054
D
4,664
12,803
D
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Rendering and Meat Byproduct
Processing
311613
750
5,699
D
2,771
2,334
Industrial
Commercial Bakeries
311812
1000
30,302
D
4,994
19,787
3,000
D
Industrial
Other Snack Food Manufacturing
311919
1250
22,227
D
1,545
18,227
D
D
Industrial
Coffee and Tea Manufacturing
311920
750
14,220
D
1,818
10,851
D
D
Industrial
Flavoring Syrup and Concentrate
Manufacturing
311930
1000
9,433
D
D
8,062
Industrial
Spice and Extract Manufacturing
311942
500
9,870
D
2,716
4,456
D
Industrial
All Other Miscellaneous Food
Manufacturing
311999
500
12,383
D
4,099
4,855
2,149
D
Industrial
Breweries
312120
1250
30,610
D
1,895
D
D
D
Industrial
Distilleries
312140
1000
10,367
D
D
D
Industrial
Tobacco Manufacturing
312230
1500
43,314
D
D
9,129
1,513
D
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
4,616
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
307
Industrial
Broadwoven Fabric Mills
313210
1000
4,672
D
713
2,729
738
D
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
1,011
Industrial
Textile and Fabric Finishing Mills
313310
1000
5,595
D
2,018
2,685
D
Industrial
Broadwoven Fabric Finishing MillsA
313311
1000 (2007 Size Standards)
3,643
Industrial
Fabric Coating Mills
313320
1000
2,489
D
1,277
D
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
875
Industrial
Leather and Hide Tanning and Finishing
316110
500
1,657
D
855
671
Industrial
Sawmills
321113
500
20,249
3,025
8,166
9,058
Industrial
Wood Preservation
321114
500
4,619
D
3,055
D
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
500
2,730
D
D
1,924
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
1250
4,550
D
D
2,936
939
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
750
972
D
D
343
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
6,862
D
D
5,184
Industrial
Wood Window and Door Manufacturing
321911
1000
9,913
D
D
4,700
D
D
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
6,445
991
3,600
D
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
500
5,466
1,285
3,065
1,115
Industrial
Pulp Mills
322110
750
6,451
D
D
3,838
2,441
Industrial
Paper (except Newsprint) Mills
322121
1250
47,457
D
D
15,266
18,226
12,621
Industrial
Newsprint Mills
322122
750
2,932
D
D
D
Industrial
Paperboard Mills
322130
1250
30,657
D
D
17,864
9,567
D
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1250
36,222
1,543
12,946
21,733
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
22,964
D
5,813
12,525
2,381
D
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
13,815
Industrial
Sanitary Paper Product Manufacturing
322291
1500
13,124
D
D
6,124
5,324
D
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
5,613
D
2,848
D
D
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
42,665
Industrial
Commercial Printing (except Screen and 323111
500
72,756
D
24,416
29,510
6,365
D
Books)
Industrial
Books Printing
323117
1250
4,564
D
D
2,661
613
D
Industrial
Petroleum Refineries
324110
1500
864,374
D
4,873
231,700
D
239,731
Industrial
Asphalt Shingle and Coating Materials
Manufacturing
324122
750
11,598
D
5,210
D
Industrial
All Other Petroleum and Coal Products
Manufacturing
324199
500
5,738
D
2,592
D
Industrial
Petrochemical Manufacturing
325110
1000
88,787
D
D
40,756
D
Industrial
Industrial Gas Manufacturing
325120
1000
7,945
2,221
3,120
D
D
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1000
9,807
D
1,613
4,666
D
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
7,312
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
750 (2007 Size Standards)
2,495
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1000
37,355
D
11,636
14,834
3,021
D
Industrial
Alkalies and Chlorine ManufacturingA
325181
1000 (2007 Size Standards)
8,717
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
2,543
Industrial
All Other Basic Inorganic Chemical
ManufacturingA
325188
1000 (2007 Size Standards)
26,095
Industrial
Cyclic Crude and Intermediate
ManufacturingA
325192
750 (2007 Size Standards)
7,703
Industrial
Ethyl Alcohol Manufacturing
325193
1000
45,971
D
32,610
11,985
Industrial
Cyclic Crude, Intermediate, and Gum
and Wood Chemical Manufacturing
325194
1250
10,222
D
1,136
5,905
D
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
1250
97,385
D
17,696
37,788
30,610
3,784 D
Industrial
Plastics Material and Resin
Manufacturing
325211
1250
98,652
D
23,032
43,892
6,868
15,848 D
Industrial
Synthetic Rubber Manufacturing
325212
1000
10,089
D
2,952
D
293
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
1000
9,302
D
788
5,541
2,281
D
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1000 (2007 Size Standards)
1,855
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
1000 (2007 Size Standards)
7,447
Industrial
Nitrogenous Fertilizer Manufacturing
325311
1000
10,233
D
2,880
D
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
12,552
D
D
D
D
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1000
16,358
D
3,095
8,773
D
D
Industrial
Medicinal and Botanical Manufacturing
325411
1000
13,564
D
1,976
5,845
4,221
D
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1250
147,083
D
D
66,479
20,657
17,420 D
Industrial
Biological Product (except Diagnostic)
Manufacturing
325414
1250
29,202
D
D
7,733
9,223
7,857 D
Industrial
Paint and Coating Manufacturing
325510
1000
25,949
D
9,755
11,835
D
Industrial
Adhesive Manufacturing
325520
500
13,051
1,272
6,627
5,153
Industrial
Surface Active Agent Manufacturing
325613
750
12,609
D
3,004
D
Industrial
Toilet Preparation Manufacturing
325620
1250
43,626
1,033
4,305
19,248
16,556
2,484
Industrial
Explosives Manufacturing
325920
750
2,299
D
D
D
Industrial
Custom Compounding of Purchased
Resins
325991
500
11,122
D
4,972
4,863
D
Industrial
Photographic Film, Paper, Plate, and
Chemical Manufacturing
325992
1500
9,412
D
916
3,406
D
D D
Industrial
All Other Miscellaneous Chemical
Product and Preparation Manufacturing
325998
500
21,827
2,609
8,428
9,395
1,396
Industrial
Plastics Packaging Film and Sheet
(including Laminated) Manufacturing
326112
1000
13,766
385
3,960
7,653
D
D
Industrial
Unlaminated Plastics Film and Sheet
(except Packaging) Manufacturing
326113
750
18,947
D
4,550
11,143
1,530
D
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
6,630
D
1,689
3,633
D
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
9,913
871
6,184
2,858
Industrial
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
326130
500
3,802
D
1,066
D
Industrial
Polystyrene Foam Product
Manufacturing
326140
1000
9,323
D
3,053
4,064
1,230
D
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
10,265
D
5,642
3,620
D
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
3,193
D
1,146
D
D
Industrial
All Other Plastics Product
Manufacturing
326199
750
87,360
5,488
23,573
47,208
8,298
2,792
Industrial
Tire Manufacturing (except Retreading)
326211
1500
21,817
D
D
2,756
5,183
11,937 D
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Rubber and Plastics Hoses and Belting
Manufacturing
326220
750
5,651
D
D
3,621
613
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
8,065
D
D
4,769
1,426
Industrial
All Other Rubber Product
Manufacturing
326299
500
11,860
781
3,657
5,241
D
D
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1000
2,322
D
583
1,061
D
D
Industrial
Clay Building Material and Refractories
Manufacturing
327120
750
5,536
467
2,681
2,388
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
1,348
Industrial
Flat Glass Manufacturing
327211
1000
3,411
D
D
D
D
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1250
3,955
D
D
D
605
D
Industrial
Cement Manufacturing
327310
1000
6,354
D
D
D
Industrial
Lime Manufacturing
327410
750
2,539
D
D
D
Industrial
Gypsum Product Manufacturing
327420
1500
3,972
D
2,232
D
Industrial
Abrasive Product Manufacturing
327910
750
5,815
414
1,677
2,164
1,561
Industrial
Mineral Wool Manufacturing
327993
1500
5,242
D
974
3,514
D
Industrial
All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
327999
500
4,454
D
2,353
D
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1500
121,366
D
D
37,945
27,761
29,819 D
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size Standards)
118,560
Industrial
Electrometallurgical Ferroalloy Product
ManufacturingA
331112
750 (2007 Size Standards)
2,806
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331210
1000
15,851
190
2,708
7,718
2,604
2,631
Industrial
Rolled Steel Shape Manufacturing
331221
1000
6,018
D
2,307
D
D
Industrial
Primary Aluminum ProductionA
331312
1000 (2007 Size Standards)
5,461
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1000
7,001
D
789
2,216
3,968
Industrial
Secondary Smelting and Alloying of
Aluminum
331314
750
6,243
D
3,210
D
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1250
17,309
D
D
4,159
9,485
D
Industrial
Aluminum Extruded Product
ManufacturingA
331316
750 (2007 Size Standards)
8,608
Industrial
Other Aluminum Rolling, Drawing, and
Extruding
331318
750
10,032
D
D
6,913
D
Industrial
Nonferrous Metal (except Aluminum)
Smelting and Refining
331410
1000
16,509
D
3,384
D
3,103
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499 >2500
Industrial
Primary Smelting and Refining of
CopperA
331411
1000 (2007 Size Standards)
6,626
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper and
Aluminum )A
331419
750 (2007 Size Standards)
9,883
Industrial
Copper Rolling, Drawing, Extruding,
and Alloying
331420
1000
25,165
D
7,927
14,259
1,858
D
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1000 (2007 Size Standards)
8,038
Industrial
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and
Extruding
331491
750
8,433
D
1,945
3,307
D
D
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal (except
Copper and Aluminum)
331492
750
16,169
D
4,702
10,052
D
Industrial
Iron Foundries
331511
1000
11,790
D
D
6,423
3,152
D
Industrial
Steel Foundries (except Investment)
331513
500
4,804
D
791
2,802
835
D
Industrial
Aluminum Die-Casting Foundries"
331521
500 (2007 Size Standards)
6,209
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
3,056
D
919
1,910
Industrial
Nonferrous Forging
332112
750
3,219
D
D
1,192
1,668
D
Industrial
Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332119
500
12,775
1,162
5,732
5,163
719
282
Industrial
Hand and Edge Tool ManufacturingA
332212
500 (2007 Size Standards)
5,564
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
6,690
D
2,329
3,591
D
133
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
28,679
D
12,416
10,837
D
D
Industrial
Metal Window and Door Manufacturing
332321
750
10,624
D
3,139
4,951
1,397
D
Industrial
Sheet Metal Work Manufacturing
332322
500
21,855
3,838
10,493
6,852
Industrial
Metal Can Manufacturing
332431
1500
16,332
D
2,933
13,189
Industrial
Other Metal Container Manufacturing
332439
500
3,865
288
1,773
1,110
694
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
500
10,681
705
3,437
5,718
821
Industrial
Metal Heat Treating
332811
750
7,102
D
2,710
D
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
14,125
1,530
6,711
5,885
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
7,796
1,384
4,000
D
D
Industrial
Other Fabricated Metal Manufacturing
332990
NA
Industrial
Small Arms Ammunition
Manufacturing
332992
1250
3,933
D
D
D
D
D D
(continued)
-------
Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1500
3,779
D
D
D
D
D
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
15,520
2,572
6,120
6,086
742
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1250
37,313
D
3,769
9,831
6,458
7,133
D
Industrial
Lawn and Garden Tractor and Home
Lawn and Garden Equipment
Manufacturing
333112
1500
8,257
D
D
2,035
3,157
D
Industrial
Construction Machinery Manufacturing
333120
1250
45,480
D
4,027
9,164
8,345
17,329
D
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
7,671
D
1,590
3,627
D
D
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
1,972
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1000
2,315
D
693
D
Industrial
Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing
333415
1250
33,057
827
3,251
14,594
6,286
8,099
Industrial
Machine Tool (Metal Cutting Types)
ManufacturingA
333512
500 (2007 Size Standards)
6,004
Industrial
Machine Tool (Metal Forming Types)
ManufacturingA
333513
500 (2007 Size Standards)
2,217
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1500
18,238
D
D
4,078
5,705
5,970
D
Industrial
Other Engine Equipment Manufacturing
333618
1500
29,996
424
1,602
10,251
8,097
9,622
Industrial
Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333923
1250
9,745
D
1,275
2,870
D
D
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1250
6,193
389
1,214
1,902
2,687
Industrial
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
334220
1250
32,613
1,192
3,337
9,155
1,861
4,736
12,332
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
1,351
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
4,827
D
1,491
2,502
D
Industrial
Semiconductor and Related Device
Manufacturing
334413
1250
52,400
D
4,845
8,445
11,831
13,655
D
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
2,801
D
823
D
688
D
(continued)
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Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
Blank Magnetic and Optical Recording
334613
1000
301
D
D
D
Media Manufacturing
Industrial
Electric Lamp Bulb and Part
335110
1250
2,037
D
D
1,121
D
Manufacturing
Industrial
Household Laundry Equipment
335224
1250
D
D
D
D
Manufacturing
Industrial
Other Major Household Appliance
335228
1000
4,901
D
D
D
3,245
D
Manufacturing
Industrial
Power, Distribution, and Specialty
335311
750
6,257
D
1,038
3,609
811
D
Transformer Manufacturing
Industrial
Motor and Generator Manufacturing
335312
1250
12,276
D
1,501
5,817
D
D
Industrial
Storage Battery Manufacturing
335911
1250
7,045
D
D
3,954
343
D
Industrial
Current-Carrying Wiring Device
335931
500
7,449
D
1,625
3,841
1,080
D
Manufacturing
Industrial
Noncurrent-Carrying Wiring Device
335932
1000
6,679
D
988
3,573
D
D
Manufacturing
Industrial
Carbon and Graphite Product
335991
750
3,838
D
763
2,524
D
Manufacturing
Industrial
Automobile Manufacturing
336111
1500
117,256
D
D
D
30,978
81,053
Industrial
Light Truck and Utility Vehicle
336112
1500
131,693
D
D
166
D
D
86,547
Manufacturing
Industrial
Heavy Duty Truck Manufacturing
336120
1500
31,861
D
D
D
5,607
17,995
D
Industrial
Motor Vehicle Body Manufacturing
336211
1000
12,330
D
2,793
5,434
2,541
D
Industrial
Truck Trailer Manufacturing
336212
1000
8,598
D
1,466
3,584
1,879
D
Industrial
Motor Vehicle Gasoline Engine and
336310
1000
31,720
D
1,533
8,444
18,109
D
Engine Parts Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and
336311
500 (2007 Size Standards)
2,543
Valve ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
750 (2007 Size Standards)
29,177
ManufacturingA
Industrial
Motor Vehicle Steering and Suspension
336330
1000
12,925
D
873
6,911
3,102
D
D
Components (except Spring)
Manufacturing
Industrial
Motor Vehicle Brake System
336340
1250
11,728
D
1,025
7,316
1,714
D
Manufacturing
Industrial
Motor Vehicle Transmission and Power
336350
1500
37,565
D
3,038
14,836
4,926
11,885
D
Train Parts Manufacturing
Industrial
Motor Vehicle Seating and Interior Trim 336360
1500
24,044
D
1,861
13,736
7,260
D
Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1000
31,544
544
4,911
13,542
7,464
5,083
Industrial
Other Motor Vehicle Parts
336390
1000
61,909
2,420
6,999
30,065
16,409
6,015
Manufacturing
(continued)
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Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
20-
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
SBA Size Standards (2017)
Total
<19
99
499
999
2499
>2500
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
54,807
Industrial
Aircraft Manufacturing
336411
1500
121,831
D
537
4,419
3,083
6,984
106,475
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1500
40,025
430
1,650
12,223
4,435
4,827
16,461
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1250
36,920
D
2,800
10,638
5,949
D
10,561
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit
Parts Manufacturing
336415
1250
4,538
D
D
D
D
2,863
Industrial
Railroad Rolling Stock Manufacturing
336510
1500
18,497
D
2,128
4,607
3,469
D
D
Industrial
Ship Building and Repairing
336611
1250
26,890
640
1,906
5,068
2,470
2,336
14,470
Industrial
Boat Building
336612
1000
7,685
D
1,627
4,589
544
D
Industrial
Military Armored Vehicle, Tank, and
Tank Component Manufacturing
336992
1500
5,997
D
D
1,065
D
D
Industrial
Wood Kitchen Cabinet and Countertop
Manufacturing
337110
750
11,603
D
D
3,630
1,913
D
Industrial
Upholstered Household Furniture
Manufacturing
337121
1000
11,295
D
D
2,969
3,082
D
D
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
4,430
D
1,101
1,490
D
D
Industrial
Institutional Furniture Manufacturing
337127
500
5,091
D
1,666
2,656
D
Industrial
Wood Office Furniture Manufacturing
337211
1000
2,785
D
508
1,567
D
Industrial
Office Furniture (except Wood)
Manufacturing
337214
1000
9,166
D
569
3,097
1,378
D
D
Industrial
Showcase, Partition, Shelving, and
Locker Manufacturing
337215
500
7,215
D
2,259
3,559
620
Industrial
Blind and Shade Manufacturing
337920
1000
1,903
D
493
932
D
Industrial
Surgical and Medical Instrument
Manufacturing
339112
1000
40,611
D
D
18,671
7,408
9,357
D
Industrial
Surgical Appliance and Supplies
Manufacturing
339113
750
39,975
D
D
12,728
4,091
11,930
D
Industrial
Jewelry and Silverware Manufacturing
339910
500
8,191
1,255
1,940
D
D
D
Industrial
Sporting and Athletic Goods
Manufacturing
339920
750
11,093
1,010
2,626
4,045
1,134
2,278
Industrial
Office Supplies (except Paper)
Manufacturing
339940
750
2,989
D
734
1,825
D
Industrial
Gasket, Packing, and Sealing Device
Manufacturing
339991
500
7,099
D
1,976
3,567
727
D
Industrial
Burial Casket Manufacturing
339995
1000
788
D
D
D
D
Industrial
All Other Miscellaneous Manufacturing
339999
500
13,361
3,094
2,939
3,990
D
D
(continued)
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Table 6-3. Receipts by Industry and Enterprise Size: 2012 (in millions of 2017$) (continued)
Receipts by Employee Size Categories (in millions of 2017S)
Sector
NAICS Descriptions
NAICS SBA Size Standards (2017)
Total
<19
20-
99
249,442
110,303
95,417
940,597
240,878
273,613
169,421
5,337
16,790
7,331
2,129
3,202
24,778
8,512
8,445
6,917
1,726
5,213
977
2,229
9,597
680
2,537
18,989
5,117
7,866
6,512
1,254
1,731
103,621
49,542
28,420
16,518
4,159
7,337
100-
499
500-
999
1000-
2499
>2500
Commercial
Commercial
Commercial
Commercial
Energy
Energy
Energy
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Waste Treatment
Waste Treatment
Waste Treatment
Waste Treatment
Educational Services
Commercial
Commercial
Commercial
Grain and Field Bean Merchant
Wholesalers
Petroleum Bulk Stations and Terminals
Scheduled Passenger Air Transportation
Line-Haul Railroads
Pipeline Transportation of Crude Oil
Pipeline Transportation of Natural Gas
Pipeline Transportation of Refined
Petroleum Products
Support Activities for Rail
Transportation
Marine Cargo Handling
General Warehousing and Storage
Other Warehousing and Storage
Lessors of Nonresidential Buildings
(except Miniwarehouses)
Testing Laboratories
Research and Development in the
Physical, Engineering and Life Sciences
(except Nanotechnology and
Biotechnology)^
All Other Support Services
Hazardous Waste Treatment and
Disposal
Solid Waste Landfill
Solid Waste Combustors and
Incinerators
Remediation Services
Colleges, Universities, and Professional
Schools
Amusement and Theme Parks
Linen and Uniform Supply
Industrial Launderers
424510 200
424710
481111
482111
486110
486210
486910
488320
493110
493190
531120
200
1500
1500
1500
$27.5 million
1500
488210 $15 million
$38.5 million
$27.5 million
$27.5 million
$27.5 million
541380
$15 million
541715
1000
561990
$11 million
562211
$38.5 million
562212
$38.5 million
562213
$38.5 million
562910
$20.5 million
611310
$27.5 million
713110
$38.5 million
812330
NA
812332
$38.5 million
21,160
7,220
7,450
936
7,076
2,426
5,536
2,683
2,247
D
2,492
1,940
15,299
3,015
6,133
13,578
255
458
7,642
715
3,773
Notes:
Blank cells represent unreported data in the category. NA means it is not a valid 2012 NAICS code, thus SBA Size Standards are not available. When sub-categories are aggregated to the reported size
categories, we treated unreported data as zero since no receipts were reported in the sub-category.
When data is reported as "D" ("Withheld to avoid disclosing data for individual companies") or "Q" ("Revenue not collected at this level of detail for multi-establishment firms") for a sub-category or
category, we report "D" or "Q," respectively, in the corresponding cell.
A These Source Categories have a 2007 NAICS description because they are not defined in the 2012 Census. The 2012 Census provides establishment and revenue data for these source categories on
2007 NAICS basis, as a total figure for all establishments and revenues. It does not provide a breakdown by employment size.
The following NAICS report aggregate data for other top employee size categories and thus are not reported in the table: 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320, 221330,
424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380, 561990, 562211, 562212, 562213, 562910, 713110, and 812332.
-------
For the following NAICS, total receipts include establishments which operated entire year and not operated entire year whereas the breakdown into categories is done for establishments operated entire
year: 221111, 221112, 221117, 221118, 221122, 221210, 221310, 221320, 221330, 424510, 424710, 481111, 486110, 486210, 486910, 488210, 488320, 493110, 493190, 531120, 541380, 561990,
562211, 562212, 562213, 562910, 713110, and 812332.
For NAICS 115114, Post harvest Crop Activities, the data are from County Business Patterns, but there are no revenue data. Geography Area Series: County Business Patterns by Employment Size
Class more information 2012 Business Patterns.
332990 is not a valid 2012 NAICS code, therefore there are no data available in the 2012 Economic Census. Also, the size standards for this NAICS code are not available in the 2007, 2016 or 2017
SBA Size Standards. There is not even a description of this NAICS code in any of the SBA Size Standards. It could be a 2002 NAICS code. We found its description as a 2002 NAICS Code in the
"Survey of Current Business: Volume 88, Issues 1-6, January 1, 2008, U.S. Department of Commerce.
482111 NAICS code (line-haul railroad) is excluded from the Economic Census therefore no data are available.
541715 is not a valid 2012 NAICS code, therefore there are no data available in the 2012 Economic Census. Four Industries in the 2012 NAICS structure have been expanded for 2017. 541712—
Research and Development in the Physical, Engineering and Life Sciences (except Biotechnology) has been expanded to include 541713—Research and Development in Nanotechnology 541715—
Research and Development in the Physical, Engineering and Life Sciences (except Nanotechnology).
812330 is not a valid 2012 NAICS code; therefore, there are no data available in the 2012 Economic Census. This code seems to be not a NAICS code but an IRS Statistics of Income (SOI) Program
Industry Code for coding the industrial activities of corporations filing returns (https://www.irs.gov/irm/part 1 /irm 01-013-007). The SOI codes correspond to NAICS codes such as 812330 corresponds
to 812332 Industrial Launderers and 812331 Linen Supply, but is a different code.
For NAICS 611310, Colleges and Universities establishment and employment data are from County Business Patterns but there are no revenue data. Geography Area Series: County Business Patterns
by Employment Size Class more information 2012 Business Patterns.
NAICS 922140 (Correctional Institutions), NAICS 927110 (Space Research and Technology), NAICS 928110 (National Security) are government/public administration NAICS codes not covered by
the Census.
NAICS 999999 is an unclassified code and therefore no data are available for it.
Sources: 2012 Economic Census, 2017 SBA Size Standards, SBA February 2016 Size Standards, SBA 2007 Size Standards, St. Louis Federal Reserve.
-------
6.2 Developing Economic and Small Entity Regulatory Relief Impact Measures
We measured the impacts of the final rule on small entities in each sector using methods
presented in the EPA's Final SBREFA Guidance (U.S. EPA, 2006c). Because the rule covers a
large number of sectors and primarily covers businesses, the analysis generated a set of sales
tests (represented as potential avoided cost-to-receipt ratios)57 for NAICS codes associated with
the affected sectors.
Facilities that could potentially be affected by the final MM2A rule fall under different
source categories selected for the MM2A analysis and the NAICS codes associated with these
source categories. A particular NAICS code may be related to more than one source category; for
instance, NAICS 324110 (Petroleum Refineries) is associated with five source categories:
Asphalt, Refineries, Gasoline Distribution, Industrial Cooling Towers, and ICI Boilers and
Process Heaters. Also, a particular source category may be associated with more than one
NAICS code; for example, the source category ICI Boilers and Process Heaters is associated
with 263 different NAICS codes. We aggregated the number of facilities that could potentially
reclassify to area source status, the number of facilities in the category subject to MACT, and the
net cost savings for the years in the analysis, across source categories to NAICS codes. Once we
aggregated these to NAICS codes, we compared Census data on receipts and establishments by
NAICS code with the cost savings and facilities data by NAICS code to obtain avoided cost-to-
sales ratios.
Although the appropriate SBA size definition should be applied at the parent company
(enterprise) level, data limitations allowed us only to compute and compare ratios for a model
establishment for 6 establishment size ranges (i.e., all categories, establishments with 19 or fewer
employees, 20 to 99 employees, 100 to 499 employees, 500 to 999 employees, 1,000 to 2,499
employees, and 2,500+ employees). This approach allowed us to account for differences in
establishment receipts between large and small establishments and differences in small business
definitions across affected industries. It is also a conservative approach (that is, may overstate
cost to receipts ratios) because an establishment's parent company (the "enterprise") may have
other economic resources that could be used to cover the costs of the reporting program.
57 The following metrics for other small entity economic impact measures (if applicable) would potentially include
the following:
Small government (if applicable): "Revenue" test—annualized compliance cost as a percentage of annual
government revenues.
Small nonprofits (if applicable): "Expenditure" test—annualized cost as a percentage of annual operating expenses.
200
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6.3 Implementing the Sales Test to Measure Impacts on Industrial, Commercial and
Other Sources under the Primary Scenario
The "sales test" is an approach that computes the annualized compliance costs as a share
of sales for each company. The "sales test" is the methodology the EPA employs in economic
impact analyses such as this one as opposed to a "profits test," in which annualized compliance
costs are calculated as a share of profits. This is because revenues or sales data are commonly
available for entities affected by EPA regulations, and profits data normally made available are
often not the true profits earned by firms because of accounting and tax considerations. Although
screening-level analyses are often employed to estimate impacts to small businesses or entities as
part of an analysis in compliance with the Regulatory Flexibility Act as amended by SBREFA, a
screening-level analysis can also be employed in an economic impact analysis such as this one
whose focus is on regulated companies. Given the general lack of information on the identity of
owners of companies potentially affected by the final rule, the EPA implemented the
recommended sales test by computing avoided cost-to-sales ratios for affected sectors at the
establishment (or facility) level.58
The ratios compare the average establishment's total yearly avoided costs to the average
establishment receipts for enterprises within several employment categories. The average entity
avoided costs used to compute the sales test vary across sources but are the same across
establishment size categories. As a result, the sales test will overstate the avoided cost-to-sales
ratio for establishments owned by small businesses, because the reporting costs are likely lower
than average entity estimates provided by the MM2A cost analysis. These avoided cost-to-sales
ratios were calculated as follows.
First, for each source category, the industry net estimated cost savings excluding
permitting costs to the state agency for year 1 (2021) and net estimated cost savings for year 5
(2025 and beyond) were calculated. This was done for years 1 and 5, because the EPA assumed
that not all establishments would reclassify in the first year but over time, and a 5-year time
frame would allow this reclassification to be complete. For year 1, the net cost savings included
the facility's permitting costs; for year 5, the net cost savings included only the supporting
58 Typically, SBREFA impact assessments are conducted at the ultimate parent company level. As noted above, we
assumed that the Census definition of enterprise is equivalent to the ultimate parent company. Theoretically, the
comparison of compliance costs to sales should be conducted at the enterprise level. Because Census only
provides data for typical establishments within various enterprise size categories, the EPA chose to compute the
cost-to-sales ratio at the establishment (or facility level). The same ratio could be computed at the enterprise level
by multiplying both the numerator and the denominator by the typical number of establishments per enterprise in
the appropriate enterprise size categories. Using the Economic Census data on typical establishments means that
the cost-to- sales ratios are identical, whether computed at the establishment level or at the enterprise level.
201
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statement cost savings and estimated area source rule burdens, because there are no permitting
costs in year 5. Because many of the source categories shared primary NAICS codes, we
aggregated the year 1 net estimated cost savings excluding permitting costs to the state agency,
and year 5 net estimated cost savings, and the number of facilities to obtain area source status.
Because the EPA also assumed that all the reclassifications are evenly distributed over the years,
the year 1 net estimated cost savings excluding permitting costs to the state agency represent the
year 1 (2021) portion (25 percent) of these costs. Then we calculated the average estimated net
cost savings per facility for year 1 (see "Average Cost per Entity" in Table 6-4) and year 5 (see
"Average Cost per Entity" in Table 6-5).
Next, we calculated the average receipts per establishment for each NAICS code overall
and for each size category by dividing the receipts (Table 6-3) by the number of establishments
(Table 6-1). Frequently, receipts data are not available, so we were not able to calculate average
receipts per establishment (or later, avoided cost-to-sales ratios) for certain size categories.
Finally, we calculated the year 1 and year 5 avoided cost-to-sales ratios for the primary
scenario by dividing the average estimated net cost savings per facility by the average receipts
per establishment for the overall NAICS and the establishment size categories. The year 1
avoided cost-to-sales ratios are reported in Table 6-4, and the year 5 avoided cost-to-sales ratios
are reported in Table 6-5. The year 1 avoided cost-to-sales ratios range from -0.19 percent to less
than 0.01 percent, with a median potential avoided cost-to-sales ratio of less than 0.01 percent
across all employment size categories. The twenty-fifth percentile and seventy-fifth percentile
avoided cost-to-sales ratio in year 1 are -0.01 percent and less than 0.01 percent respectively
across all employment size categories. The year 5 avoided cost-to-sales ratios range from less
than 0.01 percent to 5.68 percent, with a median potential avoided cost-to-sales ratio of 0.05
percent across all employment size categories. The twenty-fifth percentile and seventy-fifth
percentile avoided cost-to-sales ratios in year 5 are 0.01 percent and 0.17 percent respectively
across all employment size categories.
Because facilities according to our analysis do not face permitting costs in year 5 and all
reclassifications have taken place, the cost savings are larger in year 5 than year 1, and the
resulting avoided cost-to-sales ratios are larger. For example, NAICS 337110 (Wood Kitchen
Cabinet and Countertop Manufacturing) has an overall year 1 avoided cost-to-sales ratio of -0.06
percent and an overall year 5 avoided cost-to-sales ratio of 0.52 percent. Some NAICS codes that
have less than 0.01 percent ratios in year 1 have positive ratios in year 5, such as NAICS 327310
(Cement Manufacturing), which has an overall avoided cost-to-sales ratio of less than 0.01
percent in year 1 and 0.09 percent in year 5.
202
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As discussed above, we conducted a small entity analysis for both year 1 and year 5
impact estimates. In year 1, some small size categories have very small negative avoided cost-to-
sales ratios. The "fewer than or equal to 19 employees" category of NAICS 424710 (Petroleum
Bulk Stations and Terminals) has a less than 0.01 percent avoided cost-to-sales ratio, and the "20
to 99 employees" category of NAICS 325120 (Industrial Gas Manufacturing) has a less than
0.01 percent avoided cost-to-sales ratio. However, there are other cases of more negative
economic impacts in year 1 for small size categories, even though these impacts are small in
absolute terms. In year 1, the "fewer than or equal to 19 employees" category of NAICS 562211
(Hazardous Waste Treatment and Disposal), has a -0.06 percent avoided cost-to-sales ratio.
Establishments in this size category are considered small businesses for NAICS 562211 because
the average receipts per establishment in 2017 dollars is $1.8 million which is less than the SBA
size standard of $38.5 million for this NAICS code. For the same size category, NAICS 493110
(General Warehousing and Storage) has an avoided cost-to-sales ratio of -0.11 percent in year 1.
Establishments in the "fewer than or equal to 19 employees" size category for NAICS 493110
are treated as small businesses for purposes of this analysis because the average receipts per
establishment in 2017 dollars is $0.9 million which is less than the SBA size standard of $27.5
million for this NAICS code.
In year 5, small entities generally have larger cost savings and the resulting avoided cost-
to-sales ratios are larger. For example, for NAICS 213112 (Support Activities for Oil and Gas
Operations) the "fewer than or equal to 19 employees" category has an avoided cost-to-sales
ratio of -0.05 percent in year 1 and in year 5, the ratio is 0.69 percent. Establishments in the
"fewer than or equal to 19 employees" size category for NAICS 213112 are considered small
businesses for purposes of this analysis because the average receipts per establishment is $2.2
million in 2017 dollars, which is less than the SBA size standard of $38.5 million. For NAICS
562211, for the "fewer than or equal to 19 employees" category, the avoided cost-to-sales ratio
in year 5 is 4.95 percent.
Smaller entities having larger impacts in some cases is probably a result of smaller
establishments generally having lower average receipts per establishment than larger
establishments and the assumption that the average cost per entity is approximately the same for
different establishment sizes within a NAICS code.
As is evident from Tables 6-4 and 6-5, we did not calculate and report avoided cost-to-
sales ratios in certain cases, because we used the 2012 Economic Census to collect and organize
data on number of establishments, employment, and receipts for affected sources represented by
six-digit NAICS codes. However, because of confidentiality issues, some data values were not
203
-------
available or were reported with a range of values. Also, some source categories are not
completely covered by the 2012 Economics Census. Table 7-1 in Section 7 describes the data
limitations for the source categories not completely covered by the 2012 Economic Census.
These data limitations prevented us from reporting avoided cost-to-sales ratios entirely
for some NAICS codes and for every employment size category for some NAICS codes.
The number of establishments was not reported for the larger employee size categories
for some NAICS codes. For example, for NAICS 221320 (Sewage Treatment Facilities) the
number of establishments was only reported for "500+ employees" instead of separately for "500
to 999 employees," "1,000 to 2,499 employees," and "2,500+ employees." Similarly, for NAICS
codes 486210 (Pipeline Transportation of Natural Gas), 493110 (General Warehousing and
Storage), and 562211 (Hazardous Waste Treatment and Disposal), the number of establishments
was only reported for "100+ employees." This issue arises for employment and receipts data as
well as for these NAICS codes in the same employee size categories. Therefore, we were not
able to compute impact estimates for these size categories for these NAICS codes.
Regarding the reporting of employment data in the 2012 Economic Census, an issue is
that many categories are reported in ranges. For example, the "2,500+ employees" category for
NAICS 211111 (Crude Petroleum and Natural Gas Extraction) is simply reported as "10,000-
24,999" employees. Employment does not directly affect the calculation of the impact estimates,
so this limitation is not an issue for the avoided cost-to-sales ratios.
For receipts data, many data values are not available especially for the different employee
size categories. More commonly, unavailable data are reported as "Q," meaning "Revenue not
collected at this level of detail for multi-establishment firms," or "D," meaning "Withheld to
avoid disclosing data for individual companies." Receipts data are essential to calculating the
avoided cost-to-sales ratios, but because many data values are unavailable, we are limited in
which avoided cost-to-sales ratios we can calculate and report. Also, receipts data are defined
differently depending on the NAICS codes.
The underlying establishment and receipts data are a limiting factor because if either of
these measures is not reported for a certain category, we cannot calculate the average receipts per
establishment, which is needed for the avoided cost-to-sales ratio calculation. However, there are
cases where avoided cost-to-sales ratios are not reported because zero facilities are estimated to
obtain area source status; therefore, there are no facilities to calculate the average cost per entity.
204
-------
The public administration NAICS have facilities estimated to obtain area source status,
but because these NAICS codes comprise government facilities, the relevant sales data
(establishments and revenue) are not available for these NAICS codes. Similarly, NAICS 999999
is an unclassified code, and the 2012 Economic Census does not provide establishments or
revenue data for this NAICS code. Therefore, no data or cost-to-sales ratios are presented for
them. All of this data can be found in final MM2ARIAdataspreadsheetAugust_2020.xls that can
be found in the docket for this rulemaking.
205
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
115114
$27.5 million
* **
*
**
* **
* **
* **
* **
*
**
Cotton Ginning)
Energy
Crude Petroleum and Natural Gas
211111
1250 (Feb 2016 Size
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Extraction
Standards)
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
-$1,022
0.00%
0.00%
0.00%
0.00%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
*
**
**
**
* **
* **
*
**
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
**
*
**
* **
* **
* **
* **
*
**
Standards)
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
**
*
**
* **
* **
**
* **
*
**
Standards)
Industrial
All Other Metal Ore Mining
212299
750
**
*
**
* **
**
* **
* **
*
**
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
*
**
Industrial
Kaolin and Ball Clay Mining
212324
750
**
*
**
**
**
* **
* **
*
**
Industrial
Potash, Soda, and Borate Mineral
212391
750
**
*
**
* **
* **
**
* **
*
**
Mining
Industrial
All Other Nonmetallic Mineral Mining
212399
500
**
*
**
**
* **
* **
* **
*
**
Energy
Support Activities for Oil and Gas
213112
$38.5 million
-$1,022
-0.01%
-0.05%
-0.01%
o'oo%
o'.oo%
o'oo%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
-$1,022
-0.02%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power Generation
221112
750
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Biomass Electric Power Generation
221117
250
-$1,022
-0.01%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
-$1,022
-0.04%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
-$1,022
-0.01%
*
*
*
*
*
*
Standards)
Utilities
Electric Power Distribution
221122
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation Systems
221310
$27.5 million
-$1,022
-0.04%
*
*
*
*
*
*
Utilities
Sewage Treatment Facilities
221320
$20.5 million
-$1,022
-0.05%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
*
**
**
* **
* **
* **
*
**
Industrial
Wet Corn Milling
311221
1,250
**
*
**
**
**
* **
* **
*
**
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Soybean and Other Oilseed Processing
311224
1,000
-$1,022
0.00%
*
o!oo%
*
*
*
*
Industrial
Fats and Oils Refining and Blending
311225
1,000
**
*
**
**
* **
* **
* **
*
**
Industrial
Beet Sugar Manufacturing
311313
750
**
*
**
* **
* **
**
* **
*
**
Industrial
Cane Sugar Manufacturing
311314
1,000
**
*
**
* **
**
* **
* **
*
**
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
*
**
* **
**
* **
* **
*
**
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1,000
**
*
**
**
**
* **
* **
*
**
Industrial
Specialty Canning
311422
1,250
**
*
**
* **
* **
**
* **
*
**
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
*
**
Industrial
Dry, Condensed, and Evaporated Dairy
311514
750
**
*
**
**
**
* **
* **
*
**
Product Manufacturing
Industrial
Rendering and Meat Byproduct
311613
750
**
*
**
**
**
* **
* **
*
**
Processing
Industrial
Commercial Bakeries
311812
1,000
**
*
**
**
**
**
* **
*
**
Industrial
Other Snack Food Manufacturing
311919
1,250
**
*
**
**
**
* **
* **
*
**
Industrial
Coffee and Tea Manufacturing
311920
750
**
*
**
**
**
* **
* **
*
**
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
*
**
* **
**
* **
* **
*
**
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
500
**
*
**
**
**
* **
* **
*
**
Industrial
All Other Miscellaneous Food
311999
500
**
*
**
**
**
**
* **
*
**
Manufacturing
Industrial
Breweries
312120
1,250
-$1,022
0.00%
*
-0.01%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
*
**
* **
* **
* **
* **
*
**
Industrial
Tobacco Manufacturing
312230
1,500
**
*
**
* **
**
**
* **
*
**
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Broadwoven Fabric Finishing MillsA
313311
1000 (2007 Size Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Fabric Coating Mills
313320
1,000
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Leather and Hide Tanning and
316110
500
-$1,022
-0.01%
*
o'oo%
o'oo%
*
*
*
Finishing
Industrial
Sawmills
321113
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Wood Preservation
321114
500
**
*
**
**
* **
* **
* **
*
**
Industrial
Hardwood Veneer and Plywood
321211
500
**
*
**
* **
**
* **
* **
*
**
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Manufacturing
Industrial
Engineered Wood Member (except
321213
750
-$1,022
-0.01%
*
*
0.00%
*
*
*
Truss) Manufacturing
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Wood Window and Door
Manufacturing
321911
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
**
**
**
* **
* **
* **
* **
Industrial
All Other Miscellaneous Wood Product
Manufacturing
321999
500
**
**
**
**
* **
* **
* **
Industrial
Pulp Mills
322110
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
-$1,022
0.00%
-0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Sanitary Paper Product Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
-$1,022
-0.03%
*
*
*
*
*
*
Industrial
Commercial Printing (except Screen
and Books)
323111
500
-$1,022
-0.03%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Books Printing
323117
1,250
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
Petroleum Refineries
324110
1,500
-$1,035
0.00%
*
0.00%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating Materials
Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal Products
Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
-$1,022
-0.01%
-0.01%
0.00%
*
*
*
*
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1,000
**
* **
**
**
* **
* **
* **
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Alkalies and Chlorine ManufacturingA
325181
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size Cost/Entity 100- 500- 1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
-$1,028
0.00%
*
*
*
*
*
*
Industrial
All Other Basic Inorganic Chemical
325188
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
ManufacturingA
Industrial
Cyclic Crude and Intermediate
325192
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
ManufacturingA
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and Gum
325194
1,250
**
* **
**
**
* **
* **
* **
and Wood Chemical Manufacturing
Industrial
All Other Basic Organic Chemical
325199
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Manufacturing
Industrial
Plastics Material and Resin
325211
1,250
-$1,023
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Manufacturing
Industrial
Synthetic Rubber Manufacturing
325212
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and
325220
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Filaments Manufacturing
Industrial
Cellulosic Organic Fiber
325221
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
ManufacturingA
Industrial
Noncellulosic Organic Fiber
325222
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
ManufacturingA
Industrial
Nitrogenous Fertilizer Manufacturing
325311
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural
325320
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Chemical Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Pharmaceutical Preparation
325412
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Manufacturing
Industrial
Biological Product (except Diagnostic)
325414
1,250
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Paint and Coating Manufacturing
325510
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Adhesive Manufacturing
325520
500
-$1,022
0.00%
-0.02%
0.00%
0.00%
*
*
*
Industrial
Surface Active Agent Manufacturing
325613
750
**
* **
**
* **
* **
* **
* **
Industrial
Toilet Preparation Manufacturing
325620
1,250
**
**
**
**
**
**
* **
Industrial
Explosives Manufacturing
325920
750
**
* **
* **
* **
* **
* **
* **
Industrial
Custom Compounding of Purchased
325991
500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Resins
Industrial
Photographic Film, Paper, Plate, and
325992
1,500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical
325998
500
-$1,022
-0.01%
-0.03%
0.00%
0.00%
0.00%
*
*
Product and Preparation Manufacturing
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Plastics Packaging Film and Sheet
(including Laminated) Manufacturing
326112
1,000
-$1,022
0.00%
-0.03%
0.00%
0.00%
*
*
*
Industrial
Unlaminated Plastics Film and Sheet
(except Packaging) Manufacturing
326113
750
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
**
* **
**
**
* **
* **
* **
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
**
**
**
**
* **
* **
* **
Industrial
Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
326130
500
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Polystyrene Foam Product
Manufacturing
326140
1,000
**
* **
**
**
**
* **
* **
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
-$1,046
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Plastics Product
Manufacturing
326199
750
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Tire Manufacturing (except Retreading)
326211
1,500
-$1,004
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Rubber and Plastics Hoses and Belting
Manufacturing
326220
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
**
* **
* **
**
**
* **
* **
Industrial
All Other Rubber Product
Manufacturing
326299
500
-$1,022
-0.01%
-0.05%
-0.01%
0.00%
*
*
*
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
-$1,321
-0.04%
*
-0.02%
0.00%
*
*
*
Industrial
Clay Building Material and Refractories
Manufacturing
327120
750
-$1,022
-0.01%
-0.06%
-0.01%
0.00%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
-$1,175
-0.01%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1,250
-$1,022
-0.01%
*
*
*
o'.oo%
*
*
Industrial
Cement Manufacturing
327310
1,000
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Gypsum Product Manufacturing
327420
1,500
**
* **
**
* **
* **
* **
* **
Industrial
Abrasive Product Manufacturing
327910
750
-$1,022
-0.01%
-0.04%
-0.01%
0.00%
0.00%
*
*
Industrial
Mineral Wool Manufacturing
327993
1,500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
327999
500
**
* **
**
* **
* **
* **
* **
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Electrometallurgical Ferroalloy Product
ManufacturingA
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331210
1,000
-$1,022
0.00%
-0.02%
0.00%
0.00%
0.00%
0.00%
*
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Primary Aluminum ProductionA
331312
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Secondary Smelting and Alloying of
Aluminum
331314
750
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Aluminum Extruded Product
ManufacturingA
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Aluminum Rolling, Drawing, and
Extruding
331318
750
**
* **
* **
**
* **
* **
*
**
Industrial
Nonferrous Metal (except Aluminum)
Smelting and Refining
331410
1,000
**
* **
**
* **
**
* **
*
**
Industrial
Primary Smelting and Refining of
CopperA
331411
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper and
Aluminum )A
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Copper Rolling, Drawing, Extruding,
and Alloying
331420
1,000
**
* **
**
**
**
* **
*
**
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, and
Extruding
331491
750
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal (except
Copper and Aluminum)
331492
750
**
* **
**
**
* **
* **
*
**
Industrial
Iron Foundries
331511
1,000
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
* **
*
**
Industrial
Aluminum Die-Casting Foundries"
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
* **
*
**
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Nonferrous Forging
332112
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332119
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Hand and Edge Tool ManufacturingA
332212
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
-$1,022
-0.02%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Other Metal Container Manufacturing
332439
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Metal Heat Treating
332811
750
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
-$1,022
-0.02%
-0.12%
-0.01%
0.00%
*
*
*
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
-$1,022
-0.03%
-0.12%
-0.02%
*
*
*
*
Industrial
Other Fabricated Metal Manufacturing
332990
#N/A
-$1,022
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
-$1,022
0.00%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
-$1,022
-0.02%
-0.11%
-0.01%
0.00%
0.00%
*
*
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Lawn and Garden Tractor and Home
Lawn and Garden Equipment
Manufacturing
333112
1,500
**
* **
* **
**
**
* **
* **
Industrial
Construction Machinery Manufacturing
333120
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
* **
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
* **
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing
333415
1,250
**
**
**
**
**
**
* **
Industrial
Machine Tool (Metal Cutting Types)
ManufacturingA
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Machine Tool (Metal Forming Types)
ManufacturingA
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
* **
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
Industrial
Overhead Traveling Crane, Hoist, and
Monorail System Manufacturing
333923
1,250
**
* **
**
**
* **
* **
* **
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
* **
Industrial
Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
-$1,014
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
Industrial
Blank Magnetic and Optical Recording
Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
-$1,022
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
-$1,022
0.00%
*
*
*
0.00%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor and Generator Manufacturing
335312
1,250
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Noncurrent-Carrying Wiring Device
Manufacturing
335932
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
-$1,022
0.00%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
-$1,022
0.00%
*
*
0.00%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
-$1,022
0.00%
*
*
*
0.00%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Truck Trailer Manufacturing
336212
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and Suspension
Components (except Spring)
Manufacturing
336330
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Transmission and Power
Train Parts Manufacturing
336350
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Metal Stamping
336370
1,000
-$1,022
0.00%
-0.05%
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Aircraft Manufacturing
336411
1,500
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
-$1,022
0.00%
-0.05%
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit
Parts Manufacturing
336415
1,250
-$1,022
0.00%
*
*
*
*
0.00%
*
Industrial
Railroad Rolling Stock Manufacturing
336510
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Ship Building and Repairing
336611
1,250
-$1,022
0.00%
-0.07%
-0.01%
0.00%
0.00%
0.00%
0.00%
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017S)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
100- 500- 1000-
All <19 20-99 499 999 2499 >2500
Industrial
Boat Building
336612
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Military Armored Vehicle, Tank, and
336992
1,500
-$1,022
0.00%
*
*
0.00%
*
*
*
Tank Component Manufacturing
Industrial
Wood Kitchen Cabinet and Countertop
337110
750
-$1,022
-0.06%
*
*
0.00%
0.00%
*
*
Manufacturing
Industrial
Upholstered Household Furniture
337121
1,000
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Manufacturing
Industrial
Nonupholstered Wood Household
337122
750
-$1,022
-0.06%
*
-0.02%
0.00%
*
*
*
Furniture Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Wood Office Furniture Manufacturing
337211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Office Furniture (except Wood)
337214
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Manufacturing
Industrial
Showcase, Partition, Shelving, and
337215
500
-$1,022
-0.02%
*
-0.01%
0.00%
0.00%
*
*
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Surgical and Medical Instrument
339112
1,000
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
750
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Jewelry and Silverware Manufacturing
339910
500
**
**
**
* **
* **
* **
* **
Industrial
Sporting and Athletic Goods
339920
750
**
**
**
**
**
**
* **
Manufacturing
Industrial
Office Supplies (except Paper)
339940
750
**
* **
**
**
* **
* **
* **
Manufacturing
Industrial
Gasket, Packing, and Sealing Device
339991
500
**
* **
**
**
**
* **
* **
Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Manufacturing
339999
500
-$1,022
-0.05%
-0.19%
-0.01%
0.00%
*
*
*
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
* **
* **
* **
Wholesalers
Commercial
Petroleum Bulk Stations and Terminals
424710
200
-$1,022
0.00%
0.00%
0.00%
*
*
*
*
Commercial
Scheduled Passenger Air Transportation
481111
1,500
**
**
**
* **
* **
* **
* **
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
* **
* **
* **
Energy
Pipeline Transportation of Crude Oil
486110
1,500
**
**
**
* **
* **
* **
* **
Energy
Pipeline Transportation of Natural Gas
486210
$27.5 million
-$1,022
-0.01%
-0.02%
0.00%
*
*
*
*
Energy
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
* **
* **
* **
Petroleum Products
(continued)
-------
Table 6-4. Avoided Cost to Sales in Year 1 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017$)
All
<19
20-99
499
999
2499
>2500
Commercial
Support Activities for Rail
Transportation
488210
$15 million
-$1,022
-0.03%
-0.09%
-0.01%
*
*
*
*
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
* **
* **
* **
Commercial
General Warehousing and Storage
493110
$27.5 million
-$1,022
-0.06%
-0.11%
-0.03%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
-$1,022
-0.04%
-0.14%
-0.03%
*
*
*
*
Commercial
Lessors of Nonresidential Buildings
(except Mini warehouses)
531120
$27.5 million
**
**
**
* **
* **
* **
* **
Commercial
Testing Laboratories
541380
$15 million
**
**
**
* **
* **
* **
* **
Commercial
Research and Development in the
Physical, Engineering and Life
Sciences (except Nanotechnology and
Biotechnology)^
541715
1,000
* **
* **
* **
* **
* **
* **
* **
Commercial
All Other Support Services
561990
$11 million
**
**
**
* **
* **
* **
* **
Waste Treatment
Hazardous Waste Treatment and
Disposal
562211
$38.5 million
-$1,022
-0.01%
-0.06%
-0.01%
*
*
*
*
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
-$1,022
-0.02%
-0.05%
-0.01%
*
*
*
*
Waste Treatment
Solid Waste Combustors and
Incinerators
562213
$38.5 million
-$1,022
0.00%
*
0.00%
*
*
*
*
Waste Treatment
Remediation Services
562910
$20.5 million
-$1,022
-0.03%
-0.09%
-0.01%
*
*
*
*
Educational
Colleges, Universities, and Professional
611310
$27.5 million
-$1,022
*
*
*
*
*
*
*
Services
Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
**
**
**
* **
* **
* **
* **
Commercial
Linen and Uniform Supply
812330
#N/A
* **
* **
* **
* **
* **
* **
* **
Commercial
Industrial Launderers
812332
$38.5 million
-$1,022
-0.02%
-0.07%
-0.02%
*
*
*
*
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are estimated to obtain area source status. NA means it is not a valid 2012 NAICS code, thus SBA Size Standards
are not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
"Zero facilities estimated to obtain area source status and no estimated net costs (savings); cost-to-sales ratios cannot be calculated.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020a. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD. August 2020.7-18, SBA February 2016 Size
Standards, SBA 2007 Size Standards.
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
115114
$27.5 million
* **
* **
* **
* **
* **
* **
*
**
Cotton Ginning)
Energy
Crude Petroleum and Natural Gas
211111
1250 (Feb 2016 Size
10,296
0.02%
*
0.01%
0.00%
0.00%
0.00%
*
Extraction
Standards)
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
37,382
0.03%
0.06%
0.02%
0.01%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
* **
**
**
* **
* **
*
**
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
**
* **
* **
* **
* **
* **
*
**
Standards)
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
**
* **
* **
* **
**
* **
*
**
Standards)
Industrial
All Other Metal Ore Mining
212299
750
**
* **
* **
**
* **
* **
*
**
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
*
**
Industrial
Kaolin and Ball Clay Mining
212324
750
**
* **
**
**
* **
* **
*
**
Industrial
Potash, Soda, and Borate Mineral
212391
750
**
* **
* **
* **
**
* **
*
**
Mining
Industrial
All Other Nonmetallic Mineral
212399
500
**
* **
**
* **
* **
* **
*
**
Mining
Energy
Support Activities for Oil and Gas
213112
$38.5 million
15,247
0.16%
0.69%
0.16%
0.03%
0.01%
0.00%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
15,247
0.23%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power
221112
750
40,186
0.06%
*
*
*
*
*
*
Generation
Utilities
Biomass Electric Power Generation
221117
250
63,290
0.87%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
15,247
0.59%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007
50,126
0.46%
*
*
*
*
*
*
Size Standards)
Utilities
Electric Power Distribution
221122
1,000
15,247
0.03%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
40,400
0.10%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation
221310
$27.5 million
23,798
0.94%
*
*
*
*
*
*
Systems
Utilities
Sewage Treatment Facilities
221320
$20.5 million
22,367
1.07%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
32,701
0.20%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
* **
**
* **
* **
* **
*
**
Industrial
Wet Corn Milling
311221
1,250
**
* **
**
**
* **
* **
*
**
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size
**
* **
* **
* **
* **
* **
*
**
Standards)
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Soybean and Other Oilseed
311224
1,000
35,287
0.01%
*
0.01%
*
*
*
*
Processing
Industrial
Fats and Oils Refining and
311225
1,000
**
* **
**
* **
* **
* **
* **
Blending
Industrial
Beet Sugar Manufacturing
311313
750
**
* **
* **
* **
**
* **
* **
Industrial
Cane Sugar Manufacturing
311314
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1,000
**
* **
**
**
* **
* **
* **
Industrial
Specialty Canning
311422
1,250
**
* **
* **
* **
**
* **
* **
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
* **
Industrial
Dry, Condensed, and Evaporated
311514
750
**
* **
**
**
* **
* **
* **
Dairy Product Manufacturing
Industrial
Rendering and Meat Byproduct
311613
750
**
* **
**
**
* **
* **
* **
Processing
Industrial
Commercial Bakeries
311812
1,000
**
* **
**
**
**
* **
* **
Industrial
Other Snack Food Manufacturing
311919
1,250
**
* **
**
**
* **
* **
* **
Industrial
Coffee and Tea Manufacturing
311920
750
**
* **
**
**
* **
* **
* **
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
500
**
* **
**
**
* **
* **
* **
Industrial
All Other Miscellaneous Food
311999
500
**
* **
**
**
**
* **
* **
Manufacturing
Industrial
Breweries
312120
1,250
15,247
0.04%
*
0.10%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Tobacco Manufacturing
312230
1,500
**
* **
* **
**
**
* **
* **
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
15,247
0.06%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
15,247
0.23%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
23,798
0.17%
*
0.19%
0.04%
0.02%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
15,247
0.22%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
15,247
0.24%
*
0.12%
0.03%
*
*
*
Industrial
Broadwoven Fabric Finishing
313311
1000 (2007 Size
23,798
0.33%
*
*
*
*
*
*
MillsA
Standards)
Industrial
Fabric Coating Mills
313320
1,000
20,093
0.15%
*
0.11%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size
**
* **
* **
* **
* **
* **
* **
Standards)
Industrial
Leather and Hide Tanning and
316110
500
13,119
0.16%
*
0.04%
0.02%
*
*
*
Finishing
Industrial
Sawmills
321113
500
37,382
0.54%
2.66%
0.28%
0.07%
*
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Wood Preservation
321114
500
**
* **
**
* **
* **
* **
* **
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
500
**
* **
* **
**
* **
* **
* **
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
1,250
50,126
0.11%
*
*
0.06%
0.03%
*
*
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
750
15,247
0.17%
*
*
0.02%
*
*
*
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
23,687
0.08%
*
*
0.03%
*
*
*
Industrial
Wood Window and Door
Manufacturing
321911
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
**
**
**
* **
* **
* **
* **
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
500
**
**
**
**
* **
* **
* **
Industrial
Pulp Mills
322110
750
20,948
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
12,461
0.00%
*
*
0.01%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
15,247
0.01%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
45,144
0.02%
*
*
0.02%
0.01%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
958
0.00%
0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
20,948
0.07%
*
0.10%
0.03%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
23,798
0.08%
*
*
*
*
*
*
Industrial
Sanitary Paper Product
Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
15,247
0.37%
*
*
*
*
*
*
Industrial
Commercial Printing (except
Screen and Books)
323111
500
19,961
0.57%
*
0.23%
0.04%
0.01%
*
*
Industrial
Books Printing
323117
1,250
23,798
0.25%
*
*
0.05%
0.02%
*
*
Industrial
Petroleum Refineries
324110
1,500
98,124
0.00%
*
0.04%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal
Products Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
16,608
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
15,247
0.09%
0.22%
0.06%
*
*
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average Avoided
Cost/Entity (2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1,000
**
*
**
**
**
* **
* **
*
**
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
1000 (2007 Size
15,247
0.02%
*
*
*
*
*
*
Standards)
Industrial
Synthetic Organic Dye and Pigment ManufacturingA
325132
750 (2007 Size
**
*
**
* **
* **
* **
* **
*
**
Standards)
Industrial
Other Basic Inorganic Chemical Manufacturing
325180
1,000
20,948
0.04%
*
0.04%
0.01%
0.00%
*
*
Industrial
Alkalies and Chlorine ManufacturingA
325181
1000 (2007 Size
24,362
0.01%
*
*
*
*
*
*
Standards)
Industrial
Carbon Black Manufacturing"
325182
500 (2007 Size
27,635
0.03%
*
*
*
*
*
*
Standards)
Industrial
All Other Basic Inorganic Chemical Manufacturing"
325188
1000 (2007 Size
28,288
0.06%
*
*
*
*
*
*
Standards)
Industrial
Cyclic Crude and Intermediate Manufacturing"
325192
750 (2007 Size
**
*
**
* **
* **
* **
* **
*
**
Standards)
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
23,798
0.01%
*
0.01%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and Gum and Wood
325194
1,250
**
*
**
**
**
* **
* **
*
**
Chemical Manufacturing
Industrial
All Other Basic Organic Chemical Manufacturing
325199
1,250
55,008
0.05%
*
0.09%
0.02%
0.00%
0.00%
*
Industrial
Plastics Material and Resin Manufacturing
325211
1,250
31,275
0.04%
*
0.07%
0.01%
0.00%
0.00%
*
Industrial
Synthetic Rubber Manufacturing
325212
1,000
6,981
0.01%
*
0.01%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and Filaments
325220
1,000
23,798
0.03%
*
0.10%
0.02%
0.00%
*
*
Manufacturing
Industrial
Cellulosic Organic Fiber Manufacturing"
325221
1000 (2007 Size
**
*
**
* **
* **
* **
* **
*
**
Standards)
Industrial
Noncellulosic Organic Fiber Manufacturing"
325222
1000 (2007 Size
20,275
0.03%
*
*
*
*
*
*
Standards)
Industrial
Nitrogenous Fertilizer Manufacturing
325311
1,000
50,126
0.09%
*
0.09%
*
*
*
*
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
23,798
0.01%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural Chemical
325320
1,000
59,967
0.08%
*
0.10%
0.02%
*
*
*
Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
1,000
15,247
0.05%
*
0.08%
0.02%
0.00%
*
*
Industrial
Pharmaceutical Preparation Manufacturing
325412
1,250
7,362
0.01%
*
*
0.00%
0.00%
0.00%
*
Industrial
Biological Product (except Diagnostic) Manufacturing
325414
1,250
**
*
**
* **
**
**
**
*
**
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Rubber Product
Manufacturing
326299
500
22,088
0.13%
1.07%
0.15%
0.03%
*
*
*
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
20,052
0.58%
*
0.28%
0.05%
*
*
*
Industrial
Clay Building Material and
Refractories Manufacturing
327120
750
14,991
0.16%
0.89%
0.14%
0.03%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
17,824
0.18%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1,250
15,752
0.18%
*
*
*
0.01%
*
*
Industrial
Cement Manufacturing
327310
1,000
23,798
0.09%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
15,247
0.06%
*
*
*
*
*
*
Industrial
Gypsum Product Manufacturing
327420
1,500
**
* **
**
* **
* **
* **
* **
Industrial
Paint and Coating Manufacturing
325510
1,000
129,130
0.58%
*
0.41%
o'o9%
*
*
*
Industrial
Adhesive Manufacturing
325520
500
15,247
0.06%
0.35%
0.05%
0.01%
*
*
*
Industrial
Surface Active Agent
Manufacturing
325613
750
**
* **
**
* **
* **
* **
* **
Industrial
Toilet Preparation Manufacturing
325620
1,250
**
**
**
**
**
**
* **
Industrial
Explosives Manufacturing
325920
750
**
* **
* **
* **
* **
* **
* **
Industrial
Custom Compounding of
Purchased Resins
325991
500
23,798
0.10%
*
0.08%
o'o2%
*
*
*
Industrial
Photographic Film, Paper, Plate,
and Chemical Manufacturing
325992
1,500
15,247
0.05%
*
0.07%
0.01%
*
*
*
Industrial
All Other Miscellaneous Chemical
Product and Preparation
Manufacturing
325998
500
20,948
0.11%
0.64%
0.07%
0.02%
0.01%
*
*
Industrial
Plastics Packaging Film and Sheet
(including Laminated)
Manufacturing
326112
1,000
23,798
0.07%
0.73%
0.11%
0.03%
*
*
*
Industrial
Unlaminated Plastics Film and
Sheet (except Packaging)
Manufacturing
326113
750
45,144
0.14%
*
0.20%
0.05%
0.01%
*
*
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
**
* **
**
**
* **
* **
* **
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
**
**
**
**
* **
* **
* **
Industrial
Laminated Plastics Plate, Sheet
(except Packaging), and Shape
Manufacturing
326130
500
20,948
0.13%
*
0.13%
*
*
*
*
Industrial
Polystyrene Foam Product
Manufacturing
326140
1,000
**
* **
**
**
**
* **
* **
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
12,483
0.08%
*
0.07%
0.03%
*
*
*
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Plastics Product
Manufacturing
326199
750
41,479
0.31%
2.66%
0.35%
0.08%
0.02%
0.01%
*
Industrial
Tire Manufacturing (except
Retreading)
326211
1,500
37,602
0.02%
*
*
0.02%
0.01%
0.01%
*
Industrial
Rubber and Plastics Hoses and
Belting Manufacturing
326220
750
23,798
0.11%
*
*
0.03%
0.02%
*
*
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
**
* **
* **
**
**
* **
* **
Industrial
Abrasive Product Manufacturing
327910
750
15,247
0.08%
0.65%
0.09%
0.01%
0.00%
*
*
Industrial
Mineral Wool Manufacturing
327993
1,500
29,431
0.15%
*
0.21%
0.03%
*
*
*
Industrial
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
327999
500
**
* **
**
* **
* **
* **
* **
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
34,996
0.01%
*
*
0.01%
0.00%
0.00%
*
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size
Standards)
20,948
0.01%
*
*
*
*
*
*
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
331210
1,000
23,798
0.03%
0.46%
0.08%
0.02%
0.01%
0.00%
*
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
23,798
0.07%
*
0.06%
*
*
*
*
Industrial
Primary Aluminum ProductionA
331312
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
261,229
0.17%
*
0.56%
0.11%
0.05%
*
*
Industrial
Secondary Smelting and Alloying
of Aluminum
331314
750
4,738
0.01%
*
0.01%
*
*
*
*
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
23,798
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Aluminum Extruded Product
ManufacturingA
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Aluminum Rolling, Drawing,
and Extruding
331318
750
**
* **
* **
**
* **
* **
* **
Industrial
Nonferrous Metal (except
Aluminum) Smelting and Refining
331410
1,000
**
* **
**
* **
**
* **
* **
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Primary Smelting and Refining of
CopperA
331411
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper
and Aluminum )A
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Copper Rolling, Drawing,
Extruding, and Alloying
331420
1,000
**
* **
**
**
**
*
**
* **
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Nonferrous Metal (except Copper
and Aluminum) Rolling, Drawing,
and Extruding
331491
750
15,247
0.06%
*
0.07%
0.02%
*
*
*
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal
(except Copper and Aluminum)
331492
750
**
* **
**
**
* **
*
**
* **
Industrial
Iron Foundries
331511
1,000
63,290
0.22%
*
*
0.10%
0.02%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
*
**
* **
Industrial
Aluminum Die-Casting Foundries'^
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
*
**
* **
Industrial
Nonferrous Forging
332112
750
15,247
0.03%
*
*
0.02%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
500
15,247
0.18%
1.08%
0.15%
0.03%
0.01%
*
*
Industrial
Hand and Edge Tool
ManufacturingA
332212
500 (2007 Size Standards)
15,247
0.25%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
15,247
0.15%
*
0.10%
0.03%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
15,247
0.16%
*
0.11%
0.02%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
63,290
0.64%
*
0.61%
0.13%
0.04%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
15,247
0.29%
1.11%
0.17%
0.04%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
46,894
0.05%
*
0.08%
0.03%
*
*
*
Industrial
Other Metal Container
Manufacturing
332439
500
23,798
0.21%
1.69%
0.15%
0.05%
0.01%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and
Washer Manufacturing
332722
500
15,247
0.12%
1.00%
0.12%
0.03%
0.01%
*
*
Industrial
Metal Heat Treating
332811
750
15,247
0.17%
*
0.17%
*
*
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
47,888
0.86%
5.68%
0.46%
0.06%
*
*
*
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
23,798
0.74%
2.90%
0.39%
*
*
*
*
Industrial
Other Fabricated Metal
Manufacturing
332990
#N/A
15,247
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
15,247
0.04%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
23,798
0.03%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
23,798
0.57%
2.65%
0.29%
0.05%
0.01%
*
*
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
20,948
0.06%
*
0.16%
0.02%
0.00%
0.00%
*
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden
Equipment Manufacturing
333112
1,500
**
* **
* **
**
**
* **
* **
Industrial
Construction Machinery
Manufacturing
333120
1,250
12,504
0.02%
*
0.08%
0.01%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
* **
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
* **
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1,250
**
**
**
**
**
**
* **
Industrial
Machine Tool (Metal Cutting
Types) Manufacturing"
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Machine Tool (Metal Forming
Types) Manufacturing"
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
* **
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
23,798
0.03%
0.94%
0.11%
0.02%
0.00%
0.00%
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1,250
**
* **
**
**
* **
* **
* **
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
* **
Industrial
Radio and Television Broadcasting
and Wireless Communications
Equipment Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
41,053
0.07%
*
0.13%
0.05%
0.01%
0.00%
*
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
Industrial
Blank Magnetic and Optical
Recording Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
15,247
0.05%
*
*
0.03%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
36,901
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
23,798
0.01%
*
*
*
0.01%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
15,247
0.06%
*
0.11%
0.02%
0.01%
*
*
Industrial
Motor and Generator
Manufacturing
335312
1,250
23,798
0.09%
*
0.20%
0.03%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
15,247
0.03%
*
*
0.02%
0.01%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
15,247
0.09%
*
0.13%
0.03%
0.01%
*
*
Industrial
Noncurrent-Carrying Wiring
Device Manufacturing
335932
1,000
15,247
0.04%
*
0.07%
0.02%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
63,290
0.26%
*
0.38%
0.08%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
46,223
0.01%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
63,290
0.00%
*
*
0.11%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
57,102
0.02%
*
*
*
0.01%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
57,102
0.35%
*
0.50%
0.10%
0.02%
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Truck Trailer Manufacturing
336212
1,000
15,247
0.07%
*
0.14%
0.02%
0.01%
*
*
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
23,798
0.06%
*
0.17%
0.02%
0.00%
*
*
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
15,247
0.06%
*
*
*
*
*
*
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
23,798
0.06%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
1,000
23,798
0.05%
*
0.13%
0.02%
0.01%
*
*
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
15,247
0.03%
*
0.06%
0.01%
0.01%
*
*
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
1,500
23,798
0.03%
*
0.09%
0.02%
0.01%
0.00%
*
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
15,247
0.03%
*
0.07%
0.01%
0.00%
*
*
Industrial
Motor Vehicle Metal Stamping
336370
1,000
15,247
0.04%
0.70%
0.09%
0.02%
0.01%
0.00%
*
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
45,144
0.11%
1.65%
0.21%
0.04%
0.01%
0.01%
*
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
23,798
0.06%
*
*
*
*
*
*
Industrial
Aircraft Manufacturing
336411
1,500
106,215
0.03%
*
1.03%
0.11%
0.03%
0.01%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
57,102
0.07%
2.71%
0.42%
0.06%
0.02%
0.01%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
50,126
0.12%
*
0.36%
0.07%
0.02%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion
Unit Parts Manufacturing
336415
1,250
15,247
0.01%
*
*
*
*
0.00%
*
Industrial
Railroad Rolling Stock
Manufacturing
336510
1,500
15,247
0.02%
*
0.06%
0.01%
0.00%
*
*
Industrial
Ship Building and Repairing
336611
1,250
53,375
0.14%
3.45%
0.48%
0.09%
0.04%
0.01%
0.00%
Industrial
Boat Building
336612
1,000
15,387
0.18%
*
0.14%
0.02%
0.01%
*
*
Industrial
Military Armored Vehicle, Tank,
and Tank Component
Manufacturing
336992
1,500
23,798
0.02%
*
*
0.03%
*
*
*
Industrial
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
750
8,823
0.52%
*
*
0.02%
0.01%
*
*
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
23,798
0.26%
*
*
0.07%
0.02%
*
*
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
40,400
2.21%
*
0.68%
0.14%
*
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Institutional Furniture
337127
500
15,247
0.22%
*
0.20%
0.04%
*
*
*
Manufacturing
Industrial
Wood Office Furniture
337211
1,000
63,290
0.86%
*
0.85%
0.13%
*
*
*
Manufacturing
Industrial
Office Furniture (except Wood)
337214
1,000
26,368
0.07%
*
0.29%
0.04%
0.01%
*
*
Manufacturing
Industrial
Showcase, Partition, Shelving, and
337215
500
15,247
0.23%
*
0.18%
0.04%
0.01%
*
*
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1,000
15,247
0.29%
*
0.18%
0.04%
*
*
*
Industrial
Surgical and Medical Instrument
339112
1,000
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
750
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Jewelry and Silverware
339910
500
**
**
**
* **
* **
* **
* **
Manufacturing
Industrial
Sporting and Athletic Goods
339920
750
**
**
**
**
**
**
* **
Manufacturing
Industrial
Office Supplies (except Paper)
339940
750
**
* **
**
**
* **
* **
* **
Manufacturing
Industrial
Gasket, Packing, and Sealing
339991
500
**
* **
**
**
**
* **
* **
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
15,247
0.21%
*
*
*
*
*
*
Industrial
All Other Miscellaneous
339999
500
23,798
1.12%
4.47%
0.34%
0.03%
*
*
*
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
* **
* **
* **
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
200
20,948
0.01%
0.03%
0.01%
*
*
*
*
Terminals
Commercial
Scheduled Passenger Air
481111
1,500
**
**
**
* **
* **
* **
* **
Transportation
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
* **
* **
* **
Energy
Pipeline Transportation of Crude
Oil
486110
1,500
**
**
**
* **
* **
* **
* **
Energy
Pipeline Transportation of Natural
(~tQ C
486210
$27.5 million
29,013
0.25%
0.59%
0.08%
*
*
*
*
Energy
VJas
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
* **
* **
* **
Petroleum Products
Commercial
Support Activities for Rail
488210
$15 million
15,247
0.37%
1.32%
0.21%
*
*
*
*
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
* **
* **
* **
Commercial
General Warehousing and Storage
493110
$27.5 million
24,809
1.34%
2.75%
0.84%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
23,798
0.92%
3.35%
0.66%
*
*
*
*
(continued)
-------
Table 6-5. Avoided Cost to Sales in Year 5 under the PRIMARY SCENARIO (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
to
to
00
Commercial
Commercial
Commercial
Commercial
Waste Treatment
Waste Treatment
Waste Treatment
Waste Treatment
Educational Services
Commercial
Commercial
Commercial
Lessors of Nonresidential Buildings
(except Mini warehouses)
Testing Laboratories
Research and Development in the
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
All Other Support Services
Hazardous Waste Treatment and
Disposal
Solid Waste Landfill
Solid Waste Combustors and
Incinerators
Remediation Services
Colleges, Universities, and
Professional Schools
Amusement and Theme Parks
Linen and Uniform Supply
Industrial Launderers
531120
541380
541715
561990
562211
562212
562213
562910
611310
713110
812330
$27.5 million
$15 million
1,000
$11 million
$38.5 million
$38.5 million
$38.5 million
$20.5 million
$27.5 million
$38.5 million
#N/A
87,950
63,290
23,798
15,247
40,400
**
* **
**
1.03%
1.46%
0.10%
4.95%
2.83%
0.41% 1.28%
**
* **
**
0.74%
0.46%
0.07%
0.21%
**
* **
* **
* **
* **
*
* **
* **
* **
* **
* **
* **
* **
* **
* **
* **
* **
* **
* **
* **
812332 $38.5 million
15,247
0.26% 0.98% 0.24%
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are estimated to obtain area source status. NA means it is not a valid 2012 NAICS code thus SBA Size Standards
are not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
"Zero facilities estimated to obtain area source status and no estimated net costs (savings); cost-to-sales ratios cannot be calculated.
*,"Denotes the data status as a combination of footnotes * and **.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020a. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD. August 2020.7-18, SBA February 2016 Size
Standards, SBA 2007 Size Standards.
-------
6.4 Implementing the Sales Test to Measure Impacts on Industrial, Commercial and
Other Sources under Alternative Scenario 1
For alternative scenario 1, the year 1 avoided costs-to-sales ratios are reported in
Table 6-6, and the year 5 avoided cost-to-sales ratios are reported in Table 6-7. The year 1
avoided cost-to-sales ratios range from -0.19 percent to less than 0.01 percent, with a median
avoided cost-to-sales ratio of less than 0.01 percent across all employment size categories. The
twenty-fifth percentile and seventy-fifth percentile avoided cost-to-sales ratio in year 1 are -0.01
percent and less than 0.01 percent respectively across all employment size categories. The year 5
avoided cost-to-sales ratios range from less than 0.01 percent to 5.69 percent, with a median
avoided cost-to-sales ratio of 0.05 percent across all employment size categories. The twenty-
fifth percentile and seventy-fifth percentile avoided cost-to-sales ratios in year 5 are 0.03 percent
and 0.23 percent respectively across all employment size categories.
Because facilities according to our analysis do not face permitting costs in year 5 and all
reclassifications will have taken place, the cost savings are larger and the resulting avoided cost-
to-sales ratios are higher in year 5 than year 1. For example, NAICS 493110 (General
Warehousing and Storage) has an overall year 1 avoided cost-to-sales ratio of -0.06 percent and
an overall year 5 avoided cost-to-sales ratio of 1.34 percent. All NAICS codes have negative
cost-to-sales ratios in year 1 and positive cost-to-sales ratios in year 5.
Like the primary scenario, we conducted a small entity analysis for both year 1 and year
5 impact estimates for the alternative scenario 1. In year 1, some small size categories have small
negative avoided cost-to-sales ratios. NAICS 424710 (Petroleum Bulk Stations and Terminals)
has an avoided cost-to-sales ratio of less than 0.01 percent for the "fewer than or equal to 19
employees" category and less than 0.01 percent for the "20 to 99 employees" category in year 1.
There are no cases of positive economic impacts for year 1, but there are cases of larger positive
economic impacts for small size categories in year 5. NAICS 332812 (Metal Coating, Engraving
(except Jewelry and Silverware), and Allied Services to Manufacturers) has an avoided cost-to-
sales ratio of -0.12 percent for the "fewer than or equal to 19 employees" category in year 1, and
NAICS 493190 (Other Warehousing and Storage) has a year 5 avoided cost-to-sales ratio of 3.35
percent for the same size category. Establishments in the "fewer than or equal to 19 employees"
size category for NAICS 493190 are considered small businesses for purposes of this analysis
because the average receipts per establishment is $0.7 million, which is less than the SBA size
standard of $27.5 million for this NAICS code.
229
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
115114
$27.5 million
* **
* **
* **
* **
* **
* **
* **
Cotton Ginning)
Energy
Crude Petroleum and Natural Gas
211111
1250 (Feb 2016 Size
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Extraction
Standards)
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
-$1,022
0.00%
0.00%
0.00%
0.00%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
* **
**
**
* **
* **
* **
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
**
* **
* **
* **
* **
* **
* **
Standards)
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
**
* **
* **
* **
**
* **
* **
Standards)
Industrial
All Other Metal Ore Mining
212299
750
**
* **
* **
**
* **
* **
* **
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
* **
Industrial
Kaolin and Ball Clay Mining
212324
750
**
* **
**
**
* **
* **
* **
Industrial
Potash, Soda, and Borate Mineral
212391
750
**
* **
* **
* **
**
* **
* **
Mining
Industrial
All Other Nonmetallic Mineral
212399
500
**
* **
**
* **
* **
* **
* **
Mining
Energy
Support Activities for Oil and Gas
213112
$38.5 million
-$1,022
-0.01%
-0.05%
-0.01%
0.00%
0.00%
0.00%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
-$1,022
-0.02%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power
221112
750
-$1,022
0.00%
*
*
*
*
*
*
Generation
Utilities
Biomass Electric Power Generation
221117
250
-$1,022
-0.01%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
-$1,022
-0.04%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007
-$1,022
-0.01%
*
*
*
*
*
*
Size Standards)
Utilities
Electric Power Distribution
221122
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation
221310
$27.5 million
-$1,022
-0.04%
*
*
*
*
*
*
Systems
Utilities
Sewage Treatment Facilities
221320
$20.5 million
-$1,022
-0.05%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
* **
**
* **
* **
* **
* **
Industrial
Wet Corn Milling
311221
1,250
**
* **
**
**
* **
* **
* **
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Oilseed Processing"
311223
1000 (2007 Size
**
* **
* **
* **
* **
* **
* **
Standards)
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Soybean and Other Oilseed
311224
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Processing
Industrial
Fats and Oils Refining and
311225
1,000
**
* **
**
* **
* **
* **
* **
Blending
Industrial
Beet Sugar Manufacturing
311313
750
**
* **
* **
* **
**
* **
* **
Industrial
Cane Sugar Manufacturing
311314
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1,000
**
* **
**
**
* **
* **
* **
Industrial
Specialty Canning
311422
1,250
**
* **
* **
* **
**
* **
* **
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
* **
Industrial
Dry, Condensed, and Evaporated
311514
750
**
* **
**
**
* **
* **
* **
Dairy Product Manufacturing
Industrial
Rendering and Meat Byproduct
311613
750
**
* **
**
**
* **
* **
* **
Processing
Industrial
Commercial Bakeries
311812
1,000
**
* **
**
**
**
* **
* **
Industrial
Other Snack Food Manufacturing
311919
1,250
**
* **
**
**
* **
* **
* **
Industrial
Coffee and Tea Manufacturing
311920
750
**
* **
**
**
* **
* **
* **
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
500
**
* **
**
**
* **
* **
* **
Industrial
All Other Miscellaneous Food
311999
500
**
* **
**
**
**
* **
* **
Manufacturing
Industrial
Breweries
312120
1,250
-$1,022
0.00%
*
-0.01%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Tobacco Manufacturing
312230
1,500
**
* **
* **
**
**
* **
* **
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Broadwoven Fabric Finishing
313311
1000 (2007 Size
-$1,022
-0.01%
*
*
*
*
*
*
MillsA
Standards)
Industrial
Fabric Coating Mills
313320
1,000
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size
**
* **
* **
* **
* **
* **
* **
Standards)
Industrial
Leather and Hide Tanning and
316110
500
-$1,022
-0.01%
*
0.00%
0.00%
*
*
*
Finishing
Industrial
Sawmills
321113
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Wood Preservation
321114
500
**
* **
**
* **
* **
* **
* **
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Hardwood Veneer and Plywood
Manufacturing
321211
500
**
* **
* **
**
* **
* **
* **
Industrial
Softwood Veneer and Plywood
Manufacturing
321212
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Engineered Wood Member (except
Truss) Manufacturing
321213
750
**
* **
* **
**
* **
* **
* **
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Wood Window and Door
Manufacturing
321911
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
**
**
**
* **
* **
* **
* **
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
500
**
**
**
**
* **
* **
* **
Industrial
Pulp Mills
322110
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
-$1,022
0.00%
-0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Sanitary Paper Product
Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
-$1,022
-0.03%
*
*
*
*
*
*
Industrial
Commercial Printing (except
Screen and Books)
323111
500
-$1,022
-0.03%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Books Printing
323117
1,250
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
Petroleum Refineries
324110
1,500
-$1,037
0.00%
*
0.00%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal
Products Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
-$1,020
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
-$1,022
-0.01%
-0.01%
0.00%
*
*
*
*
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1,000
**
* **
**
**
* **
* **
* **
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size
Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Alkalies and Chlorine
ManufacturingA
325181
1000 (2007 Size
Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
-$1,040
0.00%
*
*
*
*
*
*
Industrial
All Other Basic Inorganic Chemical
ManufacturingA
325188
1000 (2007 Size
Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Cyclic Crude and Intermediate
ManufacturingA
325192
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and
Gum and Wood Chemical
Manufacturing
325194
1,250
**
* **
**
**
* **
* **
* **
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Plastics Material and Resin
Manufacturing
325211
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Synthetic Rubber Manufacturing
325212
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
1000 (2007 Size
Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Nitrogenous Fertilizer
Manufacturing
325311
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Medicinal and Botanical
Manufacturing
325411
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Biological Product (except
Diagnostic) Manufacturing
325414
1,250
**
* **
* **
**
**
**
* **
Industrial
Paint and Coating Manufacturing
325510
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
0.00%
-0.02%
0.00%
0.00%
*
*
*
**
* **
**
* **
* **
* **
* **
**
**
**
**
**
**
* **
**
* **
* **
* **
* **
* **
* **
0.00%
*
0.00%
0.00%
*
*
*
0.00%
*
0.00%
0.00%
*
*
*
-0.01%
-0.03%
0.00%
0.00%
0.00%
*
*
0.00%
-0.03%
0.00%
0.00%
*
*
*
0.00%
*
0.00%
0.00%
0.00%
*
*
**
* **
**
**
* **
* **
* **
**
**
**
**
* **
* **
* **
-0.01%
*
-0.01%
*
*
*
*
**
* **
**
**
**
* **
* **
-0.01%
*
-0.01%
0.00%
*
*
*
**
* **
**
* **
* **
* **
* **
-0.01%
-0.07%
-0.01%
0.00%
0.00%
0.00%
*
0.00%
*
*
0.00%
0.00%
0.00%
*
0.00%
*
*
0.00%
0.00%
*
*
**
* **
* **
**
**
* **
* **
-0.01%
-0.05%
-0.01%
0.00%
*
*
*
to
LtJ
Industrial Adhesive Manufacturing 325520
Industrial Surface Active Agent 325613
Manufacturing
Industrial Toilet Preparation Manufacturing 325620
Industrial Explosives Manufacturing 325920
Industrial Custom Compounding of Purchased 325991
Resins
Industrial Photographic Film, Paper, Plate, 325992
and Chemical Manufacturing
Industrial All Other Miscellaneous Chemical 325998
Product and Preparation
Manufacturing
Industrial Plastics Packaging Film and Sheet 326112
(including Laminated)
Manufacturing
Industrial Unlaminated Plastics Film and 326113
Sheet (except Packaging)
Manufacturing
Industrial Unlaminated Plastics Profile Shape 326121
Manufacturing
Industrial Plastics Pipe and Pipe Fitting 326122
Manufacturing
Industrial Laminated Plastics Plate, Sheet 326130
(except Packaging), and Shape
Manufacturing
Industrial Polystyrene Foam Product 326140
Manufacturing
Industrial Urethane and Other Foam Product 326150
(except Polystyrene) Manufacturing
Industrial Plastics Plumbing Fixture 326191
Manufacturing
Industrial All Other Plastics Product 326199
Manufacturing
Industrial Tire Manufacturing (except 326211
Retreading)
Industrial Rubber and Plastics Hoses and 326220
Belting Manufacturing
Industrial Rubber Product Manufacturing for 326291
Mechanical Use
Industrial All Other Rubber Product 326299
Manufacturing
500
750
1,250
750
500
1,500
500
1,000
750
500
750
500
1,000
750
750
750
1,500
750
750
500
-$1,022
-$1,022
-$1,022
-$1,022
-$1,022
-$1,022
-$1,022
-$1,004
-$1,022
-$1,052
-$1,022
-$1,022
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
-$1,097
-0.03%
*
-0.02%
0.00%
*
*
*
Industrial
Clay Building Material and
Refractories Manufacturing
327120
750
-$1,022
-0.01%
-0.06%
-0.01%
0.00%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
-$975
-0.01%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Other Pressed and Blown Glass
and Glassware Manufacturing
327212
1,250
-$1,022
-0.01%
*
*
*
0.00%
*
*
Industrial
Cement Manufacturing
327310
1,000
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Gypsum Product Manufacturing
327420
1,500
**
* **
**
* **
* **
* **
* **
Industrial
Abrasive Product Manufacturing
327910
750
-$1,022
-0.01%
-0.04%
-0.01%
0.00%
o'.oo%
*
*
Industrial
Mineral Wool Manufacturing
327993
1,500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
327999
500
**
* **
**
* **
* **
* **
* **
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size
Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
331210
1,000
-$1,022
0.00%
-0.02%
0.00%
0.00%
0.00%
0.00%
*
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Primary Aluminum Production"
331312
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
**
* **
**
**
**
* **
* **
Industrial
Secondary Smelting and Alloying
of Aluminum
331314
750
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Aluminum Extruded Product
Manufacturing"
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Aluminum Rolling,
Drawing, and Extruding
331318
750
**
* **
* **
**
* **
* **
* **
Industrial
Nonferrous Metal (except
Aluminum) Smelting and Refining
331410
1,000
**
* **
**
* **
**
* **
* **
Industrial
Primary Smelting and Refining of
Copper"
331411
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
* **
* **
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper
and Aluminum)A
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Copper Rolling, Drawing,
Extruding, and Alloying
331420
1,000
**
* **
**
**
**
*
**
* **
Industrial
Copper Wire (except Mechanical)
DrawingA
331422
1000 (2007 Size
Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Nonferrous Metal (except Copper
and Aluminum) Rolling, Drawing,
and Extruding
331491
750
**
* **
**
**
* **
*
**
* **
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal
(except Copper and Aluminum)
331492
750
**
* **
**
**
* **
*
**
* **
Industrial
Iron Foundries
331511
1,000
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
*
**
* **
Industrial
Aluminum Die-Casting FoundriesA
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
*
**
* **
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
*
**
* **
Industrial
Nonferrous Forging
332112
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Hand and Edge Tool
ManufacturingA
332212
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
-$1,022
-0.02%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Other Metal Container
Manufacturing
332439
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and
Washer Manufacturing
332722
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Metal Heat Treating
332811
750
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
-$1,022
-0.02%
-0.12%
-0.01%
0.00%
*
*
*
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
-$1,022
-0.03%
-0.12%
-0.02%
*
*
*
*
Industrial
Other Fabricated Metal
Manufacturing
332990
#N/A
-$1,022
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
-$1,022
0.00%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
-$1,022
-0.02%
-0.11%
-0.01%
0.00%
0.00%
*
*
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden Equipment
Manufacturing
333112
1,500
**
* **
* **
**
**
* **
*
**
Industrial
Construction Machinery
Manufacturing
333120
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
*
**
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
*
**
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1,250
**
**
**
**
**
**
*
**
Industrial
Machine Tool (Metal Cutting
Types) ManufacturingA
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Machine Tool (Metal Forming
Types) Manufacturing"
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
*
**
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1,250
**
* **
**
**
* **
* **
*
**
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
*
**
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Radio and Television Broadcasting
and Wireless Communications
Equipment Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
-$1,003
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
Industrial
Blank Magnetic and Optical
Recording Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
-$1,022
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
-$1,022
0.00%
*
*
*
0.00%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor and Generator
Manufacturing
335312
1,250
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Noncurrent-Carrying Wiring
Device Manufacturing
335932
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
-$1,022
0.00%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
-$1,022
0.00%
*
*
0.00%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
-$1,022
0.00%
*
*
*
0.00%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Truck Trailer Manufacturing
336212
1,000
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
**
* **
**
**
**
* **
* **
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
1,000
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
1,500
**
* **
**
**
**
**
* **
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Metal Stamping
336370
1,000
**
**
**
**
**
**
* **
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Aircraft Manufacturing
336411
1,500
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
-$1,022
0.00%
-0.05%
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion
Unit Parts Manufacturing
336415
1,250
**
* **
* **
* **
* **
**
* **
Industrial
Railroad Rolling Stock
Manufacturing
336510
1,500
**
* **
**
**
**
* **
* **
Industrial
Ship Building and Repairing
336611
1,250
-$1,022
0.00%
-0.07%
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Boat Building
336612
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Military Armored Vehicle, Tank,
and Tank Component
Manufacturing
336992
1,500
**
* **
* **
**
* **
* **
* **
Industrial
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
750
-$1,022
-0.06%
*
*
0.00%
0.00%
*
*
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
-$1,022
-0.06%
*
-0.02%
0.00%
*
*
*
Industrial
Institutional Furniture
Manufacturing
337127
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Wood Office Furniture
Manufacturing
337211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
100- 500- 1000-
All <19 20-99 499 999 2499 >2500
Industrial
Office Furniture (except Wood)
337214
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Manufacturing
Industrial
Showcase, Partition, Shelving, and
337215
500
-$1,022
-0.02%
*
-0.01%
0.00%
0.00%
*
*
Locker Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Surgical and Medical Instrument
339112
1,000
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
750
**
* **
* **
**
**
**
* **
Manufacturing
Industrial
Jewelry and Silverware
339910
500
**
**
**
* **
* **
* **
* **
Manufacturing
Industrial
Sporting and Athletic Goods
339920
750
**
**
**
**
**
**
* **
Manufacturing
Industrial
Office Supplies (except Paper)
339940
750
**
* **
**
**
* **
* **
* **
Manufacturing
Industrial
Gasket, Packing, and Sealing
339991
500
**
* **
**
**
**
* **
* **
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
All Other Miscellaneous
339999
500
-$1,022
-0.05%
-0.19%
-0.01%
0.00%
*
*
*
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
* **
* **
* **
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
200
-$1,022
0.00%
0.00%
0.00%
*
*
*
*
Terminals
Commercial
Scheduled Passenger Air
481111
1,500
**
**
**
* **
* **
* **
* **
Transportation
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
* **
* **
* **
Energy
Pipeline Transportation of Crude
Oil
486110
1,500
**
**
**
* **
* **
* **
* **
Energy
Pipeline Transportation of Natural
486210
$27.5 million
-$1,022
-0.01%
-0.02%
0.00%
*
*
*
*
Energy
OclS
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
* **
* **
* **
Petroleum Products
Commercial
Support Activities for Rail
488210
$15 million
-$1,022
-0.03%
-0.09%
-0.01%
*
*
*
*
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
* **
* **
* **
Commercial
General Warehousing and Storage
493110
$27.5 million
-$1,022
-0.06%
-0.11%
-0.03%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
-$1,022
-0.04%
-0.14%
-0.03%
*
*
*
*
Commercial
Lessors of Nonresidential Buildings
531120
$27.5 million
**
**
**
* **
* **
* **
* **
(except Mini warehouses)
Commercial
Testing Laboratories
541380
$15 million
**
**
**
* **
* **
* **
* **
(continued)
-------
Table 6-6. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Commercial
Research and Development in the
541715
1,000
* **
* **
* **
* **
* **
* **
* **
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
Commercial
All Other Support Services
561990
$11 million
**
**
**
* **
* **
* **
* **
Waste Treatment
Hazardous Waste Treatment and
562211
$38.5 million
-$1,022
-0.01%
-0.06%
-0.01%
*
*
*
*
Disposal
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
-$1,022
-0.02%
-0.05%
-0.01%
*
*
*
*
Waste Treatment
Solid Waste Combustors and
562213
$38.5 million
-$1,022
0.00%
*
0.00%
*
*
*
*
Incinerators
Waste Treatment
Remediation Services
562910
$20.5 million
**
**
**
* **
* **
* **
* **
Educational Services
Colleges, Universities, and
611310
$27.5 million
-$1,022
*
*
*
*
*
*
*
Professional Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
**
**
**
* **
* **
* **
* **
Commercial
Linen and Uniform Supply
812330
#N/A
* **
* **
* **
* **
* **
* **
* **
Commercial
Industrial Launderers
812332
$38.5 million
-$1,022
-0.02%
-0.07%
-0.02%
*
*
*
*
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are eligible to obtain area source status. NA means it is not a valid 2012 NAICS code, thus SBA Size Standards are
not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
"Zero facilities estimated to obtain area source status and no estimated net costs (savings); cost-to-sales ratios cannot be calculated.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020a. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD. August, 2020.7-18, SBA February 2016 Size
Standards, SBA 2007 Size Standards.
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
115114
$27.5 million
* **
* **
* **
* **
* **
* **
*
**
Cotton Ginning)
Energy
Crude Petroleum and Natural Gas
211111
1250 (Feb 2016 Size
11,168
0.02%
*
0.01%
0.00%
0.00%
0.00%
*
Extraction
Standards)
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
40,400
0.03%
0.06%
0.03%
0.01%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
* **
**
**
* **
* **
*
**
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
**
* **
* **
* **
* **
* **
*
**
Standards)
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
**
* **
* **
* **
**
* **
*
**
Standards)
Industrial
All Other Metal Ore Mining
212299
750
**
* **
* **
**
* **
* **
*
**
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
*
**
Industrial
Kaolin and Ball Clay Mining
212324
750
**
* **
**
**
* **
* **
*
**
Industrial
Potash, Soda, and Borate Mineral
212391
750
**
* **
* **
* **
**
* **
*
**
Mining
Industrial
All Other Nonmetallic Mineral
212399
500
**
* **
**
* **
* **
* **
*
**
Mining
Energy
Support Activities for Oil and Gas
213112
$38.5 million
15,247
0.16%
0.69%
0.16%
0.03%
0.01%
0.00%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
15,247
0.23%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power
221112
750
41,506
0.07%
*
*
*
*
*
*
Generation
Utilities
Biomass Electric Power Generation
221117
250
63,290
0.87%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
15,247
0.59%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
57,102
0.52%
*
*
*
*
*
*
Standards)
Utilities
Electric Power Distribution
221122
1,000
15,247
0.03%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
45,144
0.11%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation
221310
$27.5 million
23,798
0.94%
*
*
*
*
*
*
Systems
Utilities
Sewage Treatment Facilities
221320
$20.5 million
25,316
1.21%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
34,071
0.21%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
* **
**
* **
* **
* **
*
**
Industrial
Wet Corn Milling
311221
1,250
**
* **
**
**
* **
* **
*
**
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Soybean and Other Oilseed
311224
1,000
35,287
0.01%
*
0.01%
*
*
*
*
Processing
Industrial
Fats and Oils Refining and Blending 311225
1,000
**
* **
**
* **
* **
* **
*
**
Industrial
Beet Sugar Manufacturing
311313
750
**
* **
* **
* **
**
* **
*
**
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Cane Sugar Manufacturing
311314
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1,000
**
* **
**
**
* **
* **
* **
Industrial
Specialty Canning
311422
1,250
**
* **
* **
* **
**
* **
* **
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
* **
Industrial
Dry, Condensed, and Evaporated
311514
750
**
* **
**
**
* **
* **
* **
Dairy Product Manufacturing
Industrial
Rendering and Meat Byproduct
311613
750
**
* **
**
**
* **
* **
* **
Processing
Industrial
Commercial Bakeries
311812
1,000
**
* **
**
**
**
* **
* **
Industrial
Other Snack Food Manufacturing
311919
1,250
**
* **
**
**
* **
* **
* **
Industrial
Coffee and Tea Manufacturing
311920
750
**
* **
**
**
* **
* **
* **
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
500
**
* **
**
**
* **
* **
* **
Industrial
All Other Miscellaneous Food
311999
500
**
* **
**
**
**
* **
* **
Manufacturing
Industrial
Breweries
312120
1,250
15,247
0.04%
*
0.10%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Tobacco Manufacturing
312230
1,500
**
* **
* **
**
**
* **
* **
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
15,247
0.06%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
15,247
0.23%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
23,798
0.17%
*
0.19%
0.04%
0.02%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
15,247
0.22%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
15,247
0.24%
*
0.12%
0.03%
*
*
*
Industrial
Broadwoven Fabric Finishing
313311
1000 (2007 Size Standards)
23,798
0.33%
*
*
*
*
*
*
MillsA
Industrial
Fabric Coating Mills
313320
1,000
20,646
0.15%
*
0.11%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Leather and Hide Tanning and
316110
500
13,119
0.16%
*
0.04%
0.02%
*
*
*
Finishing
Industrial
Sawmills
321113
500
43,544
0.63%
3.10%
0.32%
0.08%
*
*
*
Industrial
Wood Preservation
321114
500
**
* **
**
* **
* **
* **
* **
Industrial
Hardwood Veneer and Plywood
321211
500
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
1,250
20,948
0.05%
*
*
0.02%
0.01%
*
*
Manufacturing
Industrial
Engineered Wood Member (except
321213
750
**
* **
* **
**
* **
* **
* **
Truss) Manufacturing
Industrial
Reconstituted Wood Product
321219
750
25,784
0.08%
*
*
0.03%
*
*
*
Manufacturing
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Wood Window and Door
Manufacturing
321911
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
**
**
**
* **
* **
* **
* **
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
500
**
**
**
**
* **
* **
* **
Industrial
Pulp Mills
322110
750
20,948
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
12,986
0.00%
*
*
0.01%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
15,247
0.01%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
50,126
0.03%
*
*
0.02%
0.01%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
958
0.00%
0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
23,798
0.08%
*
0.11%
0.03%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
23,798
0.08%
*
*
*
*
*
*
Industrial
Sanitary Paper Product
Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
15,247
0.37%
*
*
*
*
*
*
Industrial
Commercial Printing (except Screen
and Books)
323111
500
20,192
0.58%
*
0.24%
0.05%
0.01%
*
*
Industrial
Books Printing
323117
1,250
23,798
0.25%
*
*
0.05%
0.02%
*
*
Industrial
Petroleum Refineries
324110
1,500
97,382
0.00%
*
0.04%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal
Products Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
15,982
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
15,247
0.09%
0.22%
0.06%
*
*
*
*
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1,000
**
* **
**
**
* **
* **
* **
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
15,247
0.02%
*
*
*
*
*
*
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1,000
23,798
0.04%
*
0.04%
0.01%
0.01%
*
*
Industrial
Alkalies and Chlorine
ManufacturingA
325181
1000 (2007 Size Standards)
22,921
0.01%
*
*
*
*
*
*
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
28,397
0.03%
*
*
*
*
*
*
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Basic Inorganic Chemical
ManufacturingA
325188
1000 (2007 Size Standards)
28,199
0.06%
*
*
*
*
*
*
Industrial
Cyclic Crude and Intermediate
ManufacturingA
325192
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
23,798
0.01%
*
0.01%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and
Gum and Wood Chemical
Manufacturing
325194
1,250
**
* **
**
**
* **
* **
* **
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
1,250
60,117
0.05%
*
0.10%
0.02%
0.00%
0.00%
*
Industrial
Plastics Material and Resin
Manufacturing
325211
1,250
33,170
0.04%
*
0.07%
0.01%
0.00%
0.00%
*
Industrial
Synthetic Rubber Manufacturing
325212
1,000
6,981
0.01%
*
0.01%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
1,000
23,798
0.03%
*
0.10%
0.02%
0.00%
*
*
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
1000 (2007 Size Standards)
26,809
0.04%
*
*
*
*
*
*
Industrial
Nitrogenous Fertilizer
Manufacturing
325311
1,000
63,290
0.12%
*
0.11%
*
*
*
*
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
23,798
0.01%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1,000
52,514
0.07%
*
0.08%
0.02%
*
*
*
Industrial
Medicinal and Botanical
Manufacturing
325411
1,000
15,247
0.05%
*
0.08%
0.02%
0.00%
*
*
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1,250
12,184
0.01%
*
*
0.00%
0.00%
0.00%
*
Industrial
Biological Product (except
Diagnostic) Manufacturing
325414
1,250
**
* **
* **
**
**
**
* **
Industrial
Paint and Coating Manufacturing
325510
1,000
128,442
0.58%
*
0.41%
0.09%
*
*
*
Industrial
Adhesive Manufacturing
325520
500
15,247
0.06%
0.35%
0.05%
0.01%
*
*
*
Industrial
Surface Active Agent
Manufacturing
325613
750
**
* **
**
* **
* **
* **
* **
Industrial
Toilet Preparation Manufacturing
325620
1,250
**
**
**
**
**
**
* **
Industrial
Explosives Manufacturing
325920
750
**
* **
* **
* **
* **
* **
* **
Industrial
Custom Compounding of Purchased
Resins
325991
500
23,798
0.10%
*
0.08%
0.02%
*
*
*
Industrial
Photographic Film, Paper, Plate,
and Chemical Manufacturing
325992
1,500
15,247
0.05%
*
0.07%
0.01%
*
*
*
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Miscellaneous Chemical
Product and Preparation
Manufacturing
325998
500
23,798
0.13%
0.73%
0.08%
0.02%
0.01%
*
*
Industrial
Plastics Packaging Film and Sheet
(including Laminated)
Manufacturing
326112
1,000
23,798
0.07%
0.73%
0.11%
0.03%
*
*
*
Industrial
Unlaminated Plastics Film and
Sheet (except Packaging)
Manufacturing
326113
750
50,126
0.16%
*
0.22%
0.05%
0.02%
*
*
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
**
* **
**
**
* **
* **
* **
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
**
**
**
**
* **
* **
* **
Industrial
Laminated Plastics Plate, Sheet
(except Packaging), and Shape
Manufacturing
326130
500
23,798
0.15%
*
0.14%
*
*
*
*
Industrial
Polystyrene Foam Product
Manufacturing
326140
1,000
**
* **
**
**
**
* **
* **
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
10,726
0.07%
*
0.06%
0.02%
*
*
*
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Plastics Product
Manufacturing
326199
750
42,540
0.31%
2.73%
0.36%
0.08%
0.02%
0.01%
*
Industrial
Tire Manufacturing (except
Retreading)
326211
1,500
40,779
0.02%
*
*
0.03%
0.01%
0.01%
*
Industrial
Rubber and Plastics Hoses and
Belting Manufacturing
326220
750
23,798
0.11%
*
*
0.03%
0.02%
*
*
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
**
* **
* **
**
**
* **
* **
Industrial
All Other Rubber Product
Manufacturing
326299
500
20,948
0.12%
1.02%
0.14%
0.03%
*
*
*
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
16,425
0.47%
*
0.23%
0.04%
*
*
*
Industrial
Clay Building Material and
Refractories Manufacturing
327120
750
14,991
0.16%
0.89%
0.14%
0.03%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
14,600
0.15%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1,250
17,311
0.19%
*
*
*
0.01%
*
*
Industrial
Cement Manufacturing
327310
1,000
23,798
0.09%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
15,247
0.06%
*
*
*
*
*
*
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Gypsum Product Manufacturing
327420
1,500
**
* **
**
* **
* **
* **
*
**
Industrial
Abrasive Product Manufacturing
327910
750
15,247
0.08%
0.65%
0.09%
o'oi%
o'.oo%
*
*
Industrial
Mineral Wool Manufacturing
327993
1,500
27,554
0.14%
*
0.19%
0.03%
*
*
*
Industrial
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
327999
500
**
* **
**
* **
* **
* **
*
**
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
34,964
0.01%
*
*
0.01%
0.00%
0.00%
*
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size Standards)
23,798
0.01%
*
*
*
*
*
*
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
331210
1,000
15,247
0.02%
0.30%
0.05%
0.01%
0.00%
0.00%
*
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
15,247
0.05%
*
0.04%
*
*
*
*
Industrial
Primary Aluminum Production"
331312
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
**
* **
**
**
**
* **
*
**
Industrial
Secondary Smelting and Alloying
of Aluminum
331314
750
2,987
0.01%
*
0.01%
*
*
*
*
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
15,247
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Aluminum Extruded Product
Manufacturing"
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Aluminum Rolling, Drawing,
and Extruding
331318
750
**
* **
* **
**
* **
* **
*
**
Industrial
Nonferrous Metal (except
Aluminum) Smelting and Refining
331410
1,000
**
* **
**
* **
**
* **
*
**
Industrial
Primary Smelting and Refining of
Copper"
331411
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper
and Aluminum)"
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Copper Rolling, Drawing,
Extruding, and Alloying
331420
1,000
**
* **
**
**
**
* **
*
**
Industrial
Copper Wire (except Mechanical)
Drawing"
331422
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Nonferrous Metal (except Copper
and Aluminum) Rolling, Drawing,
and Extruding
331491
750
**
* **
**
**
* **
* **
*
**
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal
(except Copper and Aluminum)
331492
750
**
* **
**
**
* **
* **
* **
Industrial
Iron Foundries
331511
1,000
20,948
0.07%
*
*
0.03%
0.01%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
* **
* **
Industrial
Aluminum Die-Casting Foundries'^
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
* **
* **
Industrial
Nonferrous Forging
332112
750
15,247
0.03%
*
*
0.02%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
500
15,247
0.18%
1.08%
0.15%
0.03%
0.01%
*
*
Industrial
Hand and Edge Tool
ManufacturingA
332212
500 (2007 Size Standards)
15,247
0.25%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
15,247
0.15%
*
0.10%
0.03%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
15,247
0.16%
*
0.11%
0.02%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
63,290
0.64%
*
0.61%
0.13%
0.04%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
15,247
0.29%
1.11%
0.17%
0.04%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
47,702
0.05%
*
0.08%
0.03%
*
*
*
Industrial
Other Metal Container
Manufacturing
332439
500
23,798
0.21%
1.69%
0.15%
0.05%
0.01%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
500
15,247
0.12%
1.00%
0.12%
0.03%
0.01%
*
*
Industrial
Metal Heat Treating
332811
750
15,247
0.17%
*
0.17%
*
*
*
*
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
47,954
0.86%
5.69%
0.46%
0.06%
*
*
*
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
23,798
0.74%
2.90%
0.39%
*
*
*
*
Industrial
Other Fabricated Metal
Manufacturing
332990
#N/A
15,247
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
15,247
0.04%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
23,798
0.03%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
23,798
0.57%
2.65%
0.29%
0.05%
0.01%
*
*
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
20,948
0.06%
*
0.16%
0.02%
0.00%
0.00%
*
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden Equipment
Manufacturing
333112
1,500
**
* **
* **
**
**
* **
* **
Industrial
Construction Machinery
Manufacturing
333120
1,250
12,537
0.02%
*
0.08%
0.01%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
* **
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
* **
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1,250
**
**
**
**
**
**
* **
Industrial
Machine Tool (Metal Cutting
Types) ManufacturingA
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Machine Tool (Metal Forming
Types) ManufacturingA
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
* **
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
23,798
0.03%
0.94%
0.11%
0.02%
0.00%
0.00%
*
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1,250
**
* **
**
**
* **
* **
* **
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
* **
Industrial
Radio and Television Broadcasting
and Wireless Communications
Equipment Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube ManufacturingA
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
39,543
0.07%
*
0.13%
0.05%
0.01%
0.00%
*
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Blank Magnetic and Optical
Recording Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
15,247
0.05%
*
*
0.03%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
36,433
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
23,798
0.01%
*
*
*
0.01%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
15,247
0.06%
*
0.11%
0.02%
0.01%
*
*
Industrial
Motor and Generator Manufacturing
335312
1,250
23,798
0.09%
*
0.20%
0.03%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
15,247
0.03%
*
*
0.02%
0.01%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
15,247
0.09%
*
0.13%
0.03%
0.01%
*
*
Industrial
Noncurrent-Carrying Wiring Device
Manufacturing
335932
1,000
15,247
0.04%
*
0.07%
0.02%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
63,290
0.26%
*
0.38%
0.08%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
43,396
0.01%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
23,798
0.00%
*
*
0.04%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
23,798
0.01%
*
*
*
0.00%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
23,798
0.15%
*
0.21%
0.04%
0.01%
*
*
Industrial
Truck Trailer Manufacturing
336212
1,000
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
**
* **
**
**
**
* **
* **
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
15,247
0.04%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
1,000
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
1,500
**
* **
**
**
**
**
* **
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
**
* **
**
**
**
* **
* **
Industrial
Motor Vehicle Metal Stamping
336370
1,000
**
**
**
**
**
**
* **
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
20,948
0.05%
0.77%
0.10%
0.02%
0.01%
0.00%
*
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Aircraft Manufacturing
336411
1,500
109,348
0.03%
*
1.06%
0.11%
0.04%
0.01%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
23,798
0.03%
1.13%
0.17%
0.02%
0.01%
0.00%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
20,948
0.05%
*
0.15%
0.03%
0.01%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion
Unit Parts Manufacturing
336415
1,250
**
* **
* **
* **
* **
**
* **
Industrial
Railroad Rolling Stock
Manufacturing
336510
1,500
**
* **
**
**
**
* **
* **
Industrial
Ship Building and Repairing
336611
1,250
49,758
0.13%
3.22%
0.45%
0.08%
0.03%
0.01%
0.00%
Industrial
Boat Building
336612
1,000
14,721
0.17%
*
0.14%
0.02%
0.01%
*
*
Industrial
Military Armored Vehicle, Tank,
and Tank Component
Manufacturing
336992
1,500
**
* **
* **
**
* **
* **
* **
Industrial
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
750
8,932
0.53%
*
*
0.02%
0.01%
*
*
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
23,798
0.26%
*
*
0.07%
0.02%
*
*
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
43,544
2.38%
*
0.74%
0.15%
*
*
*
Industrial
Institutional Furniture
Manufacturing
337127
500
15,247
0.22%
*
0.20%
0.04%
*
*
*
Industrial
Wood Office Furniture
Manufacturing
337211
1,000
63,290
0.86%
*
0.85%
0.13%
*
*
*
Industrial
Office Furniture (except Wood)
Manufacturing
337214
1,000
26,321
0.07%
*
0.29%
0.04%
0.01%
*
*
Industrial
Showcase, Partition, Shelving, and
Locker Manufacturing
337215
500
15,247
0.23%
*
0.18%
0.04%
0.01%
*
*
Industrial
Blind and Shade Manufacturing
337920
1,000
15,247
0.29%
*
0.18%
0.04%
*
*
*
Industrial
Surgical and Medical Instrument
Manufacturing
339112
1,000
**
* **
* **
**
**
**
* **
Industrial
Surgical Appliance and Supplies
Manufacturing
339113
750
**
* **
* **
**
**
**
* **
Industrial
Jewelry and Silverware
Manufacturing
339910
500
**
**
**
* **
* **
* **
* **
Industrial
Sporting and Athletic Goods
Manufacturing
339920
750
**
**
**
**
**
**
* **
Industrial
Office Supplies (except Paper)
Manufacturing
339940
750
**
* **
**
**
* **
* **
* **
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Gasket, Packing, and Sealing
339991
500
**
* **
**
**
**
*
**
*
**
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
15,247
0.21%
*
*
*
*
*
*
Industrial
All Other Miscellaneous
339999
500
23,798
1.12%
4.47%
0.34%
0.03%
*
*
*
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
*
**
*
**
*
**
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
200
23,798
0.01%
0.03%
0.01%
*
*
*
*
Terminals
Commercial
Scheduled Passenger Air
481111
1,500
**
**
**
* **
*
**
*
**
*
**
Transportation
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
*
**
*
**
*
**
Energy
Pipeline Transportation of Crude
Oil
486110
1,500
**
**
**
* **
*
**
*
**
*
**
Energy
V_J11
Pipeline Transportation of Natural
CtQ C
486210
$27.5 million
27,963
0.24%
0.56%
0.08%
*
*
*
*
Energy
VJas
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
*
**
*
**
*
**
Petroleum Products
Commercial
Support Activities for Rail
488210
$15 million
15,247
0.37%
1.32%
0.21%
*
*
*
*
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
*
**
*
**
*
**
Commercial
General Warehousing and Storage
493110
$27.5 million
24,809
1.34%
2.75%
0.84%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
23,798
0.92%
3.35%
0.66%
*
*
*
*
Commercial
Lessors of Nonresidential Buildings
531120
$27.5 million
**
**
**
* **
*
**
*
**
*
**
(except Miniwarehouses)
Commercial
Testing Laboratories
541380
$15 million
**
**
**
* **
*
**
*
**
*
**
Commercial
Research and Development in the
541715
1,000
* **
* **
* **
* **
*
**
*
**
*
**
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
Commercial
All Other Support Services
561990
$11 million
**
**
**
* **
*
**
*
**
*
**
Waste Treatment
Hazardous Waste Treatment and
562211
$38.5 million
89,681
1.05%
5.05%
0.75%
*
*
*
*
Disposal
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
23,798
0.55%
1.06%
0.17%
*
*
*
*
Waste Treatment
Solid Waste Combustors and
562213
$38.5 million
15,247
0.06%
*
0.04%
*
*
*
*
Incinerators
Waste Treatment
Remediation Services
562910
$20.5 million
**
**
**
* **
*
**
*
**
*
**
Educational Services
Colleges, Universities, and
611310
$27.5 million
43,544
*
*
*
*
*
*
*
Professional Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
**
**
**
* **
*
**
*
**
*
**
to
to
(continued)
-------
Table 6-7. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 1 (continued)
Average
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99 499
999
2499 >2500
Commercial
Linen and Uniform Supply
812330
#N/A
* **
* **
*, ** *, **
* **
* ** **
Commercial
Industrial Launderers
812332
$38.5 million
15,247
0.26%
0.98%
0.24% *
*
* *
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are eligible to obtain area source status. NA means it is not a valid 2012 NAICS code, thus an SBA Size Standard
is not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
"Zero facilities estimated to obtain area source status and no estimated net costs (savings); cost-to-sales ratios cannot be calculated.
*,"Denotes a data status as a combination of footnotes * and **.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020a. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August b. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final rulemaking
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.SBA February 2016 Size Standards, SBA 2007 Size Standards.
to
LtJ
-------
6.5 Implementing the Sales Test to Measure Impacts on Industrial, Commercial and
Other Sources under Alternative Scenario 2
For alternative scenario 2, the year 1 cost-to-sales ratios are reported in Table 6-8, and the
year 5 avoided cost-to-sales ratios are reported in Table 6-9. The year 1 avoided cost-to-sales
ratios range from -0.19 percent to less than 0.01 percent, with a median avoided cost-to-sales
ratio of less than 0.01 percent across all employment size categories. The twenty-fifth percentile
and seventy-fifth percentile avoided cost-to-sales ratio in year 1 are -0.01 percent and less than
0.01 percent respectively across all employment size categories. The year 5 avoided cost-to-sales
ratios range from less than 0.01 percent to 5.75 percent, with a median avoided cost-to-sales ratio
of 0.06 percent across all employment size categories. The twenty-fifth percentile and seventy-
fifth percentile avoided cost-to-sales ratio in year 5 are 0.02 percent and 0.18 percent,
respectively, across all employment size categories.
Because facilities that may reclassify would not face permitting costs in year 5 and all
reclassifications would be expected to have occurred by year 5, the cost savings are generally
larger and the resulting avoided cost-to-sales ratios are larger in year 5 than year 1. For example,
NAICS 562211 (Hazardous Waste Treatment and Disposal) has an overall year 1 avoided cost-
to-sales ratio of -0.01 percent and an overall year 5 avoided cost-to-sales ratio of 1.04 percent.
Some other NAICS codes that have negative ratios in year 1 have positive ratios in year 5, such
as NAICS 326191 (Plastics Plumbing Fixture Manufacturing), which has an overall avoided
cost-to-sales ratio of -0.01 percent in year 1 and 0.29 percent in year 5.
Like for the primary scenario and alternative scenario 1, we conducted a small entity
analysis for both year 1 and year 5 impact estimates for alternative scenario 2. In year 1, small
size categories have negative avoided cost-to-sales ratios. For instance, NAICS 488210 (Support
Activities for Rail Transportation) has an avoided cost-to-sales of less than -0.09 percent for the
"fewer than or equal to 19 employees" category and -0.01 percent for the "20 to 99 employees"
category in year 1. However, there are cases of larger positive economic impacts for small size
categories in year 5. NAICS 332812 (Metal Coating, Engraving (except Jewelry and Silverware),
and Allied Services to Manufacturers) has a year 5 "fewer than or equal to 19 employees"
category avoided cost-to-sales ratio of 5.75 percent, and NAICS 493110 (General Warehousing
and Storage) has a year 5 avoided cost-to-sales ratio of 2.75 percent for the same size category.
As explained before, establishments in the size category "fewer than or equal to 19 employees"
for NAICS 493110 are considered small businesses for purposes of this analysis based on the
SBA size standard for this NAICS code.
254
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
Cotton Ginning)
115114
$27.5 million
* **
*
**
* **
* **
* **
* **
*
**
Energy
Crude Petroleum and Natural Gas
Extraction
211111
1250 (Feb 2016 Size
Standards)
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
-$1,022
0.00%
0.00%
0.00%
0.00%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
*
**
**
**
* **
* **
*
**
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
Standards)
**
*
**
* **
* **
**
* **
*
**
Industrial
All Other Metal Ore Mining
212299
750
**
*
**
* **
**
* **
* **
*
**
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
*
**
Industrial
Kaolin and Ball Clay Mining
212324
750
**
*
**
**
**
* **
* **
*
**
Industrial
Potash, Soda, and Borate Mineral
Mining
212391
750
**
*
**
* **
* **
**
* **
*
**
Industrial
All Other Nonmetallic Mineral
Mining
212399
500
**
*
**
**
* **
* **
* **
*
**
Energy
Support Activities for Oil and Gas
213112
$38.5 million
-$1,022
-0.01%
-0.05%
-0.01%
0.00%
0.00%
0.00%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
-$1,022
-0.02%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power
Generation
221112
750
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Biomass Electric Power Generation
221117
250
-$1,022
-0.01%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
-$1,022
-0.04%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Utilities
Electric Power Distribution
221122
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
-$1,022
0.00%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation
Systems
221310
$27.5 million
-$1,022
-0.04%
*
*
*
*
*
*
Utilities
Sewage Treatment Facilities
221320
$20.5 million
-$1,022
-0.05%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
*
**
**
* **
* **
* **
*
**
Industrial
Wet Corn Milling
311221
1,250
**
*
**
**
**
* **
* **
*
**
Industrial
Soybean Processing"
311222
500 (2007 Size Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Other Oilseed Processing"
311223
1000 (2007 Size Standards)
**
*
**
* **
* **
* **
* **
*
**
Industrial
Soybean and Other Oilseed
Processing
311224
1,000
-$1,022
0.00%
*
o'.oo%
*
*
*
*
Industrial
Fats and Oils Refining and
Blending
311225
1,000
**
*
**
**
* **
* **
* **
*
**
Industrial
Beet Sugar Manufacturing
311313
750
**
*
**
* **
* **
**
* **
*
**
to
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Cane Sugar Manufacturing
311314
1,000
**
* **
* **
**
* **
* **
*
**
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
* **
* **
**
* **
* **
*
**
Manufacturing
'
'
'
'
Industrial
Fruit and Vegetable Canning
311421
1,000
**
* **
**
**
* **
* **
*
**
Industrial
Specialty Canning
311422
1,250
**
* **
* **
* **
**
* **
*
**
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
*
**
Industrial
Dry, Condensed, and Evaporated
311514
750
**
* **
**
**
* **
* **
*
**
Dairy Product Manufacturing
'
'
'
Industrial
Rendering and Meat Byproduct
311613
750
**
* **
**
**
* **
* **
*
**
Processing
'
'
'
Industrial
Commercial Bakeries
311812
1,000
**
* **
**
**
**
* **
*
**
Industrial
Other Snack Food Manufacturing
311919
1,250
**
* **
**
**
* **
* **
*
**
Industrial
Coffee and Tea Manufacturing
311920
750
**
* **
**
**
* **
* **
*
**
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
* **
* **
**
* **
* **
*
**
Manufacturing
'
'
'
'
Industrial
Spice and Extract Manufacturing
311942
500
**
* **
**
**
* **
* **
*
**
Industrial
All Other Miscellaneous Food
311999
500
**
* **
**
**
**
* **
*
**
Manufacturing
'
'
Industrial
Breweries
312120
1,250
-$1,022
0.00%
*
-0.01%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
* **
* **
* **
* **
* **
*
**
Industrial
Tobacco Manufacturing
312230
1,500
**
* **
* **
**
**
* **
*
**
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Broadwoven Fabric Finishing
MillsA
313311
1000 (2007 Size Standards)
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
Fabric Coating Mills
313320
1,000
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Leather and Hide Tanning and
316110
500
-$1,022
-0.01%
*
0.00%
0.00%
*
*
*
Finishing
Industrial
Sawmills
321113
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Wood Preservation
321114
500
-$1,022
-0.01%
*
0.00%
*
*
*
*
Industrial
Hardwood Veneer and Plywood
321211
500
-$1,022
-0.01%
*
*
0.00%
*
*
*
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Manufacturing
Industrial
Engineered Wood Member (except
321213
750
-$1,022
-0.01%
*
*
0.00%
*
*
*
Truss) Manufacturing
Industrial
Reconstituted Wood Product
321219
750
-$1,022
0.00%
*
*
0.00%
*
*
*
Manufacturing
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Wood Window and Door
Manufacturing
321911
1,000
-$1,022
-0.01%
*
*
0.00%
*
*
*
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
-$1,022
-0.02%
-0.07%
-0.01%
*
*
*
*
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
500
-$1,022
-0.03%
-0.11%
-0.01%
0.00%
*
*
*
Industrial
Pulp Mills
322110
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
-$1,022
0.00%
-0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Sanitary Paper Product
Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
-$1,022
-0.03%
*
*
*
*
*
*
Industrial
Commercial Printing (except
Screen and Books)
323111
500
-$1,022
-0.03%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Books Printing
323117
1,250
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
Petroleum Refineries
324110
1,500
-$1,030
0.00%
*
0.00%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal
Products Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
-$1,021
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
-$1,022
-0.01%
-0.01%
0.00%
*
*
*
*
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1,000
**
* **
**
**
* **
* **
* **
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Synthetic Organic Dye and Pigment
Manufacturing"
325132
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Alkalies and Chlorine
Manufacturing"
325181
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
-$1,078
0.00%
*
*
*
*
*
*
Industrial
All Other Basic Inorganic Chemical
Manufacturing"
325188
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Cyclic Crude and Intermediate
Manufacturing"
325192
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and
Gum and Wood Chemical
Manufacturing
325194
1,250
**
* **
**
**
* **
* **
*
**
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Plastics Material and Resin
Manufacturing
325211
1,250
-$1,021
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Synthetic Rubber Manufacturing
325212
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Cellulosic Organic Fiber
Manufacturing"
325221
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Noncellulosic Organic Fiber
Manufacturing"
325222
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Nitrogenous Fertilizer
Manufacturing
325311
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
Industrial
Phosphatic Fertilizer
Manufacturing
325312
750
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Medicinal and Botanical
Manufacturing
325411
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Biological Product (except
Diagnostic) Manufacturing
325414
1,250
**
* **
* **
**
**
**
*
**
Industrial
Paint and Coating Manufacturing
325510
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Adhesive Manufacturing
325520
500
-$1,022
0.00%
-0.02%
0.00%
0.00%
*
*
*
Industrial
Surface Active Agent
Manufacturing
325613
750
**
* **
**
* **
* **
* **
*
**
Industrial
Toilet Preparation Manufacturing
325620
1,250
**
**
**
**
**
**
*
**
Industrial
Explosives Manufacturing
325920
750
**
* **
* **
* **
* **
* **
*
**
Industrial
Custom Compounding of
Purchased Resins
325991
500
-$1,022
0.00%
*
o'.oo%
o'oo%
*
*
*
Industrial
Photographic Film, Paper, Plate,
and Chemical Manufacturing
325992
1,500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Miscellaneous Chemical
325998
Product and Preparation
500
-$1,022
-0.01%
-0.03%
0.00%
0.00%
0.00%
*
*
Manufacturing
Industrial
Plastics Packaging Film and Sheet
326112
(including Laminated)
1,000
-$1,022
0.00%
-0.03%
0.00%
0.00%
*
*
*
Manufacturing
Industrial
Unlaminated Plastics Film and
326113
Sheet (except Packaging)
750
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Manufacturing
Industrial
Unlaminated Plastics Profile Shape
326121
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Manufacturing
Industrial
Plastics Pipe and Pipe Fitting
326122
750
-$1,022
0.00%
-0.02%
0.00%
0.00%
*
*
*
Manufacturing
Industrial
Laminated Plastics Plate, Sheet
326130
(except Packaging), and Shape
500
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Manufacturing
Industrial
Polystyrene Foam Product
326140
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Manufacturing
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
-$1,010
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Plastics Plumbing Fixture
326191
750
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Manufacturing
Industrial
All Other Plastics Product
326199
750
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
0.00%
*
Manufacturing
Industrial
Tire Manufacturing (except
326211
1,500
-$1,013
0.00%
*
*
0.00%
0.00%
0.00%
*
Retreading)
Industrial
Rubber and Plastics Hoses and
326220
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Belting Manufacturing
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
All Other Rubber Product
326299
500
-$1,022
-0.01%
-0.05%
-0.01%
0.00%
*
*
*
Manufacturing
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
-$856
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Clay Building Material and
Refractories Manufacturing
327120
750
-$1,022
-0.01%
-0.06%
-0.01%
0.00%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
-$1,031
-0.01%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Other Pressed and Blown Glass and
327212
1,250
-$1,022
-0.01%
*
*
*
0.00%
*
*
Glassware Manufacturing
Industrial
Cement Manufacturing
327310
1,000
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
-$1,022
0.00%
*
*
*
*
*
*
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Sector
NAICS Descriptions
Average
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
327420
1,500
-$1,022
-0.01%
*
0.00%
*
*
*
*
327910
750
-$1,022
-0.01%
-0.04%
-0.01%
0.00%
0.00%
*
*
327993
1,500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
327999
500
-$1,022
-0.01%
*
-0.01%
*
*
*
*
331110
1,500
-$1,022
0.00%
*
*
0.00%
0.00%
0.00%
*
331111
1000 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331210
1,000
-$1,022
0.00%
-0.02%
0.00%
0.00%
0.00%
0.00%
*
331221
1,000
-$1,022
0.00%
*
0.00%
*
*
*
*
331312
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331313
1,000
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
331314
750
-$1,022
0.00%
*
0.00%
*
*
*
*
331315
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331318
750
**
* **
* **
**
* **
* **
* **
331410
1,000
**
* **
**
* **
**
* **
* **
331411
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331420
1,000
**
* **
**
**
**
* **
* **
331422
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
331491
750
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
to
On
O
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Gypsum Product Manufacturing
Abrasive Product Manufacturing
Mineral Wool Manufacturing
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
Iron and Steel Mills and Ferroalloy
Manufacturing
Iron and Steel MillsA
Electrometallurgical Ferroalloy
Product ManufacturingA
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
Rolled Steel Shape Manufacturing
Primary Aluminum ProductionA
Alumina Refining and Primary
Aluminum Production
Secondary Smelting and Alloying
of Aluminum
Aluminum Sheet, Plate, and Foil
Manufacturing
Aluminum Extruded Product
ManufacturingA
Other Aluminum Rolling, Drawing,
and Extruding
Nonferrous Metal (except
Aluminum) Smelting and Refining
Primary Smelting and Refining of
CopperA
Primary Smelting and Refining of
Nonferrous Metal (except Copper
and Aluminum)A
Copper Rolling, Drawing,
Extruding, and Alloying
Copper Wire (except Mechanical)
DrawingA
Nonferrous Metal (except Copper
and Aluminum) Rolling, Drawing,
and Extruding
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal
(except Copper and Aluminum)
331492
750
**
* **
**
**
* **
* **
* **
Industrial
Iron Foundries
331511
1,000
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
* **
* **
Industrial
Aluminum Die-Casting Foundries'^
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
* **
* **
Industrial
Nonferrous Forging
332112
750
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Hand and Edge Tool
ManufacturingA
332212
500 (2007 Size Standards)
-$1,022
-0.02%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
-$1,022
-0.02%
-0.07%
-0.01%
0.00%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Other Metal Container
Manufacturing
332439
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and
Washer Manufacturing
332722
500
-$1,022
-0.01%
-0.07%
-0.01%
0.00%
0.00%
*
*
Industrial
Metal Heat Treating
332811
750
-$1,022
-0.01%
*
-0.01%
*
*
*
*
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
-$1,022
-0.02%
-0.12%
-0.01%
0.00%
*
*
*
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
-$1,022
-0.03%
-0.12%
-0.02%
*
*
*
*
Industrial
Other Fabricated Metal
Manufacturing
332990
#N/A
-$1,022
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
-$1,022
0.00%
*
*
*
*
*
*
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
-$1,022
-0.02%
-0.11%
-0.01%
0.00%
0.00%
*
*
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden
Equipment Manufacturing
333112
1,500
**
* **
* **
**
**
* **
* **
Industrial
Construction Machinery
Manufacturing
333120
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
* **
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
* **
Industrial
Air-Conditioning and Warm Air
Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333415
1,250
**
**
**
**
**
**
* **
Industrial
Machine Tool (Metal Cutting
Types) ManufacturingA
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Machine Tool (Metal Forming
Types) ManufacturingA
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
* **
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1,250
**
* **
**
**
* **
* **
* **
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
* **
Industrial
Radio and Television Broadcasting
and Wireless Communications
Equipment Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube Manufacturing"
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
-$1,021
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
Industrial
Blank Magnetic and Optical
Recording Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
-$1,022
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
-$1,022
0.00%
*
*
*
0.00%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor and Generator
Manufacturing
335312
1,250
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
-$1,022
0.00%
*
*
0.00%
0.00%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Noncurrent-Carrying Wiring
Device Manufacturing
335932
1,000
-$1,022
0.00%
*
0.00%
0.00%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
-$1,022
0.00%
*
-0.01%
0.00%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
-$1,022
0.00%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
-$1,022
0.00%
*
*
0.00%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
-$1,022
0.00%
*
*
*
0.00%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Truck Trailer Manufacturing
336212
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
0.00%
*
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Motor Vehicle Metal Stamping
336370
1,000
-$1,022
0.00%
-0.05%
-0.01%
0.00%
0.00%
0.00%
*
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
-$1,022
0.00%
-0.04%
0.00%
0.00%
0.00%
0.00%
*
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
-$1,022
0.00%
*
*
*
*
*
*
Industrial
Aircraft Manufacturing
336411
1,500
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
-$1,022
0.00%
-0.05%
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion
Unit Parts Manufacturing
336415
1,250
-$1,022
0.00%
*
*
*
*
0.00%
*
Industrial
Railroad Rolling Stock
Manufacturing
336510
1,500
-$1,022
0.00%
*
0.00%
0.00%
0.00%
*
*
Industrial
Ship Building and Repairing
336611
1,250
-$1,022
0.00%
-0.07%
-0.01%
0.00%
0.00%
0.00%
0.00%
Industrial
Boat Building
336612
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Military Armored Vehicle, Tank,
and Tank Component
Manufacturing
336992
1,500
-$1,022
0.00%
*
*
0.00%
*
*
*
Industrial
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
750
-$1,022
-0.06%
*
*
0.00%
0.00%
*
*
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
-$1,022
-0.01%
*
*
0.00%
0.00%
*
*
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
-$1,022
-0.06%
*
-0.02%
0.00%
*
*
*
Industrial
Institutional Furniture
Manufacturing
337127
500
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Wood Office Furniture
Manufacturing
337211
1,000
-$1,022
-0.01%
*
-0.01%
0.00%
*
*
*
Industrial
Office Furniture (except Wood)
Manufacturing
337214
1,000
-$1,022
0.00%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Showcase, Partition, Shelving, and
Locker Manufacturing
337215
500
-$1,022
-0.02%
*
-0.01%
0.00%
0.00%
*
*
Industrial
Blind and Shade Manufacturing
337920
1,000
-$1,022
-0.02%
*
-0.01%
0.00%
*
*
*
Industrial
Surgical and Medical Instrument
Manufacturing
339112
1,000
**
* **
* **
**
**
**
* **
Industrial
Surgical Appliance and Supplies
Manufacturing
339113
750
**
* **
* **
**
**
**
* **
Industrial
Jewelry and Silverware
Manufacturing
339910
500
**
**
**
* **
* **
* **
* **
Industrial
Sporting and Athletic Goods
Manufacturing
339920
750
**
**
**
**
**
**
* **
Industrial
Office Supplies (except Paper)
Manufacturing
339940
750
**
* **
**
**
* **
* **
* **
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Sector
SBA Size
NAICS Descriptions
NAICS
Average
Avoided
Cost/Entity
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Gasket, Packing, and Sealing
339991
500
**
* **
**
**
**
*
**
*
**
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
-$1,022
-0.01%
*
*
*
*
*
*
Industrial
All Other Miscellaneous
339999
500
-$1,022
-0.05%
-0.19%
-0.01%
0.00%
*
*
*
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
*
**
*
**
*
**
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
200
-$1,022
0.00%
0.00%
0.00%
*
*
*
*
Terminals
Commercial
Scheduled Passenger Air
481111
1,500
**
**
**
* **
*
**
*
**
*
**
Transportation
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
*
**
*
**
*
**
Energy
Pipeline Transportation of Crude
Oil
486110
1,500
**
**
**
* **
*
**
*
**
*
**
Energy
Pipeline Transportation of Natural
486210
$27.5 million
-$1,022
-0.01%
-0.02%
0.00%
*
*
*
*
Energy
OclS
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
*
**
*
**
*
**
Petroleum Products
Commercial
Support Activities for Rail
488210
$15 million
-$1,022
-0.03%
-0.09%
-0.01%
*
*
*
*
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
*
**
*
**
*
**
Commercial
General Warehousing and Storage
493110
$27.5 million
-$1,022
-0.06%
-0.11%
-0.03%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
-$1,022
-0.04%
-0.14%
-0.03%
*
*
*
*
Commercial
Lessors of Nonresidential Buildings
531120
$27.5 million
**
**
**
* **
*
**
*
**
*
**
(except Mini warehouses)
Commercial
Testing Laboratories
541380
$15 million
**
**
**
* **
*
**
*
**
*
**
Commercial
Research and Development in the
541715
1,000
* **
* **
* **
* **
*
**
*
**
*
**
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
Commercial
All Other Support Services
561990
$11 million
**
**
**
* **
*
**
*
**
*
**
Waste Treatment
Hazardous Waste Treatment and
562211
$38.5 million
-$1,022
-0.01%
-0.06%
-0.01%
*
*
*
*
Disposal
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
-$1,022
-0.02%
-0.05%
-0.01%
*
*
*
*
Waste Treatment
Solid Waste Combustors and
562213
$38.5 million
-$1,022
0.00%
*
0.00%
*
*
*
*
Incinerators
Waste Treatment
Remediation Services
562910
$20.5 million
-$1,022
-0.03%
-0.09%
-0.01%
*
*
*
*
Educational Services
Colleges, Universities, and
611310
$27.5 million
-$1,022
*
*
*
*
*
*
*
Professional Schools
Commercial
Amusement and Theme Parks
713110
$38.5 million
**
**
**
* **
*
**
*
**
*
**
to
On
(continued)
-------
Table 6-8. Avoided Cost to Sales in Year 1 under ALTERNATIVE SCENARIO 2 (continued)
Average
Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All <19
20-99
499
999
2499
>2500
Commercial
Linen and Uniform Supply
812330
#N/A
* ** * **
* **
* **
* **
* **
* **
Commercial
Industrial Launderers
812332
$38.5 million
-$1,022
-0.02% -0.07%
-0.02%
*
*
*
*
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are eligible to obtain area source status. NA means it is not a valid 2012 NAICS code, thus an SBA Size Standard
is not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
For assessed Source Category "Pulp & Paper (non-combust) MACT" (NAICS 322121), assessed using an extrapolated approach, one facility is extrapolated to obtain area source status. However, in the
estimation of Extrapolated Costs (Savings) "No facilities are expected to be area sources" and therefore these costs (savings) are estimated as zero. We make the same assumption for this category in our
calculation of Extrapolated Costs (Savings) in Year 1 without state permitting costs.
"Zero facilities Estimated to obtain area source status and no Estimated net costs (savings); cost-to-sales ratios cannot be calculated.
*,"Denotes a data status as a combination of footnotes * and **
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD. August 2020.7-18, SBA February 2016 Size
Standards, SBA 2007 Size Standards.
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017$)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Agriculture
Postharvest Crop Activities (except
115114
$27.5 million
* **
* **
* **
* **
* **
* **
*
**
Cotton Ginning)
Energy
Crude Petroleum and Natural Gas
211111
1250 (Feb 2016 Size
9,397
0.02%
*
0.01%
0.00%
0.00%
0.00%
*
Extraction
Standards)
Energy
Natural Gas Liquid Extraction
211112
750 (Feb 2016 Size
35,537
0.03%
0.06%
0.02%
0.01%
0.00%
*
*
Standards)
Industrial
Iron Ore Mining
212210
750
**
* **
**
**
* **
* **
*
**
Industrial
Lead Ore and Zinc Ore Mining
212231
750 (Feb 2016 Size
**
* **
* **
* **
* **
* **
*
**
Standards)
Industrial
Copper Ore and Nickel Ore Mining
212234
1500 (Feb 2016 Size
**
* **
* **
* **
**
* **
*
**
Standards)
Industrial
All Other Metal Ore Mining
212299
750
**
* **
* **
**
* **
* **
*
**
Industrial
Industrial Sand Mining
212322
500
**
**
**
**
* **
* **
*
**
Industrial
Kaolin and Ball Clay Mining
212324
750
**
* **
**
**
* **
* **
*
**
Industrial
Potash, Soda, and Borate Mineral
212391
750
**
* **
* **
* **
**
* **
*
**
Mining
Industrial
All Other Nonmetallic Mineral
212399
500
**
* **
**
* **
* **
* **
*
**
Mining
Energy
Support Activities for Oil and Gas
213112
$38.5 million
15,247
0.16%
0.69%
0.16%
0.03%
0.01%
0.00%
*
Operations
Utilities
Hydroelectric Power Generation
221111
500
15,247
0.23%
*
*
*
*
*
*
Utilities
Fossil Fuel Electric Power
221112
750
40,186
0.06%
*
*
*
*
*
*
Generation
Utilities
Biomass Electric Power Generation
221117
250
63,290
0.87%
*
*
*
*
*
*
Utilities
Other Electric Power Generation
221118
250
15,247
0.59%
*
*
*
*
*
*
Utilities
Other Electric Power GenerationA
221119
4 million MWH (2007 Size
50,126
0.46%
*
*
*
*
*
*
Standards)
Utilities
Electric Power Distribution
221122
1,000
15,247
0.03%
*
*
*
*
*
*
Utilities
Natural Gas Distribution
221210
1,000
40,400
0.10%
*
*
*
*
*
*
Utilities
Water Supply and Irrigation
221310
$27.5 million
23,798
0.94%
*
*
*
*
*
*
Systems
Utilities
Sewage Treatment Facilities
221320
$20.5 million
22,367
1.07%
*
*
*
*
*
*
Utilities
Steam and Air-Conditioning Supply
221330
$15 million
32,701
0.20%
*
*
*
*
*
*
Industrial
Other Animal Food Manufacturing
311119
500
**
* **
**
* **
* **
* **
*
**
Industrial
Wet Corn Milling
311221
1,250
**
* **
**
**
* **
* **
*
**
Industrial
Soybean ProcessingA
311222
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Oilseed ProcessingA
311223
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Soybean and Other Oilseed
311224
1,000
35,287
0.01%
*
o'oi%
*
*
*
*
Processing
Industrial
Fats and Oils Refining and Blending
311225
1,000
**
* **
**
* **
* **
* **
*
**
Industrial
Beet Sugar Manufacturing
311313
750
**
* **
* **
* **
**
* **
*
**
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Avoided
Cost/Entity
(2017S)
All
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Cane Sugar Manufacturing
311314
1,000
**
* **
* **
**
* **
* **
* **
Industrial
Frozen Fruit, Juice, and Vegetable
311411
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1,000
**
* **
**
**
* **
* **
* **
Industrial
Specialty Canning
311422
1,250
**
* **
* **
* **
**
* **
* **
Industrial
Cheese Manufacturing
311513
1,250
**
**
**
**
**
**
* **
Industrial
Dry, Condensed, and Evaporated
311514
750
**
* **
**
**
* **
* **
* **
Dairy Product Manufacturing
Industrial
Rendering and Meat Byproduct
311613
750
**
* **
**
**
* **
* **
* **
Processing
Industrial
Commercial Bakeries
311812
1,000
**
* **
**
**
**
* **
* **
Industrial
Other Snack Food Manufacturing
311919
1,250
**
* **
**
**
* **
* **
* **
Industrial
Coffee and Tea Manufacturing
311920
750
**
* **
**
**
* **
* **
* **
Industrial
Flavoring Syrup and Concentrate
311930
1,000
**
* **
* **
**
* **
* **
* **
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
500
**
* **
**
**
* **
* **
* **
Industrial
All Other Miscellaneous Food
311999
500
**
* **
**
**
**
* **
* **
Manufacturing
Industrial
Breweries
312120
1,250
15,247
0.04%
*
0.10%
*
*
*
*
Industrial
Distilleries
312140
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Tobacco Manufacturing
312230
1,500
**
* **
* **
**
**
* **
* **
Industrial
Yarn Spinning MillsA
313111
500 (2007 Size Standards)
15,247
0.06%
*
*
*
*
*
*
Industrial
Thread MillsA
313113
500 (2007 Size Standards)
15,247
0.23%
*
*
*
*
*
*
Industrial
Broadwoven Fabric Mills
313210
1,000
23,798
0.17%
*
0.19%
0.04%
0.02%
*
*
Industrial
Narrow Fabric MillsA
313221
500 (2007 Size Standards)
15,247
0.22%
*
*
*
*
*
*
Industrial
Textile and Fabric Finishing Mills
313310
1,000
15,247
0.24%
*
0.12%
0.03%
*
*
*
Industrial
Broadwoven Fabric Finishing
313311
1000 (2007 Size Standards)
23,798
0.33%
*
*
*
*
*
*
MillsA
Industrial
Fabric Coating Mills
313320
1,000
19,266
0.14%
*
0.10%
*
*
*
*
Industrial
Tire Cord and Tire Fabric MillsA
314992
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Leather and Hide Tanning and
316110
500
10,983
0.13%
*
0.04%
0.02%
*
*
*
Finishing
Industrial
Sawmills
321113
500
41,778
0.60%
2.97%
0.31%
0.08%
*
*
*
Industrial
Wood Preservation
321114
500
15,247
0.14%
*
0.06%
*
*
*
*
Industrial
Hardwood Veneer and Plywood
321211
500
15,247
0.13%
*
*
0.03%
*
*
*
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
1,250
37,382
0.08%
*
*
0.04%
0.02%
*
*
Manufacturing
Industrial
Engineered Wood Member (except
321213
750
23,798
0.26%
*
*
0.03%
*
*
*
Truss) Manufacturing
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Reconstituted Wood Product
Manufacturing
321219
750
21,614
0.07%
*
*
0.02%
*
*
*
Industrial
Wood Window and Door
Manufacturing
321911
1,000
15,247
0.18%
*
*
0.03%
*
*
*
Industrial
Cut Stock, Resawing Lumber, and
Planing
321912
500
15,247
0.23%
0.98%
0.13%
*
*
*
*
Industrial
All Other Miscellaneous Wood
Product Manufacturing
321999
500
15,247
0.49%
1.67%
0.16%
0.03%
*
*
*
Industrial
Pulp Mills
322110
750
20,948
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Paper (except Newsprint) Mills
322121
1,250
12,624
0.00%
*
*
0.01%
0.00%
0.00%
*
Industrial
Newsprint Mills
322122
750
15,247
0.01%
*
*
*
*
*
*
Industrial
Paperboard Mills
322130
1,250
40,400
0.02%
*
*
0.02%
0.01%
*
*
Industrial
Corrugated and Solid Fiber Box
Manufacturing
322211
1,250
958
0.00%
0.03%
0.00%
0.00%
*
*
*
Industrial
Paper Bag and Coated and Treated
Paper Manufacturing
322220
750
20,948
0.07%
*
0.10%
0.03%
0.00%
*
*
Industrial
Coated and Laminated Paper
ManufacturingA
322222
500 (2007 Size Standards)
23,798
0.08%
*
*
*
*
*
*
Industrial
Sanitary Paper Product
Manufacturing
322291
1,500
**
* **
* **
**
**
* **
* **
Industrial
All Other Converted Paper Product
Manufacturing
322299
500
**
* **
**
* **
* **
* **
* **
Industrial
Commercial Lithographic PrintingA
323110
500 (2007 Size Standards)
15,247
0.37%
*
*
*
*
*
*
Industrial
Commercial Printing (except Screen
and Books)
323111
500
19,795
0.57%
*
0.23%
0.04%
0.01%
*
*
Industrial
Books Printing
323117
1,250
23,798
0.25%
*
*
0.05%
0.02%
*
*
Industrial
Petroleum Refineries
324110
1,500
96,633
0.00%
*
0.04%
0.00%
*
0.00%
*
Industrial
Asphalt Shingle and Coating
Materials Manufacturing
324122
750
**
* **
**
* **
* **
* **
* **
Industrial
All Other Petroleum and Coal
Products Manufacturing
324199
500
**
* **
**
* **
* **
* **
* **
Industrial
Petrochemical Manufacturing
325110
1,000
20,158
0.00%
*
*
0.00%
*
*
*
Industrial
Industrial Gas Manufacturing
325120
1,000
15,247
0.09%
0.22%
0.06%
*
*
*
*
Industrial
Synthetic Dye and Pigment
Manufacturing
325130
1,000
**
* **
**
**
* **
* **
* **
Industrial
Inorganic Dye and Pigment
ManufacturingA
325131
1000 (2007 Size Standards)
15,247
0.02%
*
*
*
*
*
*
Industrial
Synthetic Organic Dye and Pigment
ManufacturingA
325132
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Other Basic Inorganic Chemical
Manufacturing
325180
1,000
20,948
0.04%
*
0.04%
0.01%
0.00%
*
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Alkalies and Chlorine
ManufacturingA
325181
1000 (2007 Size Standards)
28,723
0.02%
*
*
*
*
*
*
Industrial
Carbon Black ManufacturingA
325182
500 (2007 Size Standards)
32,902
0.04%
*
*
*
*
*
*
Industrial
All Other Basic Inorganic Chemical
ManufacturingA
325188
1000 (2007 Size Standards)
32,123
0.07%
*
*
*
*
*
*
Industrial
Cyclic Crude and Intermediate
ManufacturingA
325192
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Ethyl Alcohol Manufacturing
325193
1,000
20,948
0.01%
*
0.01%
0.00%
*
*
*
Industrial
Cyclic Crude, Intermediate, and
Gum and Wood Chemical
Manufacturing
325194
1,250
**
* **
**
**
* **
* **
* **
Industrial
All Other Basic Organic Chemical
Manufacturing
325199
1,250
53,241
0.05%
*
0.08%
0.02%
0.00%
0.00%
*
Industrial
Plastics Material and Resin
Manufacturing
325211
1,250
35,086
0.04%
*
0.08%
0.01%
0.00%
0.00%
*
Industrial
Synthetic Rubber Manufacturing
325212
1,000
6,981
0.01%
*
0.01%
*
*
*
*
Industrial
Artificial and Synthetic Fibers and
Filaments Manufacturing
325220
1,000
23,798
0.03%
*
0.10%
0.02%
0.00%
*
*
Industrial
Cellulosic Organic Fiber
ManufacturingA
325221
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Noncellulosic Organic Fiber
ManufacturingA
325222
1000 (2007 Size Standards)
27,543
0.04%
*
*
*
*
*
*
Industrial
Nitrogenous Fertilizer
Manufacturing
325311
1,000
50,126
0.09%
*
0.09%
*
*
*
*
Industrial
Phosphatic Fertilizer Manufacturing
325312
750
20,948
0.01%
*
*
*
*
*
*
Industrial
Pesticide and Other Agricultural
Chemical Manufacturing
325320
1,000
61,830
0.08%
*
0.10%
0.02%
*
*
*
Industrial
Medicinal and Botanical
Manufacturing
325411
1,000
15,247
0.05%
*
0.08%
0.02%
0.00%
*
*
Industrial
Pharmaceutical Preparation
Manufacturing
325412
1,250
6,127
0.00%
*
*
0.00%
0.00%
0.00%
*
Industrial
Biological Product (except
Diagnostic) Manufacturing
325414
1,250
**
* **
* **
**
**
**
* **
Industrial
Paint and Coating Manufacturing
325510
1,000
132,467
0.59%
*
0.42%
0.09%
*
*
*
Industrial
Adhesive Manufacturing
325520
500
15,247
0.06%
0.35%
0.05%
0.01%
*
*
*
Industrial
Surface Active Agent
Manufacturing
325613
750
**
* **
**
* **
* **
* **
* **
Industrial
Toilet Preparation Manufacturing
325620
1,250
**
**
**
**
**
**
* **
Industrial
Explosives Manufacturing
325920
750
**
* **
* **
* **
* **
* **
* **
Industrial
Custom Compounding of Purchased
Resins
325991
500
23,798
0.10%
*
0.08%
0.02%
*
*
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Photographic Film, Paper, Plate, and 325992
1,500
15,247
0.05%
*
0.07%
0.01%
*
*
*
Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical
Product and Preparation
Manufacturing
325998
500
20,948
0.11%
0.64%
0.07%
0.02%
0.01%
*
*
Industrial
Plastics Packaging Film and Sheet
(including Laminated)
Manufacturing
326112
1,000
63,290
0.18%
1.94%
0.29%
0.08%
*
*
*
Industrial
Unlaminated Plastics Film and
Sheet (except Packaging)
Manufacturing
326113
750
43,544
0.14%
*
0.19%
0.04%
0.01%
*
*
Industrial
Unlaminated Plastics Profile Shape
Manufacturing
326121
500
15,247
0.09%
*
0.12%
0.03%
*
*
*
Industrial
Plastics Pipe and Pipe Fitting
Manufacturing
326122
750
15,247
0.07%
0.34%
0.06%
0.02%
*
*
*
Industrial
Laminated Plastics Plate, Sheet
(except Packaging), and Shape
Manufacturing
326130
500
63,290
0.40%
*
0.38%
*
*
*
*
Industrial
Polystyrene Foam Product
Manufacturing
326140
1,000
15,247
0.07%
*
0.09%
0.02%
0.00%
*
*
Industrial
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
326150
750
14,449
0.09%
*
0.08%
0.03%
*
*
*
Industrial
Plastics Plumbing Fixture
Manufacturing
326191
750
23,798
0.29%
*
0.24%
*
*
*
*
Industrial
All Other Plastics Product
Manufacturing
326199
750
42,831
0.32%
2.75%
0.36%
0.08%
0.02%
0.01%
*
Industrial
Tire Manufacturing (except
Retreading)
326211
1,500
36,334
0.02%
*
*
0.02%
0.01%
0.00%
*
Industrial
Rubber and Plastics Hoses and
Belting Manufacturing
326220
750
63,290
0.29%
*
*
0.09%
0.04%
*
*
Industrial
Rubber Product Manufacturing for
Mechanical Use
326291
750
23,798
0.13%
*
*
0.04%
0.01%
*
*
Industrial
All Other Rubber Product
Manufacturing
326299
500
50,126
0.30%
2.43%
0.33%
0.07%
*
*
*
Industrial
Pottery, Ceramics, and Plumbing
Fixture Manufacturing
327110
1,000
12,838
0.37%
*
0.18%
0.03%
*
*
*
Industrial
Clay Building Material and
Refractories Manufacturing
327120
750
15,300
0.16%
0.91%
0.14%
0.03%
*
*
*
Industrial
Clay Refractory ManufacturingA
327124
500 (2007 Size Standards)
15,511
0.16%
*
*
*
*
*
*
Industrial
Flat Glass Manufacturing
327211
1,000
23,798
0.04%
*
*
*
*
*
*
Industrial
Other Pressed and Blown Glass and
Glassware Manufacturing
327212
1,250
32,730
0.36%
*
*
*
0.02%
*
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$) All
Avoided Cost to Sales/Entity by Employee Size Categories (%)
<19
20-99
100-
499
500-
999
1000-
2499
>2500
Industrial
Cement Manufacturing
327310
1,000
63,290
0.24%
*
*
*
*
*
*
Industrial
Lime Manufacturing
327410
750
23,798
0.09%
*
*
*
*
*
*
Industrial
Gypsum Product Manufacturing
327420
1,500
15,247
0.08%
*
0.05%
*
*
*
*
Industrial
Abrasive Product Manufacturing
327910
750
23,798
0.12%
1.02%
0.15%
0.02%
0.00%
*
*
Industrial
Mineral Wool Manufacturing
327993
1,500
53,882
0.28%
*
0.38%
0.06%
*
*
*
Industrial
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
327999
500
23,798
0.24%
*
0.15%
*
*
*
*
Industrial
Iron and Steel Mills and Ferroalloy
Manufacturing
331110
1,500
35,065
0.01%
*
*
0.01%
0.00%
0.00%
*
Industrial
Iron and Steel MillsA
331111
1000 (2007 Size Standards)
20,948
0.01%
*
*
*
*
*
*
Industrial
Electrometallurgical Ferroalloy
Product ManufacturingA
331112
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Iron and Steel Pipe and Tube
Manufacturing from Purchased
Steel
331210
1,000
23,798
0.03%
0.46%
0.08%
0.02%
0.01%
0.00%
*
Industrial
Rolled Steel Shape Manufacturing
331221
1,000
23,798
0.07%
*
0.06%
*
*
*
*
Industrial
Primary Aluminum Production"
331312
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Alumina Refining and Primary
Aluminum Production
331313
1,000
261,229
0.17%
*
0.56%
0.11%
0.05%
*
*
Industrial
Secondary Smelting and Alloying of
Aluminum
331314
750
4,519
0.01%
*
0.01%
*
*
*
*
Industrial
Aluminum Sheet, Plate, and Foil
Manufacturing
331315
1,250
23,798
0.01%
*
*
0.01%
0.00%
*
*
Industrial
Aluminum Extruded Product
Manufacturing"
331316
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Other Aluminum Rolling, Drawing,
and Extruding
331318
750
**
* **
* **
**
* **
* **
*
**
Industrial
Nonferrous Metal (except
Aluminum) Smelting and Refining
331410
1,000
**
* **
**
* **
**
* **
*
**
Industrial
Primary Smelting and Refining of
Copper"
331411
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Primary Smelting and Refining of
Nonferrous Metal (except Copper
and Aluminum)"
331419
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
Industrial
Copper Rolling, Drawing,
Extruding, and Alloying
331420
1,000
**
* **
**
**
**
* **
*
**
Industrial
Copper Wire (except Mechanical)
Drawing"
331422
1000 (2007 Size Standards)
**
* **
* **
* **
* **
* **
*
**
to
^1
to
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Nonferrous Metal (except Copper
and Aluminum) Rolling, Drawing,
and Extruding
331491
750
15,247
0.06%
*
0.07%
0.02%
*
*
*
Industrial
Secondary Smelting, Refining, and
Alloying of Nonferrous Metal
(except Copper and Aluminum)
331492
750
**
* **
**
**
* **
* **
* **
Industrial
Iron Foundries
331511
1,000
63,290
0.22%
*
*
0.10%
0.02%
*
*
Industrial
Steel Foundries (except Investment)
331513
500
**
* **
**
**
**
* **
* **
Industrial
Aluminum Die-Casting FoundriesA
331521
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Aluminum Foundries (except Die-
Casting)
331524
500
**
* **
**
**
* **
* **
* **
Industrial
Nonferrous Forging
332112
750
15,247
0.03%
*
*
0.02%
0.00%
*
*
Industrial
Metal Crown, Closure, and Other
Metal Stamping (except
Automotive)
332119
500
15,247
0.18%
1.08%
0.15%
0.03%
0.01%
*
*
Industrial
Hand and Edge Tool
ManufacturingA
332212
500 (2007 Size Standards)
15,247
0.25%
*
*
*
*
*
*
Industrial
Prefabricated Metal Building and
Component Manufacturing
332311
750
15,247
0.15%
*
0.10%
0.03%
*
*
*
Industrial
Fabricated Structural Metal
Manufacturing
332312
500
15,247
0.16%
*
0.11%
0.02%
*
*
*
Industrial
Metal Window and Door
Manufacturing
332321
750
57,102
0.58%
*
0.55%
0.12%
0.04%
*
*
Industrial
Sheet Metal Work Manufacturing
332322
500
15,247
0.29%
1.11%
0.17%
0.04%
*
*
*
Industrial
Metal Can Manufacturing
332431
1,500
43,429
0.05%
*
0.07%
0.03%
*
*
*
Industrial
Other Metal Container
Manufacturing
332439
500
20,948
0.19%
1.48%
0.13%
0.04%
0.01%
*
*
Industrial
Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332722
500
15,247
0.12%
1.00%
0.12%
0.03%
0.01%
*
*
Industrial
Metal Heat Treating
332811
750
15,247
0.17%
*
0.17%
*
*
*
*
Industrial
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
332812
500
48,487
0.87%
5.75%
0.46%
0.06%
*
*
*
Industrial
Electroplating, Plating, Polishing,
Anodizing, and Coloring
332813
500
20,948
0.65%
2.55%
0.34%
*
*
*
*
Industrial
Other Fabricated Metal
Manufacturing
332990
#N/A
15,247
*
*
*
*
*
*
*
Industrial
Small Arms Ammunition
Manufacturing
332992
1,250
15,247
0.04%
*
*
*
*
*
*
Industrial
Ammunition (except Small Arms)
Manufacturing
332993
1,500
20,948
0.03%
*
*
*
*
*
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
All Other Miscellaneous Fabricated
Metal Product Manufacturing
332999
750
20,948
0.50%
2.33%
0.25%
0.05%
0.01%
*
*
Industrial
Farm Machinery and Equipment
Manufacturing
333111
1,250
20,948
0.06%
*
0.16%
0.02%
0.00%
0.00%
*
Industrial
Lawn and Garden Tractor and
Home Lawn and Garden Equipment
Manufacturing
333112
1,500
**
* **
* **
**
**
* **
* **
Industrial
Construction Machinery
Manufacturing
333120
1,250
12,446
0.02%
*
0.08%
0.01%
0.00%
0.00%
*
Industrial
Mining Machinery and Equipment
Manufacturing
333131
500
**
* **
**
**
* **
* **
* **
Industrial
Printing Machinery and Equipment
ManufacturingA
333293
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Photographic and Photocopying
Equipment Manufacturing
333316
1,000
**
* **
**
* **
* **
* **
* **
Industrial
Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration
Equipment Manufacturing
333415
1,250
**
**
**
**
**
**
* **
Industrial
Machine Tool (Metal Cutting
Types) ManufacturingA
333512
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Machine Tool (Metal Forming
Types) Manufacturing"
333513
500 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Turbine and Turbine Generator Set
Units Manufacturing
333611
1,500
**
* **
* **
**
**
**
* **
Industrial
Other Engine Equipment
Manufacturing
333618
1,500
23,798
0.03%
0.94%
0.11%
0.02%
0.00%
0.00%
*
Industrial
Overhead Traveling Crane, Hoist,
and Monorail System
Manufacturing
333923
1,250
**
* **
**
**
* **
* **
* **
Industrial
Welding and Soldering Equipment
Manufacturing
333992
1,250
**
**
**
**
* **
**
* **
Industrial
Radio and Television Broadcasting
and Wireless Communications
Equipment Manufacturing
334220
1,250
**
**
**
**
**
**
**
Industrial
Electron Tube Manufacturing"
334411
750 (2007 Size Standards)
**
* **
* **
* **
* **
* **
* **
Industrial
Bare Printed Circuit Board
Manufacturing
334412
750
**
* **
**
**
* **
* **
* **
Industrial
Semiconductor and Related Device
Manufacturing
334413
1,250
40,679
0.07%
*
0.13%
0.05%
0.01%
0.00%
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Automatic Environmental Control
Manufacturing for Residential,
Commercial, and Appliance Use
334512
500
**
* **
**
* **
**
* **
* **
Industrial
Blank Magnetic and Optical
Recording Media Manufacturing
334613
1,000
**
* **
* **
* **
* **
* **
* **
Industrial
Electric Lamp Bulb and Part
Manufacturing
335110
1,250
15,247
0.05%
*
*
0.03%
*
*
*
Industrial
Household Laundry Equipment
Manufacturing
335224
1,250
36,901
*
*
*
*
*
*
*
Industrial
Other Major Household Appliance
Manufacturing
335228
1,000
23,798
0.01%
*
*
*
0.01%
*
*
Industrial
Power, Distribution, and Specialty
Transformer Manufacturing
335311
750
15,247
0.06%
*
0.11%
0.02%
0.01%
*
*
Industrial
Motor and Generator Manufacturing
335312
1,250
23,798
0.09%
*
0.20%
0.03%
*
*
*
Industrial
Storage Battery Manufacturing
335911
1,250
15,247
0.03%
*
*
0.02%
0.01%
*
*
Industrial
Current-Carrying Wiring Device
Manufacturing
335931
500
15,247
0.09%
*
0.13%
0.03%
0.01%
*
*
Industrial
Noncurrent-Carrying Wiring Device
Manufacturing
335932
1,000
15,247
0.04%
*
0.07%
0.02%
*
*
*
Industrial
Carbon and Graphite Product
Manufacturing
335991
750
63,290
0.26%
*
0.38%
0.08%
*
*
*
Industrial
Automobile Manufacturing
336111
1,500
43,644
0.01%
*
*
*
*
0.00%
0.00%
Industrial
Light Truck and Utility Vehicle
Manufacturing
336112
1,500
63,290
0.00%
*
*
0.11%
*
*
0.00%
Industrial
Heavy Duty Truck Manufacturing
336120
1,500
57,102
0.02%
*
*
*
0.01%
0.00%
*
Industrial
Motor Vehicle Body Manufacturing
336211
1,000
57,102
0.35%
*
0.50%
0.10%
0.02%
*
*
Industrial
Truck Trailer Manufacturing
336212
1,000
15,247
0.07%
*
0.14%
0.02%
0.01%
*
*
Industrial
Motor Vehicle Gasoline Engine and
Engine Parts Manufacturing
336310
1,000
23,798
0.06%
*
0.17%
0.02%
0.00%
*
*
Industrial
Carburetor, Piston, Piston Ring, and
Valve ManufacturingA
336311
500 (2007 Size Standards)
15,247
0.06%
*
*
*
*
*
*
Industrial
Gasoline Engine and Engine Parts
ManufacturingA
336312
750 (2007 Size Standards)
23,798
0.06%
*
*
*
*
*
*
Industrial
Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336330
1,000
23,798
0.05%
*
0.13%
0.02%
0.01%
*
*
Industrial
Motor Vehicle Brake System
Manufacturing
336340
1,250
15,247
0.03%
*
0.06%
0.01%
0.01%
*
*
Industrial
Motor Vehicle Transmission and
Power Train Parts Manufacturing
336350
1,500
23,798
0.03%
*
0.09%
0.02%
0.01%
0.00%
*
Industrial
Motor Vehicle Seating and Interior
Trim Manufacturing
336360
1,500
15,247
0.03%
*
0.07%
0.01%
0.00%
*
*
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Average Avoided Cost to Sales/Entity by Employee Size Categories (%)
Avoided
SBA Size
Cost/Entity
100-
500-
1000-
Sector
NAICS Descriptions
NAICS
Standard (2017)
(2017S)
All
<19
20-99
499
999
2499
>2500
Industrial
Motor Vehicle Metal Stamping
336370
1,000
15,247
0.04%
0.70%
0.09%
0.02%
0.01%
0.00%
*
Industrial
Other Motor Vehicle Parts
Manufacturing
336390
1,000
45,144
0.11%
1.65%
0.21%
0.04%
0.01%
0.01%
*
Industrial
All Other Motor Vehicle Parts
ManufacturingA
336399
750 (2007 Size Standards)
23,798
0.06%
*
*
*
*
*
*
Industrial
Aircraft Manufacturing
336411
1,500
104,882
0.02%
*
1.02%
0.11%
0.03%
0.01%
0.00%
Industrial
Aircraft Engine and Engine Parts
Manufacturing
336412
1,500
57,102
0.07%
2.71%
0.42%
0.06%
0.02%
0.01%
0.00%
Industrial
Other Aircraft Parts and Auxiliary
Equipment Manufacturing
336413
1,250
50,126
0.12%
*
0.36%
0.07%
0.02%
*
0.00%
Industrial
Guided Missile and Space Vehicle
Propulsion Unit and Propulsion Unit
Parts Manufacturing
336415
1,250
15,247
0.01%
*
*
*
*
0.00%
*
Industrial
Railroad Rolling Stock
Manufacturing
336510
1,500
15,247
0.02%
*
0.06%
0.01%
0.00%
*
*
Industrial
Ship Building and Repairing
336611
1,250
53,309
0.14%
3.45%
0.48%
0.09%
0.04%
0.01%
0.00%
Industrial
Boat Building
336612
1,000
15,207
0.17%
*
0.14%
0.02%
0.01%
*
*
Industrial
Military Armored Vehicle, Tank,
and Tank Component
Manufacturing
336992
1,500
23,798
0.02%
*
*
0.03%
*
*
*
Industrial
Wood Kitchen Cabinet and
Countertop Manufacturing
337110
750
9,467
0.56%
*
*
0.03%
0.01%
*
*
Industrial
Upholstered Household Furniture
Manufacturing
337121
1,000
23,798
0.26%
*
*
0.07%
0.02%
*
*
Industrial
Nonupholstered Wood Household
Furniture Manufacturing
337122
750
53,297
2.92%
*
0.90%
0.18%
*
*
*
Industrial
Institutional Furniture
Manufacturing
337127
500
15,247
0.22%
*
0.20%
0.04%
*
*
*
Industrial
Wood Office Furniture
Manufacturing
337211
1,000
57,102
0.78%
*
0.76%
0.12%
*
*
*
Industrial
Office Furniture (except Wood)
Manufacturing
337214
1,000
25,834
0.07%
*
0.28%
0.04%
0.01%
*
*
Industrial
Showcase, Partition, Shelving, and
Locker Manufacturing
337215
500
15,247
0.23%
*
0.18%
0.04%
0.01%
*
*
Industrial
Blind and Shade Manufacturing
337920
1,000
15,247
0.29%
*
0.18%
0.04%
*
*
*
Industrial
Surgical and Medical Instrument
Manufacturing
339112
1,000
**
* **
* **
**
**
**
* **
Industrial
Surgical Appliance and Supplies
Manufacturing
339113
750
**
* **
* **
**
**
**
* **
Industrial
Jewelry and Silverware
Manufacturing
339910
500
**
**
**
* **
* **
* **
* **
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
Avoided Cost to Sales/Entity by Employee Size Categories (%)
All
<19
20-99
100-
499
500-
999
1000-
2499 >2500
Industrial
Sporting and Athletic Goods
339920
750
**
**
**
**
**
**
*
**
Manufacturing
Industrial
Office Supplies (except Paper)
339940
750
**
* **
**
**
*
**
*
**
*
**
Manufacturing
Industrial
Gasket, Packing, and Sealing
339991
500
**
* **
**
**
**
*
**
*
**
Device Manufacturing
Industrial
Burial Casket Manufacturing
339995
1,000
15,247
0.21%
*
*
*
*
*
*
Industrial
All Other Miscellaneous
339999
500
23,798
1.12%
4.47%
0.34%
0.03%
*
*
*
Manufacturing
Commercial
Grain and Field Bean Merchant
424510
200
**
**
**
* **
*
**
*
**
*
**
Wholesalers
Commercial
Petroleum Bulk Stations and
424710
200
20,948
0.01%
0.03%
0.01%
*
*
*
*
Terminals
Commercial
Scheduled Passenger Air
481111
1,500
**
**
**
* **
*
**
*
**
*
**
Transportation
Commercial
Line-Haul Railroads
482111
1,500
* **
* **
* **
* **
*
**
*
**
*
**
Energy
Pipeline Transportation of Crude Oil
486110
1,500
**
**
**
* **
*
**
*
**
*
**
Energy
Pipeline Transportation of Natural
CtQ C
486210
$27.5 million
28,240
0.24%
0.57%
0.08%
*
*
*
*
Energy
Pipeline Transportation of Refined
486910
1,500
**
**
* **
* **
*
**
*
**
*
**
Petroleum Products
Commercial
Support Activities for Rail
488210
$15 million
15,247
0.37%
1.32%
0.21%
*
*
*
*
Transportation
Commercial
Marine Cargo Handling
488320
$38.5 million
**
**
**
* **
*
**
*
**
*
**
Commercial
General Warehousing and Storage
493110
$27.5 million
24,809
1.34%
2.75%
0.84%
*
*
*
*
Commercial
Other Warehousing and Storage
493190
$27.5 million
23,798
0.92%
3.35%
0.66%
*
*
*
*
Commercial
Lessors of Nonresidential Buildings
531120
$27.5 million
**
**
**
* **
*
**
*
**
*
**
(except Mini warehouses)
Commercial
Testing Laboratories
541380
$15 million
**
**
**
* **
*
**
*
**
*
**
Commercial
Research and Development in the
541715
1,000
* **
* **
* **
* **
*
**
*
**
*
**
Physical, Engineering and Life
Sciences (except Nanotechnology
and Biotechnology)^
Commercial
All Other Support Services
561990
$11 million
**
**
**
* **
*
**
*
**
*
**
Waste Treatment
Hazardous Waste Treatment and
562211
$38.5 million
88,855
1.04%
5.00%
0.74%
*
*
*
*
Disposal
Waste Treatment
Solid Waste Landfill
562212
$38.5 million
63,290
1.46%
2.83%
0.46%
*
*
*
*
Waste Treatment
Solid Waste Combustors and
562213
$38.5 million
23,798
0.10%
*
0.07%
*
*
*
*
Incinerators
Waste Treatment
Remediation Services
562910
$20.5 million
15,247
0.41%
1.28%
0.21%
*
*
*
*
Educational Services
Colleges, Universities, and
611310
$27.5 million
37,382
*
*
*
*
*
*
*
Professional Schools
to
^1
^1
(continued)
-------
Table 6-9. Avoided Cost to Sales in Year 5 under ALTERNATIVE SCENARIO 2 (continued)
Sector
NAICS Descriptions
NAICS
SBA Size
Standard (2017)
Average
Avoided
Cost/Entity
(2017$)
All
Avoided Cost to Sales/Entity by Employee Size Categories (%)
100- 500- 1000-
<19 20-99 499 999 2499 >2500
Commercial
Amusement and Theme Parks
713110
$38.5 million
**
**
**
* **
* **
* ** * **
Commercial
Linen and Uniform Supply
812330
#N/A
* **
* **
* **
* **
* **
* ** * **
Commercial
Industrial Launderers
812332
$38.5 million
15,247
0.26%
0.98%
0.24%
*
*
* *
Notes:
Blanks in "Average Avoided Cost/Entity" column are for NAICS where zero facilities are eligible to obtain area source status. NA means it is not a valid 2012 NAICS code, thus an SBA Size Standard
is not available.
*No receipts data available from Census; cost-to-sales ratios cannot be calculated.
"Zero facilities estimated to obtain area source status and no estimated net costs (savings); cost-to-sales ratios cannot be calculated.
*,"Denotes a data status as a combination of footnotes * and **.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern Research Group. August 2020. ERG
MM2A Database Memorandum, Analytical Evaluations & Summary of Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the
Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final
rulemaking "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD., SBA February 2016 Size Standards, SBA 2007
Size Standards.
to
^1
00
-------
6.6 Comparison of the Percentile Results for Each Scenario
As depicted in Table 6-10 below, the year 1 and 5 percentile results across all
employment size categories are similar across the three scenarios with year 1 showing more
similarity across scenarios than year 5. In year 1, the twenty-fifth percentiles are -0.01 percent
for each scenario, the medians are less than 0.01 percent for each scenario, and the seventy-fifth
percentiles are less than 0.01 percent for each scenario. In year 5, the twenty-fifth percentiles are
between 0.01 percent and 0.03 percent for the three scenarios, the median estimates are between
0.05 percent and 0.06 percent for each scenario, and the seventy-fifth percentiles are between
0.17 percent and 0.23 percent for the three scenarios (0.17 percent for the primary scenario, 0.23
percent for alternative scenario 1, and 0.18 percent for alternative scenario 2). All of these results
are lower than those for the proposal due to the lower estimates of net cost savings for this final
rule compared to the proposal.
Table 6-10. Avoided Cost-to-Sales Ratios Percentile Results for the Three Scenarios
PRIMARY SCENARIO ALTERNATIVE SCENARIO 1 ALTERNATIVE SCENARIO 2
Year 1
Year 5
Year 1
Year 5
Year 1
Year 5
25th Percentile
-0.01%
0.01%
-0.01%
0.03%
-0.01%
0.02%
50th Percentile
(Median)
75 th Percentile
0.00%
0.05%
0.00%
0.05%
0.00%
0.06%
0.00%
0.17%
0.00%
0.23%
0.00%
0.18%
Note:
The year 5 percentile results are for year 5 and are also the annual results for years thereafter.
Sources: 2012 Economic Census, 2012 County Business Patterns, 2017 SBA Size Standards, SBA February 2016
Size Standards, SBA 2007 Size Standards, Federal Reserve Bank of St. Louis Economic Research, Eastern
Research Group. August 2020. ERG MM2A Database Memorandum, Analytical Evaluations & Summary of
Industries Potentially Impacted by the Final Rule "Reclassification of Major Sources as Area Sources Under
Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August
2020. ERG MM2A Cost Analysis Memorandum, Compliance cost savings analysis for the final rulemaking
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for
U.S. EPA/OAQPS/SPPD.
279
-------
280
-------
SECTION 7.
LIMITATIONS AND UNCERTAINTIES
The costs and economic impacts estimated in this RIA are subject to limitations and
uncertainties. The most prominent uncertainty is that the EPA does not know what major sources
will take advantage of the opportunity to reclassify to area source status. The original 2007
proposal did not provide analyses of removing the OIAI because it was stated that impacts could
not be quantified without knowing which sources will avail themselves of the regulatory
provisions proposed in this rule and what methods of HAP emission reductions will be used. In
addition, the 2007 proposal also indicated, "It is unknown how many sources would choose to
take permit conditions that would limit their PTE to below major source levels. Within this
group, it also is not known how many sources may increase their emissions from the major
source MACT level (assuming the level is below the MST). Similarly, we cannot identify or
quantify the universe of sources that would decrease their HAP emissions to below the level
required by the NESHAP to achieve area source status."
The final rule provides potential regulatory relief (i.e., the avoided costs) to affected
major sources that are eligible to reclassify. Regulatory relief estimates as measured by avoided
costs are provided for years 1 through 5 after promulgation of this rulemaking. The avoided costs
are based on the best data available currently regarding sources affected and burden cost
estimates but are subject to uncertainties.
This RIA is limited in its analyses because it estimates administrative burden reduction
and some economic impact as measured by avoided cost-to-sales ratios, and we are unable to
provide a quantitative estimate of benefits or disbenefits as explained in the benefits/disbenefits
section of this RIA. The analysis does not measure costs or cost savings related to changes in the
use of control equipment (e.g., decrease in control device operating and maintenance costs due to
reduced device use) except for potential control cost impacts associated with the illustrative
alternative scenario 2 scenario as presented in Section 4, and does not provide quantitative
estimates of changes in benefits.
In addition, the analysis presumes a zero probability of an area source reclassifying to
major status after the source has reclassified to area. Moreover, because these estimates presume
a fixed state of the affected industries into the future, it does not capture the potential for
increased entry into affected markets because of the alleviated regulatory burden. This could
subsequently induce additional regulatory costs on new firms and state regulatory agencies. With
these considerations in mind, the cost savings estimates in the RIA may serve as an upper bound.
281
-------
7.1 Avoided Cost Estimate Limitations and Uncertainties
7.1.1 Uncertainties in Estimates of Affected Sources
These estimates presume that the number of sources in the RTR modeling files is an
accurate indication of the number of sources, whether available directly or from an extrapolated
approach based on RTR modeling files and others, and their HAP emissions for source
categories currently and in the near future. Some of the RTR modeling files contain emissions
and source data that are several years old. In addition, the NEI data used to estimate the number
of affected sources for some source categories are from 2017. Changes in the source categories
due to mergers and acquisitions and other economic factors (i.e., effects from the COVID-19
pandemic) since then may mean some differences between the information used in the analysis
and numbers of sources in these categories currently and in the near future.
7.1.2 Uncertainties in Facility Estimates
There is uncertainty about the number of facilities in source categories for which the EPA
did not collect and review permits. The analysis is likely to overestimate the number of facilities
in these source categories. This overestimate could be in the range of 5 to 10 percent of the
estimated number of facilities. The accuracy of the emissions values used by the EPA from RTR
Emissions datasets depends on factors such as the data source, method, completeness, and other
factors. This could influence the EPA's estimate of the number of facilities below MST
thresholds.
The emission estimates considered by the EPA in the analysis are annual totals for certain
years and do not account for year-to-year variations. Therefore, the estimate of the number of
facilities with emissions below MST thresholds is based on a single year's emission estimate for
each facility, whereas facilities are likely to reclassify based on estimated emissions several years
in the future.
7.1.3 Uncertainties in Permitting and Supporting Statement Costs
The permitting costs used in the cost analysis to generate the cost savings estimates are
surrogate values from the minor NSR permitting process and Administrative Amendments under
40 CRR part 70 permitting process. Thus, there may be variation in such costs by source
category at the source level that this analysis may not capture. The current and future compliance
costs are based on compliance costs estimated to fulfill Paperwork Reduction Act requirements
(44 U.S.C. § 3501 et seq.). Those costs are estimated for each major source subpart for a typical
facility using the estimate of hours needed to complete monitoring, recordkeeping, and reporting
activities, and other capital and operation and maintenance costs. These estimates are subject to
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public review and comment, but they are not the actual costs for each facility. The estimated
compliance costs after facilities obtain area source status were based on the average estimated
compliance costs for a relatively small number of area source rules. Each major source rule does
not have a corresponding area source rule, so the average area source rule cost may not be
representative of the actual compliance cost for all source categories.
In addition, the costs in the ICRs used in the cost savings analysis may reflect data that
are different from the most current information. These uncertainties are relevant for the estimates
of PV and EAV for each scenario as well as the estimates of reduced administrative burden
provided by the MM2A Cost Analysis Memorandum.
7.2 Economic Impact Data and Analysis Limitations and Uncertainties
There is uncertainty in the estimates of sources affected by this final rule and the burden
costs used to estimate the regulatory relief from this rule, as mentioned previously in this RIA.
These uncertainties also affect the economic impact analysis. The economic impact analysis
compares the avoided burden cost estimates with average industry revenues to gauge the impact
of the final MM2A rule for affected sources. We used average industry revenue and average
establishment revenue estimates by entity size to estimate the avoided cost-to-sales ratios. The
actual impacts to individual entities affected by this policy change may differ from industry
averages.
The average entity costs used to compute the sales test vary across sources but are the
same across establishment size categories. As a result, the sales test may overstate the cost-to-
receipt ratio for establishments owned by small businesses, all other factors remaining the same.
In addition, a major assumption in the estimation of potential cost savings is that all major
sources in each source category that can reclassify to an area source will do so subject to a HAP
PTE limits. It is possible that major sources may choose not to reclassify based on cost savings
not being a sufficient incentive to do so, or for other reasons (e.g., companies concerned with
their environmental reputation). For example, facilities that have already made substantial
investments in controls or process changes needed to comply may choose to retain major source
status to maintain flexibility to allow for future increases in production. This uncertainty affects
the number of facilities that would be eligible to obtain area source status.
7.3 Sales Test Data Limitations and Uncertainties
Using the 2012 Economic Census, we collected and organized data on number of
establishments, employment, and receipts for affected sources represented by NAICS codes.
However, because of confidentiality issues, some data values were not available or reported with
283
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a range of values. In addition, some NAICS codes were not valid 2012 NAICS codes, and either
no data were reported for them in the 2012 Economic Census or limited data were reported not
broken down by size categories. These data limitations prevented us from reporting avoided cost-
to-sales ratios for every employment size category for some NAICS codes. Table 7-1 lists these
data limitations by NAICS code.
Table 7-1. Data Limitations for Specific NAICS Codes
NAICS
Data Limitations
115114
Not covered in Economic Census, used 2012 County Business Patterns (no
revenue data)
221119
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
311222
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
311223
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
313111
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
313113
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
313221
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
313311
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
314992
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
322222
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
323110
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325131
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325132
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325181
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325182
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325188
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325192
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325221
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
325222
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
327124
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331111
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331112
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
employment-size categories)
Census
no
data for
(continued)
284
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Table 7-1. Data Limitations for Specific NAICS Codes (continued)
NAICS
Data Limitations
331312
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331411
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331419
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331422
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
331521
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
332212
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
332990
employment-size categories)
Invalid NAICS Code
333293
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
333512
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
333513
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
334411
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
336311
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
336312
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
336399
employment-size categories)
2007 NAICS: Data only available for all establishments in 2012 Economic
Census
no
data for
482111
employment-size categories)
Not covered in Economic Census
541715
2017 NAICS: Not covered in 2012 Economic Census
611310
Not covered in Economic Census, used 2012 County Business Patterns (no
revenue data)
812330
Invalid NAICS Code
922140
Not covered in Economic Census
927110
Not covered in Economic Census
928110
Not covered in Economic Census
999999
Unclassified NAICS
Sources: 2012 Economic Census, 2012 County Business Patterns.
The underlying establishment and receipts data are a limiting factor because if either of
these measures is not reported for a certain category, we cannot calculate the average receipts per
establishment, which is needed for the avoided cost-to-sales ratio calculation. However, there are
cases where avoided cost-to-sales ratios are not reported because zero facilities are estimated to
obtain area source status; therefore, there are no facilities to calculate the average cost per entity.
This RIA estimates administrative burden reduction and some economic impact as
measured by avoided cost-to-sales ratios. The analysis does not measure overall costs or cost
savings related to control equipment changes except for those provided in the illustrative analysis
285
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of the alternative scenario 2 as presented earlier in this RIA and does not provide quantitative
estimates of overall emission changes except for some source categories as mentioned earlier in
this RIA and benefits or disbenefits.
7.4 Benefits Limitations and Uncertainties
As mentioned earlier in this RIA, we are uncertain as to the distribution of the changes in
HAP and other emissions across the broad array of sources impacted by this final rule. As such,
we are unable to quantify the changes in emissions across these sources and cannot either
simulate the change in air quality or characterize the impact of these changes to human health.
This is not to imply that changes in emissions will not affect human health. Rather, our approach
reflects the challenges associated with modeling the direct and indirect impacts of the reductions
in emissions for these sectors with the data currently available. In place of quantitative estimates
of the quantity and economic value of the pollutant changes, we instead characterize in the
benefits/disbenefits section these impacts in qualitative terms.
286
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287
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SECTION 8.
REFERENCES
Aksoy, M. 1989. Hematotoxicity and carcinogenicity of benzene. Environ Health Perspect 82:
193-197.
Chemical Industry Institute of Toxicology (CUT). 1980. A twenty-four month inhalation
toxicology study in Fischer-344 rats exposed to atmospheric toluene. Conducted by
Industrial Bio-Test Laboratories, Inc., Decatur, IL, and Experimental Pathology
Laboratories, Inc., Raleigh, NC, for CUT, Research Triangle Park, NC.
Eastern Research Group. August 2020a. ERG MM2A Database Memorandum, Analytical
Evaluations & Summary of Industries Potentially Impacted by the Final Rule
"Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air
Act" Memorandum for U.S. EPA/OAQPS/SPPD.
Eastern Research Group. August 2020b. ERG MM2A Cost Analysis Memorandum, Compliance
cost savings analysis for the final rulemaking "Reclassification of Major Sources as Area
Sources Under Section 112 of the Clean Air Act". Memorandum for U.S.
EPA/OAQPS/SPPD.
Fann, N., C.M. Fulcher, and B.J. Hubbell. 2009. The influence of location, source, and emission
type in estimates of the human health benefits of reducing a ton of air pollution. Air Qual
Atmos Health 2: 169-176.
Federal Register. National Emissions Standards for Hazardous Air Pollutants: General
Provisions. 72 FR 69 (January 3, 2007) https://www3.epa.gov/airtoxics/gp/fr03ia07.pdf.
Federal Reserve Bank of St. Louis Economic Research. October 26, 2018. GDP implicit price
deflator, https://fred.stlouisfed.org/series/GDPDEF#0. Accessed April 22, 2018.
Goldstein, B.D. 1988. Benzene toxicity. Occupational medicine. State of the Art Reviews. 3: 541 -
554.
Gwinn, M.R., J. Craig, D.A. Axelrad, R. Cook, C. Dockins, N. Fann, R.et al. 2011. Meeting
report: Estimating the benefits of reducing hazardous air pollutants—summary of 2009
workshop and future considerations. Environ Health Perspect 119(1): 125-30.
Huff, J., 2003. Absence of carcinogenic activity in Fischer rats and B6C3F1 mice following 103-
week inhalation exposures to toluene. Int JOccup Environ Health 9: 138-146.
Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: Synthesis
Report. Contribution of Working Groups I, II and III to the Fourth Assessment Report of
the Intergovernmental Panel on Climate Change (AR4) [Core Writing Team, Pachauri,
R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, pp. 104
http://www.ipcc.ch/publications and data/publications ipcc fourth assessment report s
vnthesis report.htm. Accessed March 30, 2015.
288
-------
Intergovernmental Panel on Climate Change (IPCC). 2014. Climate Change 2014: Synthesis
Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of
the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and
L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland.
International Agency for Research on Cancer (IARC). 1982. Monographs on the Evaluation of
Carcinogenic Risk of Chemicals to Humans, Some Industrial Chemicals and Dye stuffs.
29: 345-389. IARC, World Health Organization: Lyon, France.
International Agency for Research on Cancer (IARC). 1987. Monographs on the Evaluation of
Carcinogenic Risk of Chemicals to Humans. Some Industrial Chemicals and Dyestuffs.
29(Suppl 7). World Health Organization: Lyon, France.
International Agency for Research on Cancer (IARC). 1999. IARC Monographs on the
Evaluation of Carcinogenic Risks of Chemicals to Humans. Vol. 71, Part 2. Re-
evaluation of Some Organic Chemicals, Hydrazine and Hydrogen Peroxide. Lyon,
France: International Agency for Research on Cancer, pp. 829-864.
International Agency for Research on Cancer (IARC). 2000. Monographs on the Evaluation of
Carcinogenic Risks to Humans. Some Industrial Chemicals. 77: 227-266. IARC: Lyon,
France.
Irons, R.D., W.S. Stillman, D.B. Colagiovanni, and V.A. Henry. 1992. Synergistic action of the
benzene metabolite hydroquinone on myelopoietic stimulating activity of
granulocyte/macrophage colony-stimulating factor in vitro, Proc. Natl. Acad. Sci.
89:3691-3695.
Krewski, D., M. Jerrett, R.T. Burnett, R. Ma, E. Hughes, Y. Shi, et al. 2009. Extended Follow -
Up and Spatial Analysis of the American Cancer Society Study Linking Particulate Air
Pollution and Mortality. HEI Research Report 140. Boston, MA: Health Effects Institute,
pp. 4-64.
Laden, F., J. Schwartz, F.E. Speizer, and D.W. Dockery. 2006. Reduction in fine particulate air
pollution and mortality. Am J Re spir Crit Care Med 173: 667-672.
Landers, D.H., S.L. Simonich, D.A. Jaffe, L.H. Geiser, D.H. Campbell, A.R. Schwindt, C.B. et
al. 2008. The Fate, Transport and Ecological Impacts of Airborne Contaminants in
Western National Parks (USA). EPA/600/R-07/138. Corvallis, OR: U.S. Environmental
Protection Agency, Office of Research and Development, NHEERL, Western Ecology
Division.
Lepuele, J., F. Laden, D. Dockery, and J. Schwartz. 2012. Chronic exposure to fine particles and
mortality: an extended follow-up of the Harvard Six Cities Study from 1974 to 2009.
Environ Health Perspect 120(7): 965-970.
Maltoni, C., A. Ciliberti, C. Pinto, M. Soffritti, F. Belpoggi, and L. Menarini. 1997. Results of
long-term experimental carcinogenicity studies of the effects of gasoline, correlated fuels,
and major gasoline aromatics on rats. Annals NY Acad Sci 837: 15-52.
289
-------
Maltoni, C., B. Conti, C. Giuliano, andF. Belpoggi. 1985. Experimental studies on benzene
carcinogenicity at the Bologna Institute of Oncology: current results and ongoing
research. Am JIndMed 7: 415-446.
National Toxicology Program (NTP). 1990. Toxicology and Carcinogenesis Studies of Toluene
(CAS No. 108-88-3) in F344/NRats andB5C3F1 Mice (Inhalation Studies). Technical
Report Series No. 371. Research Triangle Park, NC: Public Health Service, U.S.
Department of Health and Human Services.
National Toxicology Program (NTP). 1999. Toxicology and Carcinogenesis Studies of
Ethylbenzene (CAS No. 100-41-4) in F344/N Rats and in B6C3F1 Mice (Inhalation
Studies). Technical Report Series No. 466. NIH Publication No. 99-3956. Research
Triangle Park, NC: U.S. Department of Health and Human Services, Public Health
Service, National Institutes of Health. NTP.
Nelson, A. January 2018. Withdrawal of EPA's "Once In Always In" Policy for Major Sources
of Hazardous Air Pollutants Reduces Burden and Encourages Emission Reduction.
Pope, C.A., III, R.T. Burnett, M.J. Thun, E.E. Calle, D. Krewski, K. Ito, and G.D. Thurston.
2002. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine
particulate air pollution. JAMA 287: 1132-1141.
Roman, H.A., K.D. Walker, T.L. Walsh, L. Conner, H.M. Richmond, J. Hubbell, and P.L.
Kinney. 2008. Expert judgment assessment of the mortality impact of changes in ambient
fine particulate matter in the U.S. Environ Sci Technol 42(7): 2268-2274.
Sisler, J.F. 1996. Spatial and seasonal patterns and long-term variability of the composition of
the haze in the United States: an analysis of data from the IMPROVE network. CIRA
Report, ISSN 0737-5352-32, Colorado State University.
U.S. Census Bureau. 2012 Economic Census, https://factfinder.census.gov/
U.S. Department of Health and Human Services. 2016. National Toxicology Program 11th
Report on Carcinogens. https://ntp.niehs.nih.gov/pubhealth/roc/index-l.html.
U.S. Energy Information Administration (U.S. EIA). 2015. Engineering Economic Analysis
Guide: Liquid Fuels Technologies. December.
https://www.eia. gov/outlooks/documentation/workshops/pdf/EEAGuide 12082015 .pdf.
U.S. Environmental Protection Agency (U.S. EPA). 1995. Seitz Memorandum, Potential to Emit
for MACT Standards-Guidance on Timing Issues.
https://www.epa.gov/sites/production/files/2018-02/documents/pteguid.pdf.
U.S. Environmental Protection Agency (U.S. EPA). 2000a. Integrated Risk Information System
File for Benzene. Washington, DC: Research and Development, National Center for
Environmental Assessment, http://www.epa.gov/iris/subst/0276.htm.
290
-------
U.S. Environmental Protection Agency (U.S. EPA). 2000b. Integrated Risk Information System
(IRIS) on Vinyl Chloride, http://www.epa.gov/iris/subst/1001 .htm.
U.S. Environmental Protection Agency (U.S. EPA). January 2, 2004. NESHAP for
Miscellaneous Metal Parts and Products, Final Rule. 69 FR 130.
https://www.govinfo.gov/content/pkg/FR-2004-01-02/pdf/Q3-21917.pdf.
U.S. Environmental Protection Agency (U.S. EPA). 2005. Full IRIS Summary for Toluene
(CASRN 108-88-3). Cincinnati, OH: Environmental Protection Agency, Integrated Risk
Information System (IRIS), Office of Health and Environmental Assessment,
Environmental Criteria and Assessment Office, http://www.epa.gov/iris/subst/0118.htm.
U.S. Environmental Protection Agency (U.S. EPA). 2006a. Air Quality Criteria for Ozone and
Related Photochemical Oxidants (Final). EPA/600/R-05/004aF-cF. Office of Research
and Development, Research Triangle Park, NC.
http ://cfpub. epa. gov/ncea/CFM/recordisplav.cfm? deid= 149923.
U.S. Environmental Protection Agency (U.S. EPA). 2006b. Regulatory Impact Analysis, 2006
National Ambient Air Quality Standards for Particulate Matter, Chapter 5. Office of Air
Quality Planning and Standards, Research Triangle Park, NC.
http://www.epa.gov/ttn/ecas/regdata/RIAs/Chapter%205—Benefits.pdf
U.S. Environmental Protection Agency (U.S. EPA). November 2006c. EPA's Action
Development Process: Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as
amended by the Small Business Regulatory Enforcement Fairness.
https://www.epa.gov/reg-flex/epas-action-development-process-final-guidance-epa-
rulewriters-regulatory-flexibility-act
U.S. Environmental Protection Agency (U.S. EPA). 2008. Integrated Science Assessment (ISA)
for Oxides of Nitrogen and Sulfur - Ecological Criteria. Washington, DC: EPA.
U.S. Environmental Protection Agency (U.S. EPA). 2009a. Integrated Science Assessment for
Particulate Matter (Final Report). EPA-600-R-08-139F. Research Triangle Park, NC:
National Center for Environmental Assessment.
http://cfpub.epa.gov/ncea/cfm/recordisplav.cfm?deid=216546. Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). 2009b. Technical Support Document for
Final Endangerment and Cause or Contribute Findings for Greenhouse Gases under
Section 202(a) of the Clean Air Act.
http://www.epa.gOv/climatechange/endangerment/downloads/Endangerment%20TSD.p
d. Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). May 2010a. Regulatory Impact Analysis for
the Final Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring
Rule. EPA 452/R-10-003.
291
-------
U.S. Environmental Protection Agency (U.S. EPA). 2010b. Regulatory Impact Analysis,
National Ambient Air Quality Standards for Ozone. Office of Air Quality Planning and
Standards, Research Triangle Park, NC. http://www.epa.gov/ttn/ecas/regdata/RIAs/s 1 -
supplemental analysis full.pdf. Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). March 201 la. The Benefits and Costs of the
Clean Air Act from 1990 to 2020. Office of Air and Radiation, Washington, DC.
http://www.epa.gov/air/sect812/febll/fullreport.pdf. Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). February 2011b. Regulatory Impact
Analysis: National Emission Standards for Hazardous Air Pollutants for Industrial,
Commercial, and Institutional Boilers and Process Heaters. Office of Air Quality
Planning and Standards, Research Triangle Park, NC.
http://www.epa.gov/ttn/ecas/regdata/RIAs/boilersriafinalll0221 psg.pdf. Accessed
March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). April 2012a. Regulatory Impact Analysis
Final New Source Performance Standards and Amendments to the National Emissions
Standards for Hazardous Air Pollutants for the Oil and Natural Gas Industry. Office of
Air Quality Planning and Standards, Health and Environmental Impacts Division.
http://www.epa.gov/ttn/ecas/regdata/RIAs/oil natural gas final neshap nsps ria.pdf.
Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). December 2012b. Regulatory Impact
Analysis for the Final Revisions to the National Ambient Air Quality Standards for
Particulate Matter. EPA- 452/R-12-003. Office of Air Quality Planning and Standards,
Health and Environmental Impacts Division.
http://www.epa.gov/ttnecasl/regdata/RIAs/oil natural gas final neshap nsps ria.pdf.
Accessed March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). February 2013. Integrated Science
Assessment of Ozone and Related Photochemical Oxidants (Final Report). U.S.
Environmental Protection Agency, Washington, DC, EPA/600/R-10/076F.
http://cfpub.epa.gOv/ncea/isa/recordisplav.cfm?deid=247492#Download. Accessed
March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). August 2014a. Health Risk and Exposure
Assessment for Ozone (Final Report). U.S. Environmental Protection Agency, Research
Triangle Park, NC, EPA-452/R-14-004a.
http://www.epa.gov/ttn/naaqs/standards/ozone/data/20140829healthrea.pdf. Accessed
March 30, 2015.
U.S. Environmental Protection Agency (U.S. EPA). December 2014b. Regulatory Impact
Analysis for the Final Ozone NAAQS. EPA-452/P-14-006. Research Triangle Park, NC:
U.S. Environmental Protection Agency.
http://www.epa.gov/ttnecasl/regdata/RIAs/20141125ria.pdf. Accessed March 30, 2015.
292
-------
U.S. Environmental Protection Agency (U.S. EPA). 2016. Integrated Science Assessment (ISA)
for Nitrogen Dioxide (Health Criteria). Washington, DC: EPA.
U.S. Environmental Protection Agency (U.S. EPA). 2017. Integrated Science Assessment (ISA)
for Sulfur Oxides (Health Criteria). Washington, DC: EPA.
U.S. Environmental Protection Agency (U.S. EPA). February 1, 2018a. EPA Air Pollution
Control Cost Manual. Section 1, Chapter 2. Cost Estimation: Costs and Methodology.
https://www.epa.gov/sites/production/files/2017-
12/documents/epaccmcostestimationmethodchapter 7thedition 2017.pdf
U.S. Environmental Protection Agency (U.S. EPA). January 2018b. Reducing regulatory
burdens: EPA withdraws "once in always in" policy for major sources under Clean Air
Act. https://www.epa.gov/newsreleases/reducing-regulatory-burdens-epa-withdraws-
once-alwavs-policv-maior-sources-under-clean
U.S. Environmental Protection Agency (U.S. EPA). September 2018c. Regulatory Impact
Analysis for the Final Reconsideration of the Oil and Natural Gas Sector Standards for
New, Reconstructed, and Modified Sources. Office of Air Quality Planning and
Standards, Health and Environmental Impacts Division.
https://www.epa.gov/sites/production/files/2Q18-
09/documents/oil and natural gas nsps reconsideration final ria.pdf
U.S. Environmental Protection Agency (U.S. EPA). January 2018d. MM2A Memorandum,
Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air
Act. https://www.epa.gov/sites/production/files/2Q18-
01/documents/reclassification of major sources as area sources under section 112 o
f the clean air act.pdf
U.S. Environmental Protection Agency (U.S. EPA). 2019. Integrated Science Assessment (ISA)
for Particulate Matter (Final Report). EPA-600-R-19-188. Research Triangle Park, NC:
Center for Public Health and Environmental Assessment.
https://cfpub.epa.gov/ncea/isa/recordisplav.cfm?deid=347534. Accessed April 29, 2020.
U.S. Environmental Protection Agency (U.S. EPA). 2020a. Integrated Science Assessment of
Ozone and Related Photochemical Oxidants (Final Report). EPA/600/R-20/012. U.S.
Research Triangle Park, NC: Center for Public Health and Environmental Assessment.
https://cfpub.epa.gov/ncea/isa/recordisplav.cfm?deid=348522. Accessed April 29, 2020.
U.S. Environmental Protection Agency (U.S. EPA). 2020b. 2017 National Emissions Inventory
(NEI) Technical Support Document. https://www.epa.gov/sites/production/files/202Q-
04/documents/nei2017 tsd full 30apr2020.pdf.
U.S. Environmental Protection Agency (U.S. EPA). Memorandum. Larry Sorrels, U.S.
EPA/OAQPS/HEID/AEG to EPA Docket No. EPA-HQ-OAR-2019-0282. "Analysis for
Illustrative 125% Scenario for MM2A Final - Potential Cost Impacts from HAP Major
Sources Reducing Emissions as part of Reclassifying to HAP Area Sources." August
2020.
293
-------
U.S. Environmental Protection Agency (U.S. EPA). Memorandum from Elineth Torres to
Docket No. EPA-HQ-OAR-2019-0282. Documentation of the emission impacts analysis
for the final rulemaking: "Reclassification of Major Sources as Area Sources under
Section 112 of the Clean Air Act." May 2019.
U.S. Environmental Protection Agency (U.S. EPA). Memorandum from Kaye Whitfield to
Docket No. EPA-HQ-OAR-2010-0786. Cost Analyses for Control Options. September
27, 2010. Prepared for the Wood Furniture Manufacturing Operations NESHAP, Final
Rule.
U.S. Environmental Protection Agency, Science Advisory Board (EPA-SAB). 2008. Benefits of
Reducing Benzene Emissions in Houston, 1990-2020. EPA-COUNCIL-08-001. July.
http://vosemite.epa.gov/sab/sabproduct.nsf/D4D7EC9DAEDA8A54852574860Q728A8
3/$File/EPA-CQUNCIL-08-001-unsigned.pdf. Accessed March 30, 2015.
U.S. Federal Reserve Board, St. Louis. Gross Domestic Product (GDP implicit price deflator).
Index: 2012-100. Annual Values. Available at
https://fred.stlouisfed.org/series/A191RD3A086NBEA. Downloaded on May 14, 2019.
U.S. Small Business Administration. Table of 2007 Small Business Size Standards. Accessed
September 2018. https://www.phoenix.gov/Documents/sbasize.pdf
U.S. Small Business Administration. Table of 2017 Small Business Size Standards. Accessed
April 2018. https://www.sba.gov/sites/default/files/files/Size Standards Table.pdf
U.S. Small Business Administration. Table of February 2016 Small Business Size Standards.
Accessed September 2018.
https://www.sba.gov/sites/default/files/files/Size Standards Table.pdf
294
-------
295
-------
ATTACHMENT A
SECTORS AND SOURCE CATEGORIES AFFECTED BY THE FINAL MM2A RULE
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO
Facilities
Number of
Facilities That
Number of
May Potentially
Facilities
Experience
Subject to
Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Agriculture
Postharvest Crop Activities (except Cotton
115114
1
0
Ginning)
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
48
Energy
Natural Gas Liquid Extraction
211112
26
11
Industrial
Iron Ore Mining
212210
11
0
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
Industrial
All Other Metal Ore Mining
212299
1
0
Industrial
Industrial Sand Mining
212322
3
0
Industrial
Kaolin and Ball Clay Mining
212324
3
0
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
Energy
Support Activities for Oil and Gas Operations
213112
3
1
Utilities
Hydroelectric Power Generation
221111
1
1
Utilities
Fossil Fuel Electric Power Generation
221112
334
100
Utilities
Biomass Electric Power Generation
221117
5
4
Utilities
Other Electric Power Generation
221118
1
1
Utilities
Other Electric Power GenerationA
221119
8
6
Utilities
Electric Power Distribution
221122
1
1
Utilities
Natural Gas Distribution
221210
13
9
Utilities
Water Supply and Irrigation Systems
221310
2
2
Utilities
Sewage Treatment Facilities
221320
17
12
Utilities
Steam and Air-Conditioning Supply
221330
22
15
Industrial
Other Animal Food Manufacturing
311119
1
0
Industrial
Wet Corn Milling
311221
16
0
Industrial
Soybean ProcessingA
311222
16
0
Industrial
Other Oilseed ProcessingA
311223
5
0
Industrial
Soybean and Other Oilseed Processing
311224
116
2
Industrial
Fats and Oils Refining and Blending
311225
2
0
Industrial
Beet Sugar Manufacturing
311313
11
0
Industrial
Cane Sugar Manufacturing
311314
3
0
Industrial
Frozen Fruit, Juice, and Vegetable
311411
2
0
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1
0
Industrial
Specialty Canning
311422
2
0
Industrial
Cheese Manufacturing
311513
2
0
(continued)
A-l
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Number of
Facilities That
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
May Potentially
Experience
Regulatory
Relief
Industrial
Dry, Condensed, and Evaporated Dairy Product
311514
3
0
Manufacturing
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
Industrial
Commercial Bakeries
311812
2
0
Industrial
Other Snack Food Manufacturing
311919
1
0
Industrial
Coffee and Tea Manufacturing
311920
1
0
Industrial
Flavoring Syrup and Concentrate Manufacturing
311930
1
0
Industrial
Spice and Extract Manufacturing
311942
4
0
Industrial
All Other Miscellaneous Food Manufacturing
311999
6
0
Industrial
Breweries
312120
3
1
Industrial
Distilleries
312140
1
0
Industrial
Tobacco Manufacturing
312230
1
0
Industrial
Yarn Spinning MillsA
313111
1
1
Industrial
Thread MillsA
313113
1
1
Industrial
Broadwoven Fabric Mills
313210
2
2
Industrial
Narrow Fabric MillsA
313221
1
1
Industrial
Textile and Fabric Finishing Mills
313310
1
1
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
Industrial
Fabric Coating Mills
313320
50
28
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
Industrial
Leather and Hide Tanning and Finishing
316110
6
4
Industrial
Sawmills
321113
61
11
Industrial
Wood Preservation
321114
3
0
Industrial
Hardwood Veneer and Plywood Manufacturing
321211
3
0
Industrial
Softwood Veneer and Plywood Manufacturing
321212
29
6
Industrial
Engineered Wood Member (except Truss)
321213
6
1
Manufacturing
Industrial
Reconstituted Wood Product Manufacturing
321219
315
61
Industrial
Wood Window and Door Manufacturing
321911
4
0
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
0
Industrial
All Other Miscellaneous Wood Product
321999
3
0
Manufacturing
Industrial
Pulp Mills
322110
18
3
Industrial
Paper (except Newsprint) Mills
322121
282
11
Industrial
Newsprint Mills
322122
7
1
Industrial
Paperboard Mills
322130
36
7
Industrial
Corrugated and Solid Fiber Box Manufacturing
322211
174
55
Industrial
Paper Bag and Coated and Treated Paper
322220
17
3
Manufacturing
Industrial
Coated and Laminated Paper ManufacturingA
322222
12
2
(continued)
A-2
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
Industrial
All Other Converted Paper Product
322299
1
0
Manufacturing
Industrial
Commercial Lithographic PrintingA
323110
1
1
Industrial
Commercial Printing (except Screen and Books)
323111
188
110
Industrial
Books Printing
323117
3
2
Industrial
Petroleum Refineries
324110
430
77
Industrial
Asphalt Shingle and Coating Materials
324122
3
0
Manufacturing
Industrial
All Other Petroleum and Coal Products
324199
4
0
Manufacturing
Industrial
Petrochemical Manufacturing
325110
597
218
Industrial
Industrial Gas Manufacturing
325120
4
1
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
Industrial
Synthetic Organic Dye and Pigment
325132
2
0
ManufacturingA
Industrial
Other Basic Inorganic Chemical Manufacturing
325180
10
3
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
Industrial
Carbon Black ManufacturingA
325182
21
7
Industrial
All Other Basic Inorganic Chemical
325188
93
3
ManufacturingA
Industrial
Cyclic Crude and Intermediate ManufacturingA
325192
1
0
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
Industrial
Cyclic Crude, Intermediate, and Gum and Wood
325194
2
0
Chemical Manufacturing
Industrial
All Other Basic Organic Chemical
325199
77
23
Manufacturing
Industrial
Plastics Material and Resin Manufacturing
325211
857
254
Industrial
Synthetic Rubber Manufacturing
325212
22
2
Industrial
Artificial and Synthetic Fibers and Filaments
325220
6
2
Manufacturing
Industrial
Cellulosic Organic Fiber ManufacturingA
325221
1
0
Industrial
Noncellulosic Organic Fiber ManufacturingA
325222
4
1
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
6
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
2
Industrial
Pesticide and Other Agricultural Chemical
325320
22
5
Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
9
(continued)
A-3
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Biological Product (except Diagnostic)
325414
1
0
Manufacturing
Industrial
Paint and Coating Manufacturing
325510
48
19
Industrial
Adhesive Manufacturing
325520
4
1
Industrial
Surface Active Agent Manufacturing
325613
2
0
Industrial
Toilet Preparation Manufacturing
325620
2
0
Industrial
Explosives Manufacturing
325920
2
0
Industrial
Custom Compounding of Purchased Resins
325991
5
2
Industrial
Photographic Film, Paper, Plate, and Chemical
325992
4
1
Manufacturing
Industrial
All Other Miscellaneous Chemical Product and
325998
10
3
Preparation Manufacturing
Industrial
Plastics Packaging Film and Sheet (including
326112
5
2
Laminated) Manufacturing
Industrial
Unlaminated Plastics Film and Sheet (except
326113
16
7
Packaging) Manufacturing
Industrial
Unlaminated Plastics Profile Shape
326121
12
0
Manufacturing
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
0
Industrial
Laminated Plastics Plate, Sheet (except
326130
7
3
Packaging), and Shape Manufacturing
Industrial
Polystyrene Foam Product Manufacturing
326140
1
0
Industrial
Urethane and Other Foam Product (except
326150
19
13
Polystyrene) Manufacturing
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
0
Industrial
All Other Plastics Product Manufacturing
326199
148
64
Industrial
Tire Manufacturing (except Retreading)
326211
39
19
Industrial
Rubber and Plastics Hoses and Belting
326220
6
2
Manufacturing
Industrial
Rubber Product Manufacturing for Mechanical
T Tcp
326291
2
0
Industrial
U oC
All Other Rubber Product Manufacturing
326299
14
5
Industrial
Pottery, Ceramics, and Plumbing Fixture
327110
4
1
Manufacturing
Industrial
Clay Building Material and Refractories
327120
76
47
Manufacturing
Industrial
Clay Refractory ManufacturingA
327124
8
3
Industrial
Flat Glass Manufacturing
327211
2
0
Industrial
Other Pressed and Blown Glass and Glassware
327212
17
7
Manufacturing
Industrial
Cement Manufacturing
327310
6
2
Industrial
Lime Manufacturing
327410
38
1
(continued)
A-4
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Gypsum Product Manufacturing
327420
1
0
Industrial
Abrasive Product Manufacturing
327910
4
1
Industrial
Mineral Wool Manufacturing
327993
13
4
Industrial
All Other Miscellaneous Nonmetallic Mineral
327999
2
0
Product Manufacturing
Industrial
Iron and Steel Mills and Ferroalloy
331110
73
39
Manufacturing
Industrial
Iron and Steel MillsA
331111
50
3
Industrial
Electrometallurgical Ferroalloy Product
331112
1
0
ManufacturingA
Industrial
Iron and Steel Pipe and Tube Manufacturing
331210
5
2
from Purchased Steel
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
Industrial
Primary Aluminum ProductionA
331312
2
0
Industrial
Alumina Refining and Primary Aluminum
331313
16
2
Production
Industrial
Secondary Smelting and Alloying of Aluminum
331314
56
7
Industrial
Aluminum Sheet, Plate, and Foil Manufacturing
331315
6
2
Industrial
Aluminum Extruded Product ManufacturingA
331316
1
0
Industrial
Other Aluminum Rolling, Drawing, and
331318
2
0
Extruding
Industrial
Nonferrous Metal (except Aluminum) Smelting
331410
1
0
and Refining
Industrial
Primary Smelting and Refining of CopperA
331411
0
0
Industrial
Primary Smelting and Refining of Nonferrous
331419
2
0
Metal (except Copper and Aluminum)A
Industrial
Copper Rolling, Drawing, Extruding, and
331420
3
0
Alloying
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
Industrial
Nonferrous Metal (except Copper and
331491
3
1
Aluminum) Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying of
331492
2
0
Nonferrous Metal (except Copper and
Aluminum)
Industrial
Iron Foundries
331511
59
4
Industrial
Steel Foundries (except Investment)
331513
2
0
Industrial
Aluminum Die-Casting Foundries'"*
331521
1
0
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
Industrial
Nonferrous Forging
332112
1
1
Industrial
Metal Crown, Closure, and Other Metal
332119
1
1
Stamping (except Automotive)
(continued)
A-5
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
Industrial
Prefabricated Metal Building and Component
332311
1
1
Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
Industrial
Metal Window and Door Manufacturing
332321
5
4
Industrial
Sheet Metal Work Manufacturing
332322
1
1
Industrial
Metal Can Manufacturing
332431
14
9
Industrial
Other Metal Container Manufacturing
332439
4
2
Industrial
Bolt, Nut, Screw, Rivet, and Washer
332722
1
1
Manufacturing
Industrial
Metal Heat Treating
332811
1
1
Industrial
Metal Coating, Engraving (except Jewelry and
332812
433
280
Silverware), and Allied Services to
Manufacturers
Industrial
Electroplating, Plating, Polishing, Anodizing,
332813
3
2
and Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
Industrial
Ammunition (except Small Arms)
332993
3
2
Manufacturing
Industrial
All Other Miscellaneous Fabricated Metal
332999
3
2
Product Manufacturing
Industrial
Farm Machinery and Equipment Manufacturing
333111
8
3
Industrial
Lawn and Garden Tractor and Home Lawn and
333112
1
0
Garden Equipment Manufacturing
Industrial
Construction Machinery Manufacturing
333120
64
28
Industrial
Mining Machinery and Equipment
333131
2
0
Manufacturing
Industrial
Printing Machinery and Equipment
333293
1
0
ManufacturingA
Industrial
Photographic and Photocopying Equipment
333316
1
0
Manufacturing
Industrial
Air-Conditioning and Warm Air Heating
333415
1
0
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
Industrial
Machine Tool (Metal Cutting Types)
333512
1
0
ManufacturingA
Industrial
Machine Tool (Metal Forming Types)
333513
1
0
ManufacturingA
Industrial
Turbine and Turbine Generator Set Units
333611
1
0
Manufacturing
Industrial
Other Engine Equipment Manufacturing
333618
5
2
(continued)
A-6
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Overhead Traveling Crane, Hoist, and Monorail
333923
1
0
System Manufacturing
Industrial
Welding and Soldering Equipment
333992
2
0
Manufacturing
Industrial
Radio and Television Broadcasting and Wireless
334220
1
0
Communications Equipment Manufacturing
Industrial
Electron Tube ManufacturingA
334411
1
0
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
Industrial
Semiconductor and Related Device
334413
23
13
Manufacturing
Industrial
Automatic Environmental Control
334512
1
0
Manufacturing for Residential, Commercial, and
Appliance Use
Industrial
Blank Magnetic and Optical Recording Media
334613
0
0
Manufacturing
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
Industrial
Household Laundry Equipment Manufacturing
335224
13
9
Industrial
Other Major Household Appliance
335228
2
2
Manufacturing
Industrial
Power, Distribution, and Specialty Transformer
335311
1
1
Manufacturing
Industrial
Motor and Generator Manufacturing
335312
2
2
Industrial
Storage Battery Manufacturing
335911
1
1
Industrial
Current-Carrying Wiring Device Manufacturing
335931
1
1
Industrial
Noncurrent-Carrying Wiring Device
335932
1
1
Manufacturing
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
Industrial
Automobile Manufacturing
336111
66
18
Industrial
Light Truck and Utility Vehicle Manufacturing
336112
5
4
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
Industrial
Motor Vehicle Body Manufacturing
336211
8
5
Industrial
Truck Trailer Manufacturing
336212
1
1
Industrial
Motor Vehicle Gasoline Engine and Engine Parts
336310
2
2
Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and Valve
336311
1
1
ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
3
2
ManufacturingA
Industrial
Motor Vehicle Steering and Suspension
336330
2
2
Components (except Spring) Manufacturing
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
1
Industrial
Motor Vehicle Transmission and Power Train
336350
2
2
Parts Manufacturing
(continued)
A-7
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Motor Vehicle Seating and Interior Trim
336360
1
1
Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1
1
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
7
Industrial
All Other Motor Vehicle Parts ManufacturingA
336399
2
2
Industrial
Aircraft Manufacturing
336411
125
102
Industrial
Aircraft Engine and Engine Parts Manufacturing
336412
8
5
Industrial
Other Aircraft Parts and Auxiliary Equipment
336413
10
6
Manufacturing
Industrial
Guided Missile and Space Vehicle Propulsion
336415
1
1
Unit and Propulsion Unit Parts Manufacturing
Industrial
Railroad Rolling Stock Manufacturing
336510
1
1
Industrial
Ship Building and Repairing
336611
92
55
Industrial
Boat Building
336612
96
26
Industrial
Military Armored Vehicle, Tank, and Tank
336992
2
2
Component Manufacturing
Industrial
Wood Kitchen Cabinet and Countertop
337110
347
233
Manufacturing
Industrial
Upholstered Household Furniture Manufacturing
337121
2
2
Industrial
Nonupholstered Wood Household Furniture
337122
14
9
Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
1
1
Industrial
Wood Office Furniture Manufacturing
337211
4
Industrial
Office Furniture (except Wood) Manufacturing
337214
19
12
Industrial
Showcase, Partition, Shelving, and Locker
337215
1
1
Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
Industrial
Surgical and Medical Instrument Manufacturing
339112
0
Industrial
Surgical Appliance and Supplies Manufacturing
339113
1
0
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
Industrial
Office Supplies (except Paper) Manufacturing
339940
1
0
Industrial
Gasket, Packing, and Sealing Device
339991
2
0
Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
Commercial
Petroleum Bulk Stations and Terminals
424710
7
3
Commercial
Scheduled Passenger Air Transportation
481111
2
0
Commercial
Line-Haul Railroads
482111
1
0
(continued)
A-8
-------
Table A-l. Sources That May Potentially Experience Regulatory Relief under the
PRIMARY SCENARIO (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Energy
Pipeline Transportation of Crude Oil
486110
1
0
Energy
Pipeline Transportation of Natural Gas
486210
257
103
Energy
Pipeline Transportation of Refined
486910
1
0
Petroleum Products
Commercial
Support Activities for Rail Transportation
488210
3
1
Commercial
Marine Cargo Handling
488320
2
0
Commercial
General Warehousing and Storage
493110
180
57
Commercial
Other Warehousing and Storage
493190
6
2
Commercial
Lessors of Nonresidential Buildings (except
531120
1
0
Miniwarehouses)
Commercial
Testing Laboratories
541380
2
0
Commercial
Research and Development in the Physical,
541715
2
0
Engineering and Life Sciences (except
Nanotechnology and Biotechnology)AA
Commercial
All Other Support Services
561990
1
0
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
23
Waste Treatment
Solid Waste Landfill
562212
6
4
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
2
Waste Treatment
Remediation Services
562910
1
1
Educational
Colleges, Universities, and Professional
611310
23
9
Services
Schools
Commercial
Amusement and Theme Parks
713110
1
0
Commercial
Linen and Uniform Supply
812330
1
0
Commercial
Industrial Launderers
812332
3
1
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. MM2A Database Memorandum,
Documentation of the Data for Analytical Evaluations & Summary of Industries Potentially Impacted by the Final
Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum
for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. MM2A Cost Analysis Memorandum,
Documentation of the compliance cost savings analysis for the final rulemaking "Reclassification of Major
Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
A-9
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number ot
Facilities That
May Potentially
Experience
Regulatory
Relief
Agriculture
Postharvest Crop Activities (except Cotton
115114
1
0
Ginning)
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
40
Energy
Natural Gas Liquid Extraction
211112
26
9
Industrial
Iron Ore Mining
212210
11
0
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
Industrial
All Other Metal Ore Mining
212299
1
0
Industrial
Industrial Sand Mining
212322
3
0
Industrial
Kaolin and Ball Clay Mining
212324
3
0
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
Energy
Support Activities for Oil and Gas Operations
213112
3
1
Utilities
Hydroelectric Power Generation
221111
1
1
Utilities
Fossil Fuel Electric Power Generation
221112
334
85
Utilities
Biomass Electric Power Generation
221117
5
4
Utilities
Other Electric Power Generation
221118
1
1
Utilities
Other Electric Power GenerationA
221119
8
5
Utilities
Electric Power Distribution
221122
1
1
Utilities
Natural Gas Distribution
221210
13
7
Utilities
Water Supply and Irrigation Systems
221310
2
2
Utilities
Sewage Treatment Facilities
221320
17
10
Utilities
Steam and Air-Conditioning Supply
221330
22
13
Industrial
Other Animal Food Manufacturing
311119
1
0
Industrial
Wet Corn Milling
311221
16
0
Industrial
Soybean ProcessingA
311222
16
0
Industrial
Other Oilseed ProcessingA
311223
5
0
Industrial
Soybean and Other Oilseed Processing
311224
116
1
Industrial
Fats and Oils Refining and Blending
311225
2
0
Industrial
Beet Sugar Manufacturing
311313
11
0
Industrial
Cane Sugar Manufacturing
311314
3
0
Industrial
Frozen Fruit, Juice, and Vegetable
311411
2
0
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1
0
Industrial
Specialty Canning
311422
2
0
Industrial
Cheese Manufacturing
311513
2
0
Industrial
Dry, Condensed, and Evaporated Dairy
311514
3
0
Product Manufacturing
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
Industrial
Commercial Bakeries
311812
2
0
(continued)
A-10
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Other Snack Food Manufacturing
311919
1
0
Industrial
Coffee and Tea Manufacturing
311920
1
0
Industrial
Flavoring Syrup and Concentrate
311930
1
0
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
4
0
Industrial
All Other Miscellaneous Food Manufacturing
311999
6
0
Industrial
Breweries
312120
3
1
Industrial
Distilleries
312140
1
0
Industrial
Tobacco Manufacturing
312230
1
0
Industrial
Yarn Spinning MillsA
313111
1
1
Industrial
Thread MillsA
313113
1
1
Industrial
Broadwoven Fabric Mills
313210
2
2
Industrial
Narrow Fabric MillsA
313221
1
1
Industrial
Textile and Fabric Finishing Mills
313310
1
1
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
Industrial
Fabric Coating Mills
313320
50
26
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
Industrial
Leather and Hide Tanning and Finishing
316110
6
4
Industrial
Sawmills
321113
61
8
Industrial
Wood Preservation
321114
3
0
Industrial
Hardwood Veneer and Plywood
321211
3
0
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
29
3
Manufacturing
Industrial
Engineered Wood Member (except Truss)
321213
6
0
Manufacturing
Industrial
Reconstituted Wood Product Manufacturing
321219
315
44
Industrial
Wood Window and Door Manufacturing
321911
4
0
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
0
Industrial
All Other Miscellaneous Wood Product
321999
3
0
Manufacturing
Industrial
Pulp Mills
322110
18
3
Industrial
Paper (except Newsprint) Mills
322121
282
9
Industrial
Newsprint Mills
322122
7
1
Industrial
Paperboard Mills
322130
36
6
Industrial
Corrugated and Solid Fiber Box
322211
174
46
Manufacturing
Industrial
Paper Bag and Coated and Treated Paper
322220
17
2
Manufacturing
Industrial
Coated and Laminated Paper ManufacturingA
322222
12
2
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
Industrial
All Other Converted Paper Product
322299
1
0
Manufacturing
(continued)
A-ll
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Commercial Lithographic PrintingA
323110
1
1
Industrial
Commercial Printing (except Screen and
323111
188
99
Books)
Industrial
Books Printing
323117
3
2
Industrial
Petroleum Refineries
324110
430
65
Industrial
Asphalt Shingle and Coating Materials
324122
3
0
Manufacturing
Industrial
All Other Petroleum and Coal Products
324199
4
0
Manufacturing
Industrial
Petrochemical Manufacturing
325110
597
190
Industrial
Industrial Gas Manufacturing
325120
4
1
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
Industrial
Synthetic Organic Dye and Pigment
325132
2
0
ManufacturingA
Industrial
Other Basic Inorganic Chemical
325180
10
2
Manufacturing
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
Industrial
Carbon Black ManufacturingA
325182
21
6
Industrial
All Other Basic Inorganic Chemical
325188
93
3
ManufacturingA
Industrial
Cyclic Crude and Intermediate
325192
1
0
ManufacturingA
Industrial
Ethyl Alcohol Manufacturing
325193
7
2
Industrial
Cyclic Crude, Intermediate, and Gum and
325194
2
0
Wood Chemical Manufacturing
Industrial
All Other Basic Organic Chemical
325199
77
20
Manufacturing
Industrial
Plastics Material and Resin Manufacturing
325211
857
197
Industrial
Synthetic Rubber Manufacturing
325212
22
2
Industrial
Artificial and Synthetic Fibers and Filaments
325220
6
2
Manufacturing
Industrial
Cellulosic Organic Fiber ManufacturingA
325221
1
0
Industrial
Noncellulosic Organic Fiber ManufacturingA
325222
4
1
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
4
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
2
Industrial
Pesticide and Other Agricultural Chemical
325320
22
3
Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
4
Industrial
Biological Product (except Diagnostic)
325414
1
0
Manufacturing
Industrial
Paint and Coating Manufacturing
325510
48
18
Industrial
Adhesive Manufacturing
325520
4
1
(continued)
A-12
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Surface Active Agent Manufacturing
325613
2
0
Industrial
Toilet Preparation Manufacturing
325620
2
0
Industrial
Explosives Manufacturing
325920
2
0
Industrial
Custom Compounding of Purchased Resins
325991
5
2
Industrial
Photographic Film, Paper, Plate, and
325992
4
1
Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical Product
325998
10
2
and Preparation Manufacturing
Industrial
Plastics Packaging Film and Sheet (including
326112
5
2
Laminated) Manufacturing
Industrial
Unlaminated Plastics Film and Sheet (except
326113
16
6
Packaging) Manufacturing
Industrial
Unlaminated Plastics Profile Shape
326121
12
0
Manufacturing
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
0
Industrial
Laminated Plastics Plate, Sheet (except
326130
7
2
Packaging), and Shape Manufacturing
Industrial
Polystyrene Foam Product Manufacturing
326140
1
0
Industrial
Urethane and Other Foam Product (except
326150
19
13
Polystyrene) Manufacturing
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
0
Industrial
All Other Plastics Product Manufacturing
326199
148
46
Industrial
Tire Manufacturing (except Retreading)
326211
39
14
Industrial
Rubber and Plastics Hoses and Belting
326220
6
2
Manufacturing
Industrial
Rubber Product Manufacturing for
326291
2
0
Mechanical Use
Industrial
All Other Rubber Product Manufacturing
326299
14
3
Industrial
Pottery, Ceramics, and Plumbing Fixture
327110
4
1
Manufacturing
Industrial
Clay Building Material and Refractories
327120
76
41
Manufacturing
Industrial
Clay Refractory ManufacturingA
327124
8
3
Industrial
Flat Glass Manufacturing
327211
2
0
Industrial
Other Pressed and Blown Glass and
327212
17
5
Glassware Manufacturing
Industrial
Cement Manufacturing
327310
6
2
Industrial
Lime Manufacturing
327410
38
1
Industrial
Gypsum Product Manufacturing
327420
1
0
Industrial
Abrasive Product Manufacturing
327910
4
1
Industrial
Mineral Wool Manufacturing
327993
13
3
Industrial
All Other Miscellaneous Nonmetallic Mineral
327999
2
0
Product Manufacturing
(continued)
A-13
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Iron and Steel Mills and Ferroalloy
331110
73
37
Manufacturing
Industrial
Iron and Steel MillsA
331111
50
2
Industrial
Electrometallurgical Ferroalloy Product
331112
1
0
ManufacturingA
Industrial
Iron and Steel Pipe and Tube Manufacturing
331210
5
1
from Purchased Steel
Industrial
Rolled Steel Shape Manufacturing
331221
6
1
Industrial
Primary Aluminum ProductionA
331312
2
0
Industrial
Alumina Refining and Primary Aluminum
331313
16
0
Production
Industrial
Secondary Smelting and Alloying of
331314
56
5
Aluminum
Industrial
Aluminum Sheet, Plate, and Foil
331315
6
1
Manufacturing
Industrial
Aluminum Extruded Product ManufacturingA
331316
1
0
Industrial
Other Aluminum Rolling, Drawing, and
331318
2
0
Extruding
Industrial
Nonferrous Metal (except Aluminum)
331410
1
0
Smelting and Refining
Industrial
Primary Smelting and Refining of CopperA
331411
0
0
Industrial
Primary Smelting and Refining of Nonferrous
331419
2
0
Metal (except Copper and Aluminum)A
Industrial
Copper Rolling, Drawing, Extruding, and
331420
3
0
Alloying
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
Industrial
Nonferrous Metal (except Copper and
331491
3
0
Aluminum) Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying
331492
2
0
of Nonferrous Metal (except Copper and
Aluminum)
Industrial
Iron Foundries
331511
59
3
Industrial
Steel Foundries (except Investment)
331513
2
0
Industrial
Aluminum Die-Casting Foundries'"*
331521
1
0
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
Industrial
Nonferrous Forging
332112
1
1
Industrial
Metal Crown, Closure, and Other Metal
332119
1
1
Stamping (except Automotive)
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
Industrial
Prefabricated Metal Building and Component
332311
1
1
Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
Industrial
Metal Window and Door Manufacturing
332321
Industrial
Sheet Metal Work Manufacturing
332322
1
1
(continued)
A-14
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Metal Can Manufacturing
332431
14
8
Industrial
Other Metal Container Manufacturing
332439
4
2
Industrial
Bolt, Nut, Screw, Rivet, and Washer
332722
1
1
Manufacturing
Industrial
Metal Heat Treating
332811
1
1
Industrial
Metal Coating, Engraving (except Jewelry and 332812
433
241
Silverware), and Allied Services to
Manufacturers
Industrial
Electroplating, Plating, Polishing, Anodizing,
332813
3
2
and Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
Industrial
Ammunition (except Small Arms)
332993
3
2
Manufacturing
Industrial
All Other Miscellaneous Fabricated Metal
332999
3
2
Product Manufacturing
Industrial
Farm Machinery and Equipment
333111
8
3
Manufacturing
Industrial
Lawn and Garden Tractor and Home Lawn
333112
1
0
and Garden Equipment Manufacturing
Industrial
Construction Machinery Manufacturing
333120
64
27
Industrial
Mining Machinery and Equipment
333131
2
0
Manufacturing
Industrial
Printing Machinery and Equipment
333293
1
0
ManufacturingA
Industrial
Photographic and Photocopying Equipment
333316
1
0
Manufacturing
Industrial
Air-Conditioning and Warm Air Heating
333415
1
0
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
Industrial
Machine Tool (Metal Cutting Types)
333512
1
0
ManufacturingA
Industrial
Machine Tool (Metal Forming Types)
333513
1
0
ManufacturingA
Industrial
Turbine and Turbine Generator Set Units
333611
1
0
Manufacturing
Industrial
Other Engine Equipment Manufacturing
333618
5
2
Industrial
Overhead Traveling Crane, Hoist, and
333923
1
0
Monorail System Manufacturing
Industrial
Welding and Soldering Equipment
333992
2
0
Manufacturing
Industrial
Radio and Television Broadcasting and
334220
1
0
Wireless Communications Equipment
Manufacturing
Industrial
Electron Tube ManufacturingA
334411
1
0
(continued)
A-15
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
Industrial
Semiconductor and Related Device
334413
23
11
Manufacturing
Industrial
Automatic Environmental Control
334512
1
0
Manufacturing for Residential, Commercial,
and Appliance Use
Industrial
Blank Magnetic and Optical Recording Media
334613
0
0
Manufacturing
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
Industrial
Household Laundry Equipment
335224
13
8
Manufacturing
Industrial
Other Major Household Appliance
335228
2
2
Manufacturing
Industrial
Power, Distribution, and Specialty
335311
1
1
Transformer Manufacturing
Industrial
Motor and Generator Manufacturing
335312
2
2
Industrial
Storage Battery Manufacturing
335911
1
1
Industrial
Current-Carrying Wiring Device
335931
1
1
Manufacturing
Industrial
Noncurrent-Carrying Wiring Device
335932
1
1
Manufacturing
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
Industrial
Automobile Manufacturing
336111
66
10
Industrial
Light Truck and Utility Vehicle
336112
5
2
Manufacturing
Industrial
Heavy Duty Truck Manufacturing
336120
8
2
Industrial
Motor Vehicle Body Manufacturing
336211
8
2
Industrial
Truck Trailer Manufacturing
336212
1
0
Industrial
Motor Vehicle Gasoline Engine and Engine
336310
2
0
Parts Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and Valve
336311
1
0
ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
3
1
ManufacturingA
Industrial
Motor Vehicle Steering and Suspension
336330
2
0
Components (except Spring) Manufacturing
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
0
Industrial
Motor Vehicle Transmission and Power Train
336350
2
0
Parts Manufacturing
Industrial
Motor Vehicle Seating and Interior Trim
336360
1
0
Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1
0
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
3
Industrial
All Other Motor Vehicle Parts
336399
2
0
ManufacturingA
(continued)
A-16
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Aircraft Manufacturing
336411
125
89
Industrial
Aircraft Engine and Engine Parts
336412
8
2
Manufacturing
Industrial
Other Aircraft Parts and Auxiliary Equipment
336413
10
3
Manufacturing
Industrial
Guided Missile and Space Vehicle Propulsion
336415
1
0
Unit and Propulsion Unit Parts Manufacturing
Industrial
Railroad Rolling Stock Manufacturing
336510
1
0
Industrial
Ship Building and Repairing
336611
92
18
Industrial
Boat Building
336612
96
16
Industrial
Military Armored Vehicle, Tank, and Tank
336992
2
0
Component Manufacturing
Industrial
Wood Kitchen Cabinet and Countertop
337110
347
209
Manufacturing
Industrial
Upholstered Household Furniture
337121
2
2
Manufacturing
Industrial
Nonupholstered Wood Household Furniture
337122
14
8
Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
1
1
Industrial
Wood Office Furniture Manufacturing
337211
5
4
Industrial
Office Furniture (except Wood)
337214
19
11
Manufacturing
Industrial
Showcase, Partition, Shelving, and Locker
337215
1
1
Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
Industrial
Surgical and Medical Instrument
339112
2
0
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
1
0
Manufacturing
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
Industrial
Office Supplies (except Paper) Manufacturing
339940
1
0
Industrial
Gasket, Packing, and Sealing Device
339991
2
0
Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
Commercial
Petroleum Bulk Stations and Terminals
424710
7
2
Commercial
Scheduled Passenger Air Transportation
481111
2
0
Commercial
Line-Haul Railroads
482111
1
0
Energy
Pipeline Transportation of Crude Oil
486110
1
0
Energy
Pipeline Transportation of Natural Gas
486210
257
84
Energy
Pipeline Transportation of Refined Petroleum
486910
1
0
Products
(continued)
A-17
-------
Table A-2. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 1 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
numDer oi
Facilities That
May Potentially
Experience
Regulatory
Relief
Commercial
Support Activities for Rail Transportation
488210
3
1
Commercial
Marine Cargo Handling
488320
2
0
Commercial
General Warehousing and Storage
493110
180
53
Commercial
Other Warehousing and Storage
493190
6
2
Commercial
Lessors of Nonresidential Buildings (except
531120
1
0
Miniwarehouses)
Commercial
Testing Laboratories
541380
2
0
Commercial
Research and Development in the Physical,
541715
2
0
Engineering and Life Sciences (except
Nanotechnology and Biotechnology)AA
Commercial
All Other Support Services
561990
1
0
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
18
Waste Treatment
Solid Waste Landfill
562212
6
2
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
1
Waste Treatment
Remediation Services
562910
1
0
Educational Services
Colleges, Universities, and Professional
611310
23
8
Schools
Commercial
Amusement and Theme Parks
713110
1
0
Commercial
Linen and Uniform Supply
812330
1
0
Commercial
Industrial Launderers
812332
3
1
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. MM2A Database Memorandum,
Documentation of the Data for Analytical Evaluations & Summary of Industries Potentially Impacted by the Final
Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum
for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. MM2A Cost Analysis Memorandum,
Documentation of the compliance cost savings analysis for the final rulemaking "Reclassification of Major
Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
A-18
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2
Facilities
Number of
Facilities That
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
May Potentially
Experience
Regulatory
Relief
Agriculture
Postharvest Crop Activities (except Cotton
115114
1
0
Ginning)
Energy
Crude Petroleum and Natural Gas Extraction
211111
120
57
Energy
Natural Gas Liquid Extraction
211112
26
12
Industrial
Iron Ore Mining
212210
11
0
Industrial
Lead Ore and Zinc Ore Mining
212231
1
0
Industrial
Copper Ore and Nickel Ore Mining
212234
1
0
Industrial
All Other Metal Ore Mining
212299
1
0
Industrial
Industrial Sand Mining
212322
3
0
Industrial
Kaolin and Ball Clay Mining
212324
3
0
Industrial
Potash, Soda, and Borate Mineral Mining
212391
6
0
Industrial
All Other Nonmetallic Mineral Mining
212399
1
0
Energy
Support Activities for Oil and Gas
213112
3
1
Operations
Utilities
Hydroelectric Power Generation
221111
1
1
Utilities
Fossil Fuel Electric Power Generation
221112
334
100
Utilities
Biomass Electric Power Generation
221117
5
4
Utilities
Other Electric Power Generation
221118
1
1
Utilities
Other Electric Power GenerationA
221119
8
6
Utilities
Electric Power Distribution
221122
1
1
Utilities
Natural Gas Distribution
221210
13
9
Utilities
Water Supply and Irrigation Systems
221310
2
2
Utilities
Sewage Treatment Facilities
221320
17
12
Utilities
Steam and Air-Conditioning Supply
221330
22
15
Industrial
Other Animal Food Manufacturing
311119
1
0
Industrial
Wet Corn Milling
311221
16
0
Industrial
Soybean ProcessingA
311222
16
0
Industrial
Other Oilseed ProcessingA
311223
5
0
Industrial
Soybean and Other Oilseed Processing
311224
116
2
Industrial
Fats and Oils Refining and Blending
311225
2
0
Industrial
Beet Sugar Manufacturing
311313
11
0
Industrial
Cane Sugar Manufacturing
311314
3
0
Industrial
Frozen Fruit, Juice, and Vegetable
311411
2
0
Manufacturing
Industrial
Fruit and Vegetable Canning
311421
1
0
Industrial
Specialty Canning
311422
2
0
Industrial
Cheese Manufacturing
311513
2
0
Industrial
Dry, Condensed, and Evaporated Dairy
311514
3
0
Product Manufacturing
Industrial
Rendering and Meat Byproduct Processing
311613
1
0
Industrial
Commercial Bakeries
311812
2
0
(continued)
A-19
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Other Snack Food Manufacturing
311919
1
0
Industrial
Coffee and Tea Manufacturing
311920
1
0
Industrial
Flavoring Syrup and Concentrate
311930
1
0
Manufacturing
Industrial
Spice and Extract Manufacturing
311942
4
0
Industrial
All Other Miscellaneous Food
311999
6
0
Manufacturing
Industrial
Breweries
312120
3
1
Industrial
Distilleries
312140
1
0
Industrial
Tobacco Manufacturing
312230
1
0
Industrial
Yarn Spinning MillsA
313111
1
1
Industrial
Thread MillsA
313113
1
1
Industrial
Broadwoven Fabric Mills
313210
2
2
Industrial
Narrow Fabric MillsA
313221
1
1
Industrial
Textile and Fabric Finishing Mills
313310
1
1
Industrial
Broadwoven Fabric Finishing MillsA
313311
3
2
Industrial
Fabric Coating Mills
313320
50
32
Industrial
Tire Cord and Tire Fabric MillsA
314992
1
0
Industrial
Leather and Hide Tanning and Finishing
316110
6
5
Industrial
Sawmills
321113
61
25
Industrial
Wood Preservation
321114
3
1
Industrial
Hardwood Veneer and Plywood
321211
3
1
Manufacturing
Industrial
Softwood Veneer and Plywood
321212
29
11
Manufacturing
Industrial
Engineered Wood Member (except Truss)
321213
6
2
Manufacturing
Industrial
Reconstituted Wood Product Manufacturing
321219
315
126
Industrial
Wood Window and Door Manufacturing
321911
4
1
Industrial
Cut Stock, Resawing Lumber, and Planing
321912
4
1
Industrial
All Other Miscellaneous Wood Product
321999
3
1
Manufacturing
Industrial
Pulp Mills
322110
18
3
Industrial
Paper (except Newsprint) Mills
322121
282
14
Industrial
Newsprint Mills
322122
7
1
Industrial
Paperboard Mills
322130
36
9
Industrial
Corrugated and Solid Fiber Box
322211
174
68
Manufacturing
Industrial
Paper Bag and Coated and Treated Paper
322220
17
3
Manufacturing
Industrial
Coated and Laminated Paper
322222
12
2
ManufacturingA
Industrial
Sanitary Paper Product Manufacturing
322291
2
0
(continued)
A-20
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
All Other Converted Paper Product
322299
1
0
Manufacturing
Industrial
Commercial Lithographic PrintingA
323110
1
1
Industrial
Commercial Printing (except Screen and
323111
188
121
Books)
Industrial
Books Printing
323117
3
2
Industrial
Petroleum Refineries
324110
430
88
Industrial
Asphalt Shingle and Coating Materials
324122
3
0
Manufacturing
Industrial
All Other Petroleum and Coal Products
324199
4
0
Manufacturing
Industrial
Petrochemical Manufacturing
325110
597
260
Industrial
Industrial Gas Manufacturing
325120
4
1
Industrial
Synthetic Dye and Pigment Manufacturing
325130
1
0
Industrial
Inorganic Dye and Pigment ManufacturingA
325131
3
1
Industrial
Synthetic Organic Dye and Pigment
325132
2
0
ManufacturingA
Industrial
Other Basic Inorganic Chemical
325180
10
3
Manufacturing
Industrial
Alkalies and Chlorine ManufacturingA
325181
4
1
Industrial
Carbon Black ManufacturingA
325182
21
8
Industrial
All Other Basic Inorganic Chemical
325188
93
5
ManufacturingA
Industrial
Cyclic Crude and Intermediate
325192
1
0
ManufacturingA
Industrial
Ethyl Alcohol Manufacturing
325193
7
3
Industrial
Cyclic Crude, Intermediate, and Gum and
325194
2
0
Wood Chemical Manufacturing
Industrial
All Other Basic Organic Chemical
325199
77
28
Manufacturing
Industrial
Plastics Material and Resin Manufacturing
325211
857
341
Industrial
Synthetic Rubber Manufacturing
325212
22
2
Industrial
Artificial and Synthetic Fibers and Filaments
325220
6
2
Manufacturing
Industrial
Cellulosic Organic Fiber ManufacturingA
325221
1
0
Industrial
Noncellulosic Organic Fiber ManufacturingA
325222
4
1
Industrial
Nitrogenous Fertilizer Manufacturing
325311
16
6
Industrial
Phosphatic Fertilizer Manufacturing
325312
30
3
Industrial
Pesticide and Other Agricultural Chemical
325320
22
6
Manufacturing
Industrial
Medicinal and Botanical Manufacturing
325411
4
1
Industrial
Pharmaceutical Preparation Manufacturing
325412
36
11
Industrial
Biological Product (except Diagnostic)
325414
1
0
Manufacturing
(continued)
A-21
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector
NAICS Descriptions
NAICS
MACT
Relief
Industrial
Paint and Coating Manufacturing
325510
48
26
Industrial
Adhesive Manufacturing
325520
4
1
Industrial
Surface Active Agent Manufacturing
325613
2
0
Industrial
Toilet Preparation Manufacturing
325620
2
0
Industrial
Explosives Manufacturing
325920
2
0
Industrial
Custom Compounding of Purchased Resins
325991
5
2
Industrial
Photographic Film, Paper, Plate, and
325992
4
1
Chemical Manufacturing
Industrial
All Other Miscellaneous Chemical Product
325998
10
3
and Preparation Manufacturing
Industrial
Plastics Packaging Film and Sheet (including
326112
5
4
Laminated) Manufacturing
Industrial
Unlaminated Plastics Film and Sheet (except
326113
16
8
Packaging) Manufacturing
Industrial
Unlaminated Plastics Profile Shape
326121
12
1
Manufacturing
Industrial
Plastics Pipe and Pipe Fitting Manufacturing
326122
1
1
Industrial
Laminated Plastics Plate, Sheet (except
326130
7
4
Packaging), and Shape Manufacturing
Industrial
Polystyrene Foam Product Manufacturing
326140
1
1
Industrial
Urethane and Other Foam Product (except
326150
19
16
Polystyrene) Manufacturing
Industrial
Plastics Plumbing Fixture Manufacturing
326191
2
2
Industrial
All Other Plastics Product Manufacturing
326199
148
81
Industrial
Tire Manufacturing (except Retreading)
326211
39
23
Industrial
Rubber and Plastics Hoses and Belting
326220
6
4
Manufacturing
Industrial
Rubber Product Manufacturing for
326291
2
2
Mechanical Use
Industrial
All Other Rubber Product Manufacturing
326299
14
6
Industrial
Pottery, Ceramics, and Plumbing Fixture
327110
4
3
Manufacturing
Industrial
Clay Building Material and Refractories
327120
76
57
Manufacturing
Industrial
Clay Refractory ManufacturingA
327124
8
4
Industrial
Flat Glass Manufacturing
327211
2
2
Industrial
Other Pressed and Blown Glass and
327212
17
11
Glassware Manufacturing
Industrial
Cement Manufacturing
327310
6
4
Industrial
Lime Manufacturing
327410
38
2
Industrial
Gypsum Product Manufacturing
327420
1
1
Industrial
Abrasive Product Manufacturing
327910
4
2
Industrial
Mineral Wool Manufacturing
327993
13
6
(continued)
A-22
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector NAICS Descriptions NAICS MACT Relief
Industrial
All Other Miscellaneous Nonmetallic
327999
2
2
Mineral Product Manufacturing
Industrial
Iron and Steel Mills and Ferroalloy
331110
73
44
Manufacturing
Industrial
Iron and Steel MillsA
331111
50
3
Industrial
Electrometallurgical Ferroalloy Product
331112
1
0
ManufacturingA
Industrial
Iron and Steel Pipe and Tube Manufacturing
331210
5
2
from Purchased Steel
Industrial
Rolled Steel Shape Manufacturing
331221
6
2
Industrial
Primary Aluminum ProductionA
331312
2
0
Industrial
Alumina Refining and Primary Aluminum
331313
16
2
Production
Industrial
Secondary Smelting and Alloying of
331314
56
8
Aluminum
Industrial
Aluminum Sheet, Plate, and Foil
331315
6
2
Manufacturing
Industrial
Aluminum Extruded Product
331316
1
0
ManufacturingA
Industrial
Other Aluminum Rolling, Drawing, and
331318
2
0
Extruding
Industrial
Nonferrous Metal (except Aluminum)
331410
1
0
Smelting and Refining
Industrial
Primary Smelting and Refining of CopperA
331411
0
0
Industrial
Primary Smelting and Refining of
331419
2
0
Nonferrous Metal (except Copper and
Aluminum)A
Industrial
Copper Rolling, Drawing, Extruding, and
331420
3
0
Alloying
Industrial
Copper Wire (except Mechanical) DrawingA
331422
1
0
Industrial
Nonferrous Metal (except Copper and
331491
3
1
Aluminum) Rolling, Drawing, and Extruding
Industrial
Secondary Smelting, Refining, and Alloying
331492
2
0
of Nonferrous Metal (except Copper and
Aluminum)
Industrial
Iron Foundries
331511
59
4
Industrial
Steel Foundries (except Investment)
331513
2
0
Industrial
Aluminum Die-Casting Foundries'"*
331521
1
0
Industrial
Aluminum Foundries (except Die-Casting)
331524
2
0
Industrial
Nonferrous Forging
332112
1
1
Industrial
Metal Crown, Closure, and Other Metal
332119
1
1
Stamping (except Automotive)
(continued)
A-23
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Number of
Facilities That
Number of May Potentially
Facilities Experience
Subject to Regulatory
Sector NAICS Descriptions NAICS MACT Relief
Industrial
Hand and Edge Tool ManufacturingA
332212
1
1
Industrial
Prefabricated Metal Building and
332311
1
1
Component Manufacturing
Industrial
Fabricated Structural Metal Manufacturing
332312
1
1
Industrial
Metal Window and Door Manufacturing
332321
Industrial
Sheet Metal Work Manufacturing
332322
1
1
Industrial
Metal Can Manufacturing
332431
14
11
Industrial
Other Metal Container Manufacturing
332439
Industrial
Bolt, Nut, Screw, Rivet, and Washer
332722
1
1
Manufacturing
Industrial
Metal Heat Treating
332811
1
1
Industrial
Metal Coating, Engraving (except Jewelry
332812
433
332
and Silverware), and Allied Services to
Manufacturers
Industrial
Electroplating, Plating, Polishing,
332813
3
3
Anodizing, and Coloring
Industrial
Other Fabricated Metal Manufacturing
332990
1
1
Industrial
Small Arms Ammunition Manufacturing
332992
1
1
Industrial
Ammunition (except Small Arms)
332993
3
3
Manufacturing
Industrial
All Other Miscellaneous Fabricated Metal
332999
3
3
Product Manufacturing
Industrial
Farm Machinery and Equipment
333111
8
3
Manufacturing
Industrial
Lawn and Garden Tractor and Home Lawn
333112
1
0
and Garden Equipment Manufacturing
Industrial
Construction Machinery Manufacturing
333120
64
30
Industrial
Mining Machinery and Equipment
333131
2
0
Manufacturing
Industrial
Printing Machinery and Equipment
333293
1
0
ManufacturingA
Industrial
Photographic and Photocopying Equipment
333316
1
0
Manufacturing
Industrial
Air-Conditioning and Warm Air Heating
333415
1
0
Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
Industrial
Machine Tool (Metal Cutting Types)
333512
1
0
ManufacturingA
Industrial
Machine Tool (Metal Forming Types)
333513
1
0
ManufacturingA
Industrial
Turbine and Turbine Generator Set Units
333611
1
0
Manufacturing
Industrial
Other Engine Equipment Manufacturing
333618
5
2
(continued)
A-24
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number ot
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
Electron Tube ManufacturingA
334411
1
0
Industrial
Bare Printed Circuit Board Manufacturing
334412
1
0
Industrial
Semiconductor and Related Device
334413
23
15
Manufacturing
Industrial
Automatic Environmental Control
334512
1
0
Manufacturing for Residential, Commercial,
and Appliance Use
Industrial
Blank Magnetic and Optical Recording
334613
0
0
Media Manufacturing
Industrial
Electric Lamp Bulb and Part Manufacturing
335110
1
1
Industrial
Household Laundry Equipment
335224
13
9
Manufacturing
Industrial
Other Major Household Appliance
335228
2
2
Manufacturing
Industrial
Power, Distribution, and Specialty
335311
1
1
Transformer Manufacturing
Industrial
Motor and Generator Manufacturing
335312
2
2
Industrial
Storage Battery Manufacturing
335911
1
1
Industrial
Current-Carrying Wiring Device
335931
1
1
Manufacturing
Industrial
Noncurrent-Carrying Wiring Device
335932
1
1
Manufacturing
Industrial
Carbon and Graphite Product Manufacturing
335991
6
4
Industrial
Automobile Manufacturing
336111
66
28
Industrial
Light Truck and Utility Vehicle
336112
5
4
Manufacturing
Industrial
Heavy Duty Truck Manufacturing
336120
8
5
Industrial
Motor Vehicle Body Manufacturing
336211
8
5
Industrial
Truck Trailer Manufacturing
336212
1
1
Industrial
Motor Vehicle Gasoline Engine and Engine
336310
2
2
Parts Manufacturing
Industrial
Carburetor, Piston, Piston Ring, and Valve
336311
1
1
ManufacturingA
Industrial
Gasoline Engine and Engine Parts
336312
3
2
ManufacturingA
Industrial
Motor Vehicle Steering and Suspension
336330
2
2
Components (except Spring) Manufacturing
Industrial
Motor Vehicle Brake System Manufacturing
336340
1
1
Industrial
Motor Vehicle Transmission and Power
336350
2
2
Train Parts Manufacturing
Industrial
Motor Vehicle Seating and Interior Trim
336360
1
1
Manufacturing
Industrial
Motor Vehicle Metal Stamping
336370
1
1
Industrial
Other Motor Vehicle Parts Manufacturing
336390
13
7
(continued)
A-25
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number ot
Facilities That
May Potentially
Experience
Regulatory
Relief
Industrial
All Other Motor Vehicle Parts
336399
2
2
ManufacturingA
Industrial
Aircraft Manufacturing
336411
125
107
Industrial
Aircraft Engine and Engine Parts
336412
8
5
Manufacturing
Industrial
Other Aircraft Parts and Auxiliary
336413
10
6
Equipment Manufacturing
Industrial
Guided Missile and Space Vehicle
336415
1
1
Propulsion Unit and Propulsion Unit Parts
Manufacturing
Industrial
Railroad Rolling Stock Manufacturing
336510
1
1
Industrial
Ship Building and Repairing
336611
92
67
Industrial
Boat Building
336612
96
35
Industrial
Military Armored Vehicle, Tank, and Tank
336992
2
2
Component Manufacturing
Industrial
Wood Kitchen Cabinet and Countertop
337110
347
263
Manufacturing
Industrial
Upholstered Household Furniture
337121
2
2
Manufacturing
Industrial
Nonupholstered Wood Household Furniture
337122
14
11
Manufacturing
Industrial
Institutional Furniture Manufacturing
337127
1
1
Industrial
Wood Office Furniture Manufacturing
337211
5
5
Industrial
Office Furniture (except Wood)
337214
19
17
Manufacturing
Industrial
Showcase, Partition, Shelving, and Locker
337215
1
1
Manufacturing
Industrial
Blind and Shade Manufacturing
337920
1
1
Industrial
Surgical and Medical Instrument
339112
2
0
Manufacturing
Industrial
Surgical Appliance and Supplies
339113
1
0
Manufacturing
Industrial
Jewelry and Silverware Manufacturing
339910
1
0
Industrial
Sporting and Athletic Goods Manufacturing
339920
1
0
Industrial
Office Supplies (except Paper)
339940
1
0
Manufacturing
Industrial
Gasket, Packing, and Sealing Device
339991
2
0
Manufacturing
Industrial
Burial Casket Manufacturing
339995
3
1
Industrial
All Other Miscellaneous Manufacturing
339999
5
2
Commercial
Grain and Field Bean Merchant Wholesalers
424510
1
0
Commercial
Petroleum Bulk Stations and Terminals
424710
7
3
Commercial
Scheduled Passenger Air Transportation
481111
2
0
Commercial
Line-Haul Railroads
482111
1
0
(continued)
A-26
-------
Table A-3. Sources That May Potentially Experience Regulatory Relief under
ALTERNATIVE SCENARIO 2 (continued)
Facilities
Sector
NAICS Descriptions
NAICS
Number of
Facilities
Subject to
MACT
Number of
Facilities That
May Potentially
Experience
Regulatory
Relief
Energy
Pipeline Transportation of Crude Oil
486110
1
0
Energy
Pipeline Transportation of Natural Gas
486210
257
123
Energy
Pipeline Transportation of Refined
486910
1
0
Petroleum Products
Commercial
Support Activities for Rail Transportation
488210
3
1
Commercial
Marine Cargo Handling
488320
2
0
Commercial
General Warehousing and Storage
493110
180
65
Commercial
Other Warehousing and Storage
493190
6
2
Commercial
Lessors of Nonresidential Buildings (except
531120
1
0
Miniwarehouses)
Commercial
Testing Laboratories
541380
2
0
Commercial
Research and Development in the Physical,
541715
2
0
Engineering and Life Sciences (except
Nanotechnology and Biotechnology)AA
Commercial
All Other Support Services
561990
1
0
Waste Treatment
Hazardous Waste Treatment and Disposal
562211
41
27
Waste Treatment
Solid Waste Landfill
562212
6
4
Waste Treatment
Solid Waste Combustors and Incinerators
562213
3
2
Waste Treatment
Remediation Services
562910
1
1
Educational Services
Colleges, Universities, and Professional
611310
23
11
Schools
Commercial
Amusement and Theme Parks
713110
1
0
Commercial
Linen and Uniform Supply
812330
1
0
Commercial
Industrial Launderers
812332
3
1
Sources: 2012 Economic Census; Eastern Research Group. August 2020a. MM2A Database Memorandum,
Documentation of the Data for Analytical Evaluations & Summary of Industries Potentially Impacted by the Final
Rule "Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum
for U.S. EPA/OAQPS/SPPD; Eastern Research Group. August 2020b. MM2A Cost Analysis Memorandum,
Documentation of the compliance cost savings analysis for the final rulemaking "Reclassification of Major
Sources as Area Sources Under Section 112 of the Clean Air Act". Memorandum for U.S. EPA/OAQPS/SPPD.
A-27
-------
A-28
-------
ATTACHMENT B
SUMMARY OF METHODOLOGY AND DATA USED TO REVIEW
RECLASSIFICATIONS
As described in the Emission Impact Analysis Technical Support Memorandum, the EPA
and ERG reviewed the reclassification of 69 sources that as of May 2020 had reclassified to area
source status or were in the process of reclassifying to area source status since the release of the
Wehrum memorandum in January 2018. Below we summarize the analysis of reclassifications.
This analysis is purely illustrative in nature and does not serve as an analysis of emissions
impacts for all source categories affected by the final rule.
At proposal, to assess the potential environmental impact associated with the
reclassification of sources, the EPA evaluated information from 34 sources that had reclassified
to area source status consistent with the EPA's plain language reading of the CAA section 112
definitions of "major" and "area" source since January 2018. The review of these
reclassifications provided a representation of the potential real-world impact on emissions by
looking at the facts and circumstances of actual reclassification actions. In addition to the
evaluation of the reclassification actions, at proposal the EPA also performed an illustrative
assessment for six source categories: Wood Furniture Manufacturing Operations, Surface
Coating of Metal Cans, Surface Coating of Miscellaneous Metal Parts and Products, Wet-
Formed Fiberglass Mat Production, Hydrochloric Acid (HC1) Production, and Non-Gasoline
Organic Liquids Distribution (OLD). The analysis of these six source categories was informative
in some respects but is only illustrative and speculative in nature and can only present a range of
possible outcomes that is dependent on the assumptions that we made in the assessment. The
EPA received numerous comments on the emission analyses presented at proposal. Many
commenters argued that the EPA had failed to adequately assess the effects of the rule on HAP
emissions and did not perform any health impact analysis. These commenters argued the EPA
did not include enough source categories in the emission analysis at proposal to draw reasonable
conclusions. Commenters also opined that the analysis of the actual reclassifications relies on a
small sample, and a few speculated that we had "cherry picked" permits to review.
For the final rule, the EPA expanded the review of reclassification actions to include the
review of 35 additional reclassifications received from March 2019 through February 2020. This
allowed us to more than double the number of reclassifications reviewed for the final rule. The
details and results of the analysis of 769 reclassification actions are summarized below and are
presented in extensive detail in the review of reclassifications technical support memorandum for
B-l
-------
the final rule, which is available in the docket for this action.59 The EPA received comments on
the permit review completed for the proposal; we have considered the input from commenters in
the review of the reclassifications included in the final analysis.
To assess the potential for emission impacts due to reclassification, the EPA focused the
review on the enforceable conditions associated with the PTE limitations for the emission units
previously subject to major source NESHAP requirements. The EPA review focused on whether
the emission units previously subject to major source NESHAP requirements continue to have
enforceable conditions that are either the same as or consistent with the previous applicable
major source NESHAP compliance obligations. Summaries of the permit reviews and emissions
evaluations are presented in the Review of Reclassification Actions TSM available in the docket
for this action.
The use of add-on control equipment is one of the compliance options sources can use to
comply with major source NESHAP requirements. In general, sources that comply using add-on
controls demonstrate compliance by meeting certain operating limits/parameters established
during performance tests. For sources relying on emission control equipment, EPA focused the
review on those sources that used "adjustable" emission control equipment as the compliance
method for previously applicable major source NESHAP requirements. Adjustable controls are
those for which important operating parameters (e.g., combustion temperature) can be potentially
adjusted, which could lead to a change in the HAP emission control level. For our analysis, we
viewed particulate controls for inorganic HAP (e.g., fabric filters, electrostatic precipitators) as
non-adjustable, but controls for organic HAP or acid gases (e.g., regenerative thermal oxidizers
[RTOs], caustic scrubbers, wet scrubbers) as controls that could be adjustable.
For sources employing adjustable emission controls, the EPA reviewed the permit
enforceable limitations associated with using the emission control, including operating
parameters.
If the permit conditions reflect the use of the same control equipment and operating
parameters as when the source was subject to major source NESHAP requirements, the EPA
assumed no potential for emissions increases due to the reclassification. If permit conditions
reflect the use of the same control equipment but a change in operating parameters (e.g., change
in monitoring device, change in monitoring frequency), the EPA assessed whether the change in
59 See Technical Support Memorandum (TSM): Review of Reclassification Actions for the Final Rulemaking
"Reclassification of Major Sources as Area Sources under Section 112 of the Clean Air Act" available in the
docket of this rulemaking. August 2020.
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operating parameters could lead to a change in HAP emission control level and an increase of
HAP emissions. The use of work practices is another form of compliance that is used for some
major source NESHAP requirements. For sources employing work practices, the EPA focused
on whether the work practice requirements previously applicable to the source changed when the
source reclassified. If the permit conditions reflect the same work practice requirements, the EPA
assumed no potential for emissions increases due to the reclassification. If the permit conditions
reflect a change in the work practice requirements, the EPA assessed whether the change could
lead to a change in the HAP emission control level and an increase of HAP emissions.
When reclassifying, a source can opt to operate with new operational limitations, which
are incorporated into their operating permit, to avoid applicability to major source NESHAP
requirements. For these types of reclassifications, the EPA assessed whether these new
operational restrictions will lead to additional emission reductions.
Many sources have made permanent process changes and have reclassified as true area
sources (HAP PTE is below the MST and source does not rely on any physical or operational
limits, including the use of pollution control equipment to constrain their emissions). The EPA
determined that the reclassification of such sources will not lead to emissions increases.
Based on the analysis described above, the EPA's findings from the review of
reclassification actions and emission evaluation are that sources that had reclassified to area
source status, in most cases, achieved and maintain area source status by operating the emission
controls or continuing to implement the practices they used to comply with the major source
NESHAP requirements, and we expect no emission increases due to reclassification for these
sources. While some permitting authorities could allow for changes in the enforceable conditions
or practices the sources used to comply with major source NESHAP requirements, this happened
for only one source or 1.4 percent of the actual reclassifications. Below is an overview of the
EPA's findings from the permit review and evaluation for 69 reclassifications.
Of the 69 sources that have reclassified, 46 sources are of a coating type source category,
11 are chemical sources, six are fuel combustion/boiler sources, five are oil and gas sources, and
two are heavy industry. (See Tables 3 and 4 of the Review of Reclassification Actions TSM
available in the docket for this action.) Of the 69 reclassifications reviewed, 14 sources are now
classified as true area sources because these sources are no longer physically or operationally
able to emit HAP above the MST. Of the 56 sources with enforceable PTE limitations, 18
sources had obtained enforceable PTE limitations before January 2018 (existing PTE
limitations), while 38 obtained the PTE limitations after January 2018 (i.e., new PTE
B-3
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limitations). A majority of these 69 sources are in coatings source categories. For these sources,
the use of compliant materials is one of the compliance options sources use to comply with many
major source NESHAP requirements. This compliance method is more prevalent for coating
source NESHAP categories. In general, sources comply by applying materials that meet the
emission limits, either individually or collectively, during each compliance period. Sources
demonstrate compliance by showing that the organic HAP content of each
coating/thinner/additive/resin used is less than or equal to the applicable limitation.
A discussion with the EPA's coatings source experts indicated that a source that
reclassifies to area source status after being in compliance with major source NESHAP
requirements through the use of compliant materials is highly unlikely to change their
formulations from a low- or no-HAP content to a higher HAP content (e.g., switching from
powder coatings back to liquid coatings). This change is unlikely because a change to higher
HAP content formulation could also lead to an increase in VOC emissions, to applicability of
VOC and OSHA regulations, and to an increase in costs associated with the disposal of the
hazardous waste. In addition, many facilities have made substantive process changes to
incorporate the use of the low-HAP/no-HAP coatings. These facilities would incur substantial
costs to change their operations to use higher HAP coatings.
Thus, the EPA does not expect that sources that have employed the use of pollution
prevention measures {i.e., low-HAP/no-HAP coatings or no-HAP coatings/resins) as their
compliance method to meet previous applicable major source NESHAP requirements and have
reformulated their products accordingly will change their formulations and products as a result of
a change in status.
For these types of sources, if permits reflect the use of compliant materials (i.e., low-HAP
or no-HAP coatings/resins) as the method of compliance with the PTE limitations, the EPA
assumed no potential for emissions increases due directly to the reclassification. However, if the
post-reclassification permit reflected a change in the use of compliant materials, the EPA
analyzed whether such change could lead to emission increases that otherwise would have not
happened if the source continued to be subject to major source NESHAP requirements.
Of the 45 coating sources, 32 used compliant materials (low-HAP/no-HAP) to meet
applicable major source requirements before reclassification, and their continued use of
compliant materials is an enforceable condition after reclassification. Seven other coating
sources relied exclusively on compliant materials before reclassifying, while after reclassifying
they relied on both compliant materials and a change in operations and/or production limits to
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maintain compliance. Four sources used a combination of compliant materials and control
technology (RTOs or total enclosures) to meet applicable major source requirements and
maintain enforceable conditions requiring the operation of the RTOs after reclassification. One
source used an RTO and work practice standards to meet applicable major source requirements
and maintain compliance before and after reclassifying without also relying on compliant
materials. As described in detail in the TSM, the EPA does not expect emission increases from
these sources due to reclassification to area source status. Finally, one source used compliant
materials to meet applicable major source requirements but after reclassification requested a
change to use a HAP-containing formulation with accompanying process limitations to maintain
area source status. Had the change in formulation happened while the source was a major source,
the source would have had to comply with the applicable NESHAP using an add-on control
device. For this source, the change in formulation after reclassification could lead to emission
increases of 4.3 tpy of xylene or 18.75 tpy of combined HAP.
Of the 11 chemical sources reviewed, four sources are miscellaneous organic chemical
manufacturing facilities; these relied on a variety of control technologies (including RTOs,
scrubbers, and flares) and work practices to maintain compliance before reclassifying and
continue to have enforceable conditions requiring the control technologies after reclassification.
Three sources are gasoline distribution sources that relied on vapor collection and vapor
flare/vapor combustion to meet applicable major source requirements before reclassification, and
these controls are enforceable conditions to maintain compliance after reclassification. Three
sources are off-site waste recovery facilities that relied on control technologies such as vapor
balance/recovery systems, condensers, and scrubbers to meet applicable major source
requirements before reclassification. All these sources continue to rely on the same (or
additional) requirements as enforceable conditions to maintain compliance after reclassification.
Finally, one source is a former hazardous waste combustor and cement facility that until 2015
fueled its cement kiln using collected hazardous and non-hazardous waste, using various control
technologies to maintain compliance. This facility permanently removed all equipment
associated with Portland cement manufacturing and took on a new primary role as a hazardous
waste storage/transfer facility, using throughput limits and a carbon adsorption system to
maintain compliance.
Of the six combustion/boiler sources reviewed, four made permanent operational changes
(ceased combustion of coal and/or ceased operation of boilers), allowing the sources to reclassify
to area source status. Another source had material and operational limitations prior to
reclassification, both of which continue to be enforceable conditions after reclassification, and
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one source took additional operational restrictions on the usage of natural gas as the mechanism
to constrain their emissions and PTE and reclassify to area source status. Three sources of these
sources had emissions above MST before reclassifying; the reclassification of these three sources
resulted in a HAP reduction of 56.9 tpy single HAP and 78.8 tpy total HAP.
All five oil and gas production and transmission sources reviewed relied on the use of
control technologies (oxidation catalyst [enclosed combustion device] and flares) to meet
applicable major source requirements before reclassification, and their continued use is an
enforceable condition to maintain compliance after reclassification. One of these sources took
additional restrictions on the amount of gas vented to the atmosphere to reclassify to area source
status. Also, the reclassification of this facility prevented additional emissions that would have
occurred if the source had remained a major source. As described in detail in the Review of
Reclassifications Actions TSM, the EPA does not expect emission increases from these sources
due to reclassification to area source status.
Of the two heavy industry sources reviewed, one is a lime manufacturing plant and the
other is a flexible polyurethane foam fabrication facility. The lime manufacturing facility, after
reclassification, remains subject to other regulatory requirements, including PM emission
limitations, the use of a baghouse, and monitored opacity as an operating limit via operation of a
continuous opacity monitoring system. The flexible polyurethane foam fabrication facility relied
on compliant materials, control technology (carbon adsorption systems), work practices, and
operational limitations to meet applicable major source standards before reclassification and
continues to rely on these as enforceable conditions to maintain compliance after reclassification.
See the Review of Reclassification Actions TSM available in the docket for the detailed permit
reviews and emission evaluations.
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ATTACHMENT C
ESTIMATES USED FOR CALCULATING POTENTIAL
CONTROL COSTS FOR THE ILLUSTRATIVE
125 PERCENT SCENARIO COST ANALYSIS
C.l Organic Liquid Distribution (OLD) Annual Cost Analysis Details
The capital costs were annualized at an interest rate of 5 percent, which was within the
range of rates that represent the bank prime rate as of October 2019. The equipment life for
control measures, practices, and technologies included in the compliance cost analysis ranges
from 4 to 15 years. Half of the annualized costs including product recovery are due to the
requirement on transfer racks (i.e., 240-hour exemption removal), while the other half are due to
requirements on storage tanks and flares.
The operation and maintenance (O&M) costs for storage tanks include labor costs for
installing controls to reduce volume applicability thresholds and degassing during startup,
shutdown, and maintenance (SSM); the capital costs include those for materials needed as part of
controls for storage tanks. For flares, the O&M costs include labor needed for operation of flare
monitoring; the capital costs are those for purchase of necessary monitors. For transfer racks, the
O&M costs are those for operation of combustion controls, while control devices are undergoing
maintenance (i.e., elimination of exception from control during maintenance). There are no
capital costs associated with the operation of these combustion controls. These costs are
summarized in Table C-l.
Table C-l. Nationwide Cost Impacts of Final OLD Amendments (2016$)
Million $/yr
Total Annualized
Total Annualized
Total Annualized
Cost without
Cost with
Affected
Total Capital
Operation &
Product
Product
Product
Source
Cost (million $)
Maintenance
Recovery3
Recovery Credit
Recovery
Tanks
2.28
0.42
0.71
0.17
0.54
Flares
0.19
0.34
0.36
-
0.36
Transfer
0.0
0.89
0.89
-
0.89
Racks
Total3
2.47
1.64
1.95
0.17
1.78
a The total annualized costs are expected to be incurred starting in 2020 and continuing over the life of the capital
equipment and practices included in the cost analysis (varying from 4 to 15 years). Totals may not sum due to
rounding conventions.
C.2 Wood Furniture Annual Cost Details
The annual costs used in the potential cost impacts in the illustrative 125 percent analysis
are those for a switch to a low formaldehyde coating system. The costs below are taken from the
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cost memo for the Wood Furniture RTR proposed in 2010. The costs estimates are based on a
number of analyses done by different regulatory agencies.
C.2.1 Bay Area Air Quality Management District (BAAQMD)
On July 29, 2010, the BAAQMD met to review Regulation 8, Rule 32: Wood Products
Coatings, which regulates VOC emissions from the wood products manufacturing industry by
setting standards for application techniques and the amount of VOCs in coatings that can be used
in surface preparation, coatings application, and cleanup for the manufacture of wood products,
including furniture, bathroom vanities, kitchen cabinets, picture frames, outdoor speakers,
architectural mill work, and other wood products.
The proposed amendments to Rule 8-32 reduce VOC limits for some types of coatings
used on the three types of wood products subject to VOC limitations in the rule: general wood
products; wood furniture, custom cabinetry and custom architectural millwork; and custom
furniture. The lower VOC limits became effective July 1, 2010, and provided for alternative
standards for each type of high-solids coating based on grams VOC per gram of coating solid.
The proposed BAAQMD amendments reduce VOC emissions by at least 0.45 tons per
day, representing a 30 percent reduction in current emissions. The most significant costs of
implementation are higher coating costs. A few manufacturers would need to add additional
drying trays or ventilation during damp and cool winter months. The cost-effectiveness of the
proposed amendments is estimated to range in costs from $7,000 to $26,000 per ton of VOC
reduced, $7,000 to $22,000 per ton depending on the costs of new coatings only, and up to
$26,000 if additional drying facilities are required.
The Board determined that a VOC cost-effectiveness of $15,000 per ton was within a
reasonable range to be acceptable.60
60 The EPA notes that while some of the cost effectiveness values used in this analysis are above the range that we
have typically found to be cost effective, an individual source's circumstances may result in higher or lower cost-
effectiveness values that, while sometimes serving as decision-making tools for EPA analyses, may not serve as
a key consideration for facilities when determining to reduce emissions. We employ the values in this analysis to
illustrate the potential costs of reducing emissions to a level below the MST. This illustration assumes that if
sources find a particular annual cost value to be lower than the potential gains they may accrue as a result of
reclassification, then they will adopt the value per ton. The metric that sources are likely to use for a
determination of whether they should install controls to reduce emissions in order to reclassify is cost per dollar
saved, or the break-even value at which the financial benefits from reclassification will exceed costs.
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C. 2.2 Wood Furniture Risk Assessment Cost Analyses
Multiple control cost options were evaluated for wood furniture operations. The options
include the use of add-on control equipment and the use of lower volatile (VHAP) coatings. All
of the costs were based on the two cost analyses in Parts I and II of this memo. This section
explains how the analyses were adapted for the two different kinds of control.
A. Regenerative Thermal Oxidizer (RTO)
Based on the cost analysis for MasterBrand Cabinets in Ferdinand, Indiana, the only add-
on control that was considered potentially applicable for wood furniture operations was the
regenerative thermal oxidizer. All other add-on control options are not compatible with wood
furniture coatings or emission characteristics.
Two types of coating operations were evaluated for add-on control equipment. The first
type of operation is more automated with steady coating rates. This type of operation is less
common in wood furniture manufacturing. At this time, only three wood furniture manufacturing
facilities are controlled by RTO. For our cost analysis, we assumed the operations include all
three spray booth options, using a weighted average based on the amount of VOC removed.
The second type of operations is less automated and more intermittent. This type of
operation is more common in wood furniture manufacturing. For that analysis, we assumed the
operations would most closely resemble the intermittent operations from the touch-up booths.
The cost analyses needed a few changes to work for the risk analysis. First, the
MasterBrand Cabinets analysis was based on VOC. Second, the costs are based on 2003 dollars.
The amount of VHAP was estimated based on EPA's Toxics Release Inventory. In 2003,
54 percent of the MasterBrand Cabinets VOC emissions were classified as VHAP. The Marshall
and Swift Index was used to convert the costs in 2003 to a 2010 basis. In 2003, the Index was
1,123.6, and 1,515.1 in the first quarter of 2010.
B. Compliant Coatings
Based on the cost analysis by the Bay Area Air Quality Management District, this
analysis is for the cost of lower VOC coatings, assuming that the NESHAP was revised to match
the requirements of Regulation 8-32. These lower VOC limits for wood furniture are shown as
Table 3.
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The only update that was required for the analysis was to convert the VOC to VHAP. In
terms of VOC, the cost-effectiveness was determined to be about $20,000/ton VOC. Based on
EPA case studies, VOC content of wood furniture coatings is typically 50 percent HAPs, so
$10,000/ton VOC converts to approximately $20,000/ton VHAP.
Additional work practice standards were also evaluated. Work practice standards include
cleaning up spills as soon as possible and keeping containers of volatile materials closed when
not being used. The reduction in emissions is low and costs are difficult to estimate. The
complete control cost analysis for wood furniture operations is shown in Table 5.
C. Conclusions
Overall, the annual costs for wood furniture control options range from $589,000 to $1.7
million, and VHAP reductions range from 9 to 128 tons per year of VHAP. These estimates lead
to cost-effectiveness from $20,000 per ton of VHAP to $65,000 per ton of VHAP.61
C.2.3 Miscellaneous Organic Chemical Manufacturing (MON) Annual Cost Details
The total capital and annual costs are associated with the new requirements in the MON
final rule for flares, equipment leaks, pressure relief devices (PRDs), heat exchange systems,
maintenance vents, storage tank degassing activities, and recordkeeping and reporting. More
detailed information on these costs is below.
For flares, the costs include hydrogen analyzers, calorimeters, flare gas flow monitors,
steam controls/flow monitors, air controls/flow monitors, natural gas costs, steam costs, flare
management plans, and root cause/corrective action analysis. The equipment life is assumed to
be 15 years. The initial set-up cost for a flare management plan is estimated to cost $7,400,
which was annualized over 15 years, and each root cause/corrective action analysis is estimated
to cost $1,020. These annual costs apply to facilities that operate flares that control ethylene
oxide emissions and/or flares used to control emissions from processes that produce olefins and
polyolefins.
61 The EPA notes that while some of the cost effectiveness values used in this analysis are above the range that we
have typically found to be cost effective, an individual source's circumstances may result in higher or lower cost-
effectiveness values that, while sometimes serving as decision-making tools for EPA analyses, may not serve as
a key consideration for facilities when determining to reduce emissions. We employ the values in this analysis to
illustrate the potential costs of reducing emissions to a level below the MST. This illustration assumes that if
sources find a particular annual cost value to be lower than the potential gains they may accrue as a result of
reclassification, then they will adopt the value per ton. The metric that sources are likely to use for a
determination of whether they should install controls to reduce emissions in order to reclassify is cost per dollar
saved, or the break-even value at which the financial benefits from reclassification will exceed costs.
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For MON sources without ethylene oxide controls, there is additional cost for equipment
leaks. Costs include monthly monitoring of LL pumps at a leak definition of 1,000 ppm instead
of 10,000 ppm for batch processes. Because we did not have data to identify facilities with only
continuous or only batch processes, costs were spread across all facilities. Costs are for initial
and continuous pump repair for new monitoring leak rates. The equipment life is assumed to be 5
years for pumps seals.
Equipment leak emission reductions from the controls result in chemicals in process lines
not leaking and chemicals not being lost. A recovery credit of $900 per ton VOC was applied to
the VOC emission reductions in the analyses to calculate the savings in chemicals not being
emitted due to the equipment leak requirements. The $900 per ton recovery credit has
historically been used by the EPA to represent the variety of chemicals that are used as reactants
and produced at synthetic organic chemical manufacturing (SOCMI) facilities (U.S. EPA, 2007).
For PRDs, costs include implementation of three prevention measures per PRE), root
cause/corrective action analysis per release event, and PRD monitoring. The equipment life is
assumed to be 15 years.
For heat exchange systems, costs reflect the use of the Modified El Paso Method and
repair of leaks of total strippable hydrocarbon concentration (as methane) in the stripping gas of
6.2 ppmv or greater. The costs estimates are based on a 5-year useful life of a quality assurance
plan and/or a monitor.
Emission reductions due to application of the El Paso method result in chemicals in
process lines not leaking into the heat exchange system and not being lost. A recovery credit of
$900 per ton VOC was applied to the VOC emission reductions in the analyses to calculate the
savings in those chemicals not being emitted.
For maintenance/equipment openings, costs include (i) documenting the procedures for
equipment openings and procedures for verifying that events meet the specific conditions, (ii)
documenting each circumstance under which the alternative maintenance vent limit is used, and
(iii) providing an explanation for why the other criteria could not be met prior to equipment
blinding, along with an estimate of the emissions that occurred during the equipment blinding
process. The costs assume the alternative limit is used only once per year and 0.1 hours per event
are needed to write an explanation.
For degassing tanks, the costs include degassing storage tanks to the control device to 10
percent of the lower explosive limit. The costs assume 104 tanks would be degassed each year.
C-5
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Storage tanks at facilities located in Texas were excluded from these costs because these
facilities are already subject to the state degassing permit conditions. For recordkeeping and
reporting, the initial costs include reading the rule, training costs, and initial report preparation.
Annual costs include labor costs for preparing periodic reports and recording information.
For MON sources with ethylene oxide controls, there is additional cost for equipment
leaks, process vents, and storage tanks. More detailed information on these additional costs is
below.
For equipment leaks specifically for ethylene oxide, costs include (i) monthly monitoring
of LL pumps at a leak definition of 1,000 ppm instead of 10,000 ppm for batch processes and
annual connector monitoring at a leak definition of 500 ppm, (ii) initial and continuous pump
repair for new monitoring leak rates, (iii) initial and annual monitoring of connectors, and (iv)
administrative costs for connector monitoring. The equipment life is assumed to be 5 years for
pump seals and 10 years for annual connector monitoring.
For process vents specifically for ethylene oxide, costs include (i) testing costs for
existing scrubbers to meet an ethylene oxide percent reduction of 99.9 percent, (ii) replacing of
existing scrubbers with a new scrubbing system (including scrubbers, packing, retention tank,
mix tank, pumps, heat exchanger) to achieve 99.9 percent reduction, and (iii) testing costs after
installation of the new scrubber and every 5 years thereafter. The equipment life is assumed to be
20 years.
For storage tanks specifically for ethylene oxide, costs include (i) testing costs for
existing scrubbers to meet an ethylene oxide percent reduction of 99.9 percent or sampling
analysis proving testing is not necessary, (ii) replacing of existing scrubbers with a new
scrubbing system (including scrubbers, packing, retention tank, mix tank, pumps, heat
exchanger) to achieve 99.9 percent reduction, and (iii) testing costs after installation of the new
scrubber and every 5 years thereafter. The equipment life is assumed to be 20 years.
Below in Table C-2, we present total capital investment and total annual costs for (i) all
MON facilities, (ii) MON facilities without ethylene oxide controls, and (iii) only MON facilities
with ethylene oxide controls. The annual capital costs were calculated using a 5 percent interest
rate.
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Table C-2. Total Capital Investment and Total Annual Costs (2016$)
Total
Number of Facilities
Annual Costs
w/Costs Associated with
Capital
Annual Costs w/o
w/Recovery
New Requirements
Investment
Recovery Credits
Credits
All MON Sources - Total
42,697,970
12,658,057
12,311,598
MON Sources w/o Ethylene Oxide Controls - Total
39,705,483
11,409,788
11,066,204
Flares62
2163
17,181,375
4,088,543
4,088,543
MON Equipment Leaks6*
19365
828,775
150,343
81,849
Pressure Relief Devices66
201
18,723,954
4,771,921
4,771,921
Heat Exchange Systems67
201
1,483,221
260,823
(14,268)
Maintenance Vents (Equipment Openings)4
201
-
2,340
2,340
Degassing Tanks68
162
-
489,216
489,216
Recordkeeping and Reporting
201
1,488,159
1,646,602
1,646,602
MON Sources w/Ethylene Oxide Controls - Total
2,992,487
1,248,268
1,245,394
EtO. Equipment Leaks69
770
71,125
47,460
44,586
62 The flare costs include purchasing analyzers, monitors, natural gas, and steam; developing a flare management
plan; and performing root cause analysis and corrective action; the costs are discussed in the memorandum
Control Option Impacts for Flares Located in the Miscellaneous Organic Chemical Manufacturing Source
Category, which is available in the docket.
63 The following summarizes costs for the 21 flares: (i) for 16 flares, costs are to install and operate the suite of new
operational and monitoring equipment (TCI: $1,071,000, TAC: $255,000) and (ii) for 5 flares, there are one-time
costs for initial set-up of a flare management plan because these flares already have the required monitoring
equipment (TCI: $7,400 TCI, TAC: $1,700).
64 Equipment leak costs include LDAR at a leak definition of 1,000 ppmv for light liquid pumps at batch processes
and are discussed in the memoranda Clean Air Act Section 112(d)(6) Technology Review for Equipment Leaks
Located in the Miscellaneous Organic Chemical Manufacturing Source Category and Clean Air Act Section
112(d)(6) Technology Review for Equipment Leaks Located in the Miscellaneous Organic Chemical
Manufacturing Source Category for the Final Rule, which are available in the docket.
65 All 201 facilities are subject, but since this requirement is included in EtO equipment leak requirements we did
not want to "double count" costs. As such, only 193 are shown here.
66 Pressure relief device costs were developed to comply with the work practice standard being finalized in this
action and include implementation of three prevention measures, performing root cause analysis and corrective
action, and purchasing pressure relief device monitors. Maintenance costs were estimated to document
equipment opening procedures and circumstances under which the alternative maintenance vent limit is used.
Costs are discussed in the memorandum Review of Regulatory Alternatives for Certain Vent Streams in the
Miscellaneous Organic Chemical Manufacturing Source Category, which is available in the docket.
67 Heat exchange systems costs include the use of the Modified El Paso Method to monitor for leaks and are
discussed in the memoranda Clean Air Act Section 112(d)(6) Technology Review for Heat Exchange Systems
Located in the Miscellaneous Organic Chemical Manufacturing Source Category and Clean Air Act Section
112(d)(6) Technology Review for Heat Exchange Systems Located in the Miscellaneous Organic Chemical
Manufacturing Source Category For the Final Rule, which are available in the docket.
68 Costs for degassing storage tanks are discussed in the memorandum Storage Tank Degassing Cost and Emissions
Impacts for the Miscellaneous Organic Chemical Manufacturing Source Category, which is available in the
docket.
69 Equipment leak costs for equipment in ethylene oxide service include costs for equipment leak co-proposed
Control Option 1. This control option includes LDAR at a leak definition of 1,000 ppmv for light liquid pumps at
batch processes with monthly monitoring and connector monitoring at a leak definition of 500 ppmv with annual
monitoring. Costs are discussed in the memoranda Analysis of Control Options for Equipment Leaks at
Processes that use Ethylene Oxide Located in the Miscellaneous Organic Chemical Manufacturing Source
Category and Analysis of Control Options for Equipment Leaks at Processes that use Ethylene Oxide Located in
the Miscellaneous Organic Chemical Manufacturing Source Category For the Final Rule, which are available in
the docket.
70 Eight facilities are expected to meet the threshold; however, one of these facilities already meets the requirements
of this amendment.
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EtO Process Vents71 3 2,743,001 943,071 943,071
EtO Tanks 3^ 178,361 257,737 257,737
C.2.4 Marine Vessel Tank Loading Operations
We calculated annual costs based on the information listed below that was taken from the
preamble for the Marine Vessel Tank Loading Operations finalized in 1995.
These standards will reduce nationwide emissions of HAPs from marine tank vessel
loading operations by approximately 4,150 Mg (4,565 tons) after 1999 compared with the
emissions that would result in the absence of the standards. These standards will reduce
emissions of VOCs from marine tank vessel loading operations by approximately 39,000 Mg
(42,900 tons) after 1999 compared with the emissions that would result in the absence of the
standards. No significant adverse secondary air, water, solid waste, or energy impacts are
anticipated from the promulgation of these standards. The implementation of this regulation is
expected to result in nationwide annualized costs for existing marine tank vessel loading
operations of $60 million to $100 million beyond baseline based on an analysis of applying
controls to all existing facilities not currently controlled to the level of the standards. Nationwide
capital costs expected to result from these regulations are approximately $266 million to $440
million.
The annualized costs will mostly be in the form of capital given that vapor recovery
systems are primarily required for control, with a lesser fraction devoted to operating and
maintenance.
71 Costs for process vents and storage tanks in ethylene oxide service include the requirement to control all storage
tanks in ethylene oxide service, the installation of a control device that achieves 99.9 percent ethylene oxide
emissions reductions, and initial and periodic performance testing of the control device; the costs are discussed in
the memoranda Analysis of Control Options for Storage Tanks and Process Vents Emitting Ethylene Oxide
Located in the Miscellaneous Organic Chemical Manufacturing Source Category and Analysis of Control
Options for Storage Tanks and Process Vents Emitting Ethylene Oxide Located in the Miscellaneous Organic
Chemical Manufacturing Source Category for the Final Rule, which are available in the docket.
72 Of the three storage tanks, costs assume that (i) one will be required to install a new control device (TCI:
$158,000, TAC: $250,800); (ii) one already has a control device that is meeting the required level of control so
will only have performance testing costs (TCI: $19,150, TAC: $6,900); and (iii) one will test once to
demonstrate that they are below the threshold for the requirements to apply (TCI: $1,000, TAC: $0).
C-8
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C-9
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United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Air Economics Group
Research Triangle Park, NC
EPA-452/R-20-005
September 2020
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