# Economic Impact Analysis of the Clay Ceramics Manufacturing NESHAP

U

. S

. Environmental Protection Agency Office of Air Quality Planning and Standards (OAQPS) Air Economics Group Research Triangle Park, NC 27711

Ju ly 2014 Docket ID No. EPA

- HQ

- OAR

- 2013

- 0290CONTACT INFORMATION This document has been prepared by staff from the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency. Questions related to this document should be
addressed to Tom Walton (C445

- K) , U.S. Environmental Protection Agency, Offic e of Air Quality Planning and Standards, Research Triangle Park, North Carolina 27711 (email: Walton.tom@epa.gov ).

ACKNOWLEDGEMENTS

Personnel from RTI International and Kapur Energy Environmental Economics, LLC contributed significant data, analysis, and writing to this document under contract number EP

- W

11

- 029.CONTENTS

Section Page

1. Introduction

................................ ................................ ................................ ................... 1

- 1

1.1 Executive Summary

................................ ................................ ............................. 1

- 1

2

. Profile of the Affected Industry

................................ ................................ .................... 2

- 1

2.1 Supply

................................ ................................ ................................ .................. 2

- 3
2.1.1 What Types of Products Does the Industry Provide?

.............................. 2

- 3
2.1.2 What Factors Influence Market Supply?

................................ ................. 2

- 3
2.1.3 What Factors Influence the Relationship Between Output Prices and the Quantity Supplied?

................................ ................................ ...... 2

- 4

2.2 Demand

................................ ................................ ................................ ................ 2

- 5
2.2.1 Who Uses Ceramic Products?

................................ ................................ .. 2

- 5
2.2.2 What Factor s Influence the Market Demand?

................................ ......... 2

- 5
2.2.3 What Factors Influence the Relationship Between Prices and the Quantity Demanded?

................................ ................................ ............... 2

- 6

2.3 Firm Behavior and Organization of Industry

................................ ....................... 2

- 7
2.3.1 Market Definition

................................ ................................ ..................... 2

- 7
2.3.2 Firm Pricing Behavior

................................ ................................ .............. 2

- 7
2.3.3 Affected Facilities and Ultimate Parent Companies

................................ 2

- 8

2.4 Market Data and Trends

................................ ................................ ..................... 2

- 10
2.4.1 Market Prices

................................ ................................ ......................... 2

- 11

3

. Costs of the Affected Industry

................................ ................................ ...................... 3

- 1

4

. Economic Impact Analys is

................................ ................................ ........................... 4

- 1

4.1 Description of Entities Affected

................................ ................................ .......... 4

- 1

4.2 Economic Screenin g Analysis

................................ ................................ ............. 4

- 15

. Conclusion

................................ ................................ ................................ .................... 5

- 1

6. References

................................ ................................ ................................ ..................... 6

- 1

Appendixes

A: Historical Data for Ceramic Wall and Floor Tile Manufacturin g

........................... A

- 1LIST OF FIGURES

Number Page

2

- 1. Capacity Utilization for Nonmetallic Mineral Products (NAICS 327)

........................ 2

- 2 2

- 2. Real Price Trends for Ceramic Products

................................ ................................ ..... 2

- 12LIST OF TABLES

Number Page

2

- 1. Types of Products by the Ceramics Manufacturing Indu stry

................................ ....... 2

- 4 2

- 2. Number of Establishments by Census Region

................................ .............................. 2

- 8 2

- 3. Affected Production Facilities by Census Region: Ceramic Tile and Sanitary Ware

................................ ................................ ................................ .............................. 2

- 9 2

- 4

. Parent Company Size Information

................................ ................................ ................ 2

- 9

3

- 1. Summary of Testing and Monitoring Costs

................................ ................................ .. 3

- 1

4

- 1. Summary Statistics for Economic Impact Analysis

................................ ....................... 4

- 21

- 1 SECTION 1 INTRODUCTION

The Environmental Protection Agency (EPA) promulgated Maximum Achievable Control Technology (MACT) standards for hazardous air pollutants emitted by clay ceramics manufacturing companies in 2003. These standards were vacated by the D.C. Circuit Court of Appeals in 2007. The Agency is now aiming to sign proposed standards to replace the vacated rule by August 28, 2014 and a final rule for promulgation by June 30, 2015.

1.1 Executive Summary
The purpose of this report is to evaluate the economic impacts of pollution control requirements on ceramic wall a nd floor tile and sanitary ware manufacturing businesses to help the Agency develop updated MACT standards for these businesses. The key results of the Economic Impact Analysis (EIA) are as follows:

■ Engineering Costs: Dal

- Tile, a wall tile company
, and Ko hler Co
., a Sanitary Ware company , are major sources and will incur costs as a result of the rule. EPA estimates that the total annualized costs as a result of this rule for Dal

- Tile will be $8
, 264 and for Kohler Co. will be $ 45,770 for a total annualized cost of $54,034 (2011$)

.

■ Economic Impacts: T he economic impact of compliance costs is less than 0.001% of sales for both companies affected. Hence, the economic impact for compliance is minimal.

1.2 Organization of the Report

The report is organized as follows: Section 2 provides a profile o f the industry which includes a description of the supply and demand of clay ceramic products. This section also presents information on industry organization and available market data and tr ends in the industry. Mark et data on manufacturers’ shipments
, foreign trade, and apparent consumption for

ceram ic wall and floor tiles is included in Appendix A. Section 3 describes the company

- level

costs that businesses will face to comply with the up dated rule. Section 4 explai ns the economic impacts of complying with this rule and Section 5 provides conclusions.2

- 1 SECTION 2 PROFILE OF THE AFFEC TED INDUSTRY

Ceramic wall and floor tiles and sanitary wares are inputs to build different types of structures, in cluding homes, bu ildings, and office facilities (U.S. EPA
, 2003)

. Floor and wall tile serve a decorative purpose and are used to add character to homes and buildings; sanitary ware and bathroom accessories are products installed in bathrooms (or kitchens, when it comes to sinks) and are primarily used for cleansing (U.S. EPA
, 2003)

. Ceramic Tile's end use break down in 2010 was 56.4% in residential sales dollars and 43.6% in commercial sales dollars (Ceramic Tile and Stone Consultants
, 2013)

. To provide a general overview of current conditions in the affected industry, we used the U.S. government’s official measures reported in the Annual Survey of Manufacturers (ASM), County Business Patterns, and Current Industrial Reports

. Because the latest year of data (2010) differs from historical industry trends, it is unclear whether the industry without the proposed rule would be similar to the industry today. As a resu lt, the profile provides information on a range of factors that may influence how the ceramic floor and wall tile and sanitary ware markets may evolve.

Federal statistical agencies classify business establishments in this industry using two North American Industry Classification System (NAICS) codes: 1

■ 327111 Vitreous china plumbing fixture and china and earthenware bathroom accessories manufacturing

■ 327122 Ceramic wall and floor tile manufacturing

In the rest of the industry profile section, we use the te rm “sanitary ware” to refer to products produced by the NAICS 327111 industry, and the term “ceramic wall and floor tile” to refer to products produced by the NAICS 327122 industry. We also use the term “ceramic products” to refer to both ceramic floor and wall tile and sanitary ware products.

1 In 2012, the sanitary ware industry (327111) was classified under NAICS 327 1 10 Pottery, Ceramics, and Plumbing Fixture Manufacturing

. See http://www.census.gov/cgi

bin/sssd/naics/naicsrch?code=3271 1 0&search=2012

. In 2012, the ceramic tile industry (327122) was classified under NAICS 327120 Clay Building Material and Refractories Manufacturing . See http://www.census.gov/cgi

bin/sssd/naics/naicsrch?code=327120&search=2012

.2

- 2 In 2011, the value of products shipped in the two industries was approximately $1.1 billion ( U.S. Census Bureau, 2013 f)

. The value from NAICS 327122 was about twice of that from NAICS 327111. The ASM and the County Business Patterns reported that 151 establishments (24 in 327111 and 127 in NAICS 327122) employed 5,980 people with a total annual payroll of about $243 million in 2011. (U.S. Census Bureau, 2013a, b ).

Du ring 201 0 , approximately 700 m illion square feet of tiles were produced by the ceramic wall and floor tile industry (U.S. Department of Commerce, Census Bureau, 2011 ). Federal Reserve data suggest the capacity utilization r ate for the industries under the broad 327 NAICS is close to 56% ( Board of Governors of the Federal Reserve System , 2013 ) ( see Figure 2

- 1 )

.

Figure 2

- 1. C apacity Utilization for Nonmetallic Mineral Products (NAICS 327)

Source: Federal Reserve Board. 2013. Industrial Production and Capacity Utilization

— G.17.

http://www.federalreserve.gov/datadownload/Chart.aspx?rel=G17&series=a0ccc54490f3f114f44928eb9cb9ec98 &lastObs=20&from=&to=&fi letype=spreadsheetml&label=include&layout=seriescolumn&pp=Download ( December 20 , 2013). The current observed conditions are influenced by the recent steep declines in the residential construction market. For example, 2011 new privately owned housing starts (608,800) units are well below levels observed in 2000 (1.6 million) and 1990 (1.2 million ) (U.S. Census Bureau, 2013c ). Since 2010, new residential housing starts have begun to grow again, but levels2

- 3 are still much lower than the previous two decades. New privately owned housing starts in July 2013 were at a seasonally adjusted annual rate of 852,000 (U.S. Census Bureau, 2013d ).

2.1 Supply To better understand the markets for affected product s, we consider the group of sellers that provide goods to the market and common factors that influence supply (e.g., input prices) and quantity of goods supplied (e.g., output prices).

2.1.1 What Types of Products Does the Industry Provide?

Table 2

- 1 lists categ ories of sanitary ware (NAICS 327111) and ceramic wall and floor tile (NAICS 327122) products.

2.1.2 What Factors Influence Market Supply ? The general process steps used in the production of ceramics include raw material processing, mixing, forming, shape drying, glazing, firing, and finishing (U.S. EPA, 2003; U.S. EPA, 1996)

. Census data for NAICS 327122 c eramic w all and f loor t ile m anufacturing and for NAICS 327111 sanitary ware manufacturing suggest that in both industries around 70 % of the product’s val ue is associated with value

- added activities (i.e., labor and capital earnings and energy costs ) (U.S. Census Bureau 2013 (a)). During the last 5 years, labor costs have remained flat in the nonmetallic mineral products sector. The U.S. Bureau of Labor Sta tistics reports that average annual hourly earnings (adjusted for inflation) of all employees was about $20 per hour (U.S. Bureau of Labor Statistics, 2013a, b ).

The value of intermediate goods used in thes e processes (i.e., raw materials including clays and other minerals mined from natural deposits, and high purity powders prepared by chemical synthesis [ U.S. EPA, 2003; U.S. EPA, 1996 ] ) make up the remaining 30% of the ceramics’ total product value. Interm ediate production costs can be influenced by changes in raw clay material prices, but the prices of these materials have not fluctuated recently

. Ball clay prices primarily used in floor and wall tile, (consuming 38% of ball clay production in 2011) and

sa nitary ware (consuming 20% of ball clay production in 20 11 ) were $45 per metric ton in 2010 and $46 per metric ton in 2011; the average free alongside ship value for exported ball clay and the average c ustoms value for imported ball clay were, respectively , $59 per metri c ton and $318 per metric ton (U.S. Geological Survey [USGS], 2013 ).2

- 4 Table 2

- 1

. Types of Products by the Ceramics Manufacturing Indust ry

2007 NAICS 2012 NAICS Product

327111 327110 Bathroom accessories, vitreous china and earthenware, manufacturing
327111 327110 Bidets, vitreous china, manufacturing
327111 327110 Drinking fountains, vitreous china, non

- refrigerated, manufacturing
327111 327110 Faucet handles, vitreous china and earthenware, manufacturing
327111 327110 Handles, faucet, vitreous china and earthenware, manufacturing
327111 327110 Lavatories, vitreous china, manufacturing
327111 327110 Plumbing fixtures, vitreous china, manufacturing
327111 327110 Sinks, vitreous china, manufacturing
327111 327110 Soap dishes, vitreous china and earthenware, manufacturing
327111 327110 Tanks, flush, vitreous china, manufacturing
327111 327110 Toilet fixtures, vitreous china, manufacturing
327111 327110 Towel bar holders, vitreous china and earthenware, manufacturing
327111 327110 Urinals, vitreous china, manufacturing
327111 327110 Water closet bowls, vitreous china, manufacturing
327122 327120 Ceramic tiles, floor and wall, manufacturing
327122 327120 Floor tile, ceramic, manufacturing
327122 327120 Mosaic tile, ceramic, manufacturing
327122 327120 Quarry tiles, clay, manufacturing
327122 327120 Tile, ceramic wall and floor, manufacturing
327122 327120 Wall tile, ceramic, manufacturing

Source: U.S. Census Bureau 2013 . 2012 NAICS definition, 327110 Pottery, Ceramics, and Plumbing Fixture

Manufacturing. http://www.census.gov/cgi

bin/sssd/naics/naicsrch?code=327110&search=2012%20NAICS%20Search

2.1.3 What Factors Influence the Relationship Between Output Prices and the Quantity Supplied ? All other things equal, wall and floor tile and sanitary ware manufacturers are likely to off er to sell more when the prices of wall and floor tile and sanitary ware rise. The price elasticity of supply measures how much the quantity of wall and floor tile/sanitary ware supplied responds to changes in its price. 2 If manufacturers have a significant amount of flexibility to change the amount they produce when the price rises, the supply is elastic. In contrast, if the

2 The measure is computed as the percentage change in quantity supplied divided by the percentage change in price.2

- 5 quantity produced and supplied only changes by small amounts when the price rises, the supply is inelastic. A key determinant of the price elasticity of supply is the length of the time period over which the product choices can be made. During shorter periods, it is more d ifficult for the firm to adjust inputs and increase production , because quantities of some factors are fixed in the short run

.
2.2 Demand

Ceramic wall and floor tiles and sanitary wares are inputs to build different types of structures, including homes, build ings, and office facilities, and are influenced by overall macroeconomic trends and conditions in the residential housing industry.

2.2.1 Who Uses Ceramic Products?
Sanitary ware and c eramic floor and wall tile are used in the construction of homes, buildings, and structures: floor and wall tile serve a decorative purpose and are used to add character to homes and buildings. Sanitary wares (and bathroom accessories) are products installed in bathrooms and are primarily used for cleansing (U.S. EPA, 2003). In the case of sinks, sanitary wares are also installed in kitchens (U.S. EPA, 2003). These products are purchased by construction companies to be used as inputs for the production of homes, buildings, and office facilities. Once these structures are built, cons umers then purchase these structures from the construction companies. However, if consumers build homes or make improvements to existing structures themselves, they may directly purchase and install sanitary ware (bathroom accessories,) and ceramic tiles ( U.S. EPA, 2003).

2.2.2 What Factors Influence the Market Demand ? Ceramics are designed for specific commercial or industrial applications to withstand high temperatures and electrical voltage, or to resist chemical attack, fatigue failure, or rapid wear (Midwes t Research Institute
, 1999).

2.2.2.1 Price of Related Goods

There are similar

- use products made from materials other than clay . Below we discuss sanitary ware and ceramic wall and floor tile separately.

2.2.2.1.1 Sanitary Ware

As EPA (2003) mentions:

“ Bathroom accessories such as soap dishes, towel racks, toothbrush holders, and faucet fixtures come in an array of materials, including plastic, brushed or polished metal, and glass.2

- 6 Consumers usually base their choice of bathroom accessories on their spec ific tastes and the type of look they want to create as they decorate the bathroom. Generally plastic accessories are relatively inexpensive, though when higher quality plastics are used, producers can charge prices in the same range as those for bathroom accessories made from glass, ceramics, or metal. ”

“ Clay is the most common material used for the manufacture of sanitary ware, but sinks and toilets can also be made out of stainless or enameled steel, fiberglass, or enameled cast iron. These materials all possess similar characteristics to ceramic sanitary ware, but to differing degrees. For example, steel may be less subject to cracking than ceramic material; however it is not as heat resistant. Another material used to produce sanitary ware is marble, wh ich is one of the most expensive materials available for sanitary ware production. ”

2.2.2.1.2 Ceramic Wall and Floor Tile

The substitutes for ceramic floor tile are other floor covering materials including laminate, hardwood, stone, vinyl sheet & floor tile, carpet & area rug, and other resilient flooring (Floor Covering Weekly
, 2013). In 2012, Ceramic wall and floor tile account ed for 12.5% of U.S. Floor Covering Sales, on the same level with hardwood (10.4%) and vinyl sheet & floor tile (12.6%) but far less than carpet & area rug (52.1%) (Floor Covering Weekly
, 2013). Among these different types of materials, natural stone is the most expensive, having an average value of around $4 per square foot during the years between 2008 and 2012. Hardwood has an average price of around $2. All other types, including ceramic tile, have a price of around $1 per square foot, except vinyl sheet & floor tile that has a price of around $0.7 per square foot (Floor Covering Weekly
, 2013)

.
2.2.3 What Factors Influence the Relati onship Between Prices and the Quantity Demanded? All other things equal, consumers will likely buy fewer ceramic products when the price of the product rises. The price elasticity of demand measures the size of the price response. 3
Several factors influenc e how sensitive consumers are to price changes. If consumers can easily switch from one product to another because there are many close substitutes, demand tends to be more elastic. This is particularly true for more narrow market definitions ( mosaic versus quarry tile ) and over longer time horizons for the consumption decision (months versus years).

3 The measure is computed as the percentage change in quantity demanded divided by the percentage change in price.2

- 7 2.3 Firm Behavior and Organization of Industry

2.3.1 Market Definition Market definition boundaries are commonly defined in two dimensions: product substitution an d geography. Based on product substitution characteristics and available data, we rely on the Census definitions to define two groups of markets in which buyers are more likely to view products as substitutes:

■ Sanitary ware

■ Ceramic wall and floor tile

We f ound that international trade represented a large fraction of economic activity for ceramic wall and floor tile (see Section 2.4 )

.
2.3.2 Firm Pricing Behavior Economists have developed a system for grouping markets that helps describe the pricing behavior of fi rm s . At one end of the spectrum, firms have little control over pricing for their products. Put another way, firms are price takers, and price is determined by supply and demand conditions. This basic model is more likely to hold when the industry has a la rge number of sellers, goods are identical, and barriers for entry and exit (laws, high capital requirements, or patents) are low. At the other end of the spectrum, there is a single firm that searches for the price

- output combination that maximizes its pr ofit. This basic model is more likely to hold when there are significant barriers to entry (industries with economies of scale or ownership of a patent).

When markets have a small number of firms selling identical products, firms may not necessarily be pri ce takers; instead, they may be able to determine their price while considering how competitors respond to their own decisions. To assess the extent to which affected markets may be concentrated among a small number of sellers we compiled and estimated Tab le 2

- 2.

The latest 5

- year Census statistics describing U.S. concentration at the 6

- digit NAICS code level, found that the ceramic wall and floor tile manufacturing industry has a Herfindahl index level (a measurement of concentration) that government agen cies consider moderately concentrated (U.S. Census Bureau, 2013e; U.S. Department of Justice and the Federal Trade Commission
, 1997 ). This index is not available for the sanitary ware industry. However, the data suggest th at the sanitary ware industry is even more concentrated. The 4 largest ceramic wall and floor tile manufacturing companies account for 59.8% of the industry’s total shipment value,2

- 8 while the 4 largest sanitary ware manufacturing companies account for 87.2% of the industry’s shipment (U.S. Census Bureau, 2013e )

.
Table 2

- 2

. Number of Establishments by Census Region

Census Region Number of Establishments, NAICS 327111 Number of Establishments, NAICS 327122

East North Central 6 18

East South Central 1 15

Mid

- Atlantic 4 11

Mountain 1 13 New England 0 5

Pacific 5 33

South Atlantic 3 16
West North Central 1 9
West South Central 3 7 Note: In County Business Pattern, an “establishment” is defined as follows

–

“ An establishment is a single physical location at which business is conducted or services or industrial operations are performed. It is not necessarily identical with a company or enterprise, which may consist of one or more establishments. When two or more a ctivities are carried on at a single location under a single ownership, all activities generally are grouped together as a single establishment. The entire establishment is classified on the basis of its major activity and all data are included in that cla ssification. ” Source s : U.S. Census Bureau. 2013; Geography Area Series: County Business Patterns: 2011;

http://censtats.census.gov/cgi

- bin/cbpnaic/cbpcomp.pl (17 Dec 2013) ;
U.S. Census Bureau. 2013; Geography Area Series: County Business Patterns: 2011: Definitions; http://www.census.gov/econ/cbp/definitions.htm

U.S. Census Bureau (undated), Census Regions and Divisions of the United States, http://www.census.gov/geo/maps

- data/maps/pdfs/refe rence/us_regdiv.pdf

2.3.3 Affected Facilities and Ultimate Parent Companies

RTI has identified t he major source facilities that are expect ed to be covered by the rule in Table 2

- 3. T wo companies own four facilities ; two of the four affected facilities are located in the south central region.2

- 9 Table 2

- 3

. Affected Production Facilities by Census Region: Ceramic Tile and Sanitary W are

Facility/ Company

- Ceramic Tile Facility Location Tile Type Region

Dal

- Tile /Mohawk Industries El Paso, TX Wall tile West South Central
Company

- Sanitary W are Facility Location Region

Kohler Co. Kohler, WI East North Central

Kohler Co. Spartanburg, SC South Atlantic

Kohler Co. Brownwood, TX West South Central

2.3.3.1 Small Businesses The Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA) requires federal departments and agencies to evaluate if and/or how their regulations affect small business entities. Specifically, the Agency must determine if a regulation is expe cted to have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. The business is defined as the owner company, rather than the facility ; the size of the owner company determines the resources it has available to comply with the rule. The Small Business Administration website specifies the criteria for a company to be considered a small business. The size standards for NAICS 327111 (which in 2012 was changed to NAICS 327110) and NAICS 327122 ( which in 2012 was changed to NAICS 327120 ) is any company with 750 or fewer employees. Thus, as shown in Table 2

- 4, neither of the affected

owner

- companies is a small entity.

Table 2

- 4. Parent Company Size Information

Parent Company Sales (million $) Employment * Small

Mohawk Industries, Inc. 5, 642.3 * 25,100 No

Kohler Co. 4, 680 * 30
, 000 No

*201 1 data Sources: Mohawk Industries, Inc. 2012 Form 10

-

K http://www.sec.gov/Archives/edgar/data/851968/000085196813000027/a201210k.htm#s83B6709C35E312765 F11526DA34F90DA Kohler: Forbe s.com http://www.forbes.com/companies/kohler2

- 10 2.4 Market Data and Trends This section presents historical market data for Ceramic wall and floor tiles and sanitary

ware. Historical market data include U.S. volumes for manufacturers’ shipments, 4 foreign trade, and apparent consumption . Data for ceramic wall and floor tile, obtained from various years of Current Industrial Reports published by the U.S. Census Bureau, are shown in Appendix A

.

These data revea l that the clay floor and wall tile market has two characteristics. First, the historical shipment levels have been stable with mild fluctuations. Second, imports account for much larger proportion of the apparent consumption than do shipments

. Imports of wall and floor tiles experienced declines starting in 2007, the year the recent economic crisis set in, and continued to decline post

- crisis. The shipments also experienced a decline in 2007, although it was mild compared to the drastic drop of imports. Th e level of shipments has come back to its
pre

- 2007 levels as of 2010

. The decline in imports since 2007 is due to the decreased demand resulti ng from the 2007

– 2008 recession rather than to structural changes within the industry. We expect both overall dema nd and imports to come back to prerecession levels in the future. This projection is also supported by the recent annual report of a large company producing these products. T he annual report of Mohawk Industries shows the company recovering after exhibitin g declines during the recession.

Kohler Co. manufactures sanitary ware , in addition to other products

. There is evidence that the sanitary ware industry will see rising domestic production in the coming years

. Toilet s

are one of the major sanitary ware products. According to an article from the Wall Street Journal by James R. Hagerty, Kohler Co. is the biggest toilet supplier in the U.S., with an estimated 24% of the U.S. market. T he article mentions that making toilets req uires lots of manual labor and for this reason most production moved over the past two decades to lower

- cost countries, mostly China and Mexico. It was estimated that three quarters of the 10.6 million residential and commercial toilets sold in the U.S. in the year 2012 were imports; there are just 7 toilet plants in the U.S. now , compared with 48 in the late 1970s. However, because of high shipping costs and increasing wages in China and Mexico, U.S. manufacturing of toilets is m aking a come back (Hagerty
, 2013).

4 The source reports list both shipment and production quantities. Here we have chosen shipment quantities over production quantities, even though these do not differ by much in each y ear nor show different trends over time. The reason to choose shipment numbers over production numbers is that shipment quantity is the number that is relevant for final consumption. In fact, when the data source reports calculate “ apparent consumption, ” t hey use shipment numbers, not production numbers.2

- 11 Kohler Co. has four toilet plants, three in the U.S. and one in Mexico. Its revenues rose from $4.68 billion in 2011 (Forbes, 2011) to $5 billion in 2012 (Forbes, 2013). David Kohler, the president of Kohler Co., says in an interview that “the econo my definitely is on stronger footing and national and regional businesses are doing better” (Kirchen
, 2013). The likely increas e in residential building during the economy’s recovery should lead to an increased demand for sanitary ware.

The above company

- specific information supports the recovery since 2007 we see in the Current Industrial Reports’ information for the ceramic tile industry. The Current Industrial Reports do not provide data for the sanitary ware industry. However, based on the above
compan y

- specific information and the fact that sanitary ware is demanded by residential and commercial building, we believe that the sanitary ware industry, similar to the ceramic tile industry, will recover as the building and construction industry revives. In addition, our prediction that the ceramic tile industry is only experiencing a temporary setback and will come back to prerecession levels also is supported by recent reports for the clay and shale industry, which is upstream of the ceramic product s indust ry. O ne of the most common types of clays used to produce ceramic products is common clay and shale (U.S. EPA, 2003 ). A recent advance report published in 2013 by U.S. Department of the Interior , U.S. Geological Ser vice, suggests that once statistical data become available, the country may see a moderate growth in common clay sales in 2012 (U.S. Department of the Interior, 2013 ). In their analysis, the factors supporting the growth are increases in housing starts and construction spending for commercial buildings, which are the sources of demand for ceramic tile and sanitary ware.

2.4.1 Market Prices In 2010, the average price of clay floor and wall tile was approximately $1.30 per square foot ( U.S. Department of Commerce, Census Bureau, 2011 ). Since 2005, the average nominal price for clay floor and wall tile has remained flat
, while the price for sanitary ware has risen moderately (Figure 2

- 2).2

- 12 Figure 2

- 2. Real Price Trends for Ceramic Products

Sources: U.S. Bureau of Labor Statistics. 2013 . Employment, Hours, and Earnings from the Current Employment Statistics

survey (National) Series ID: CEU3132700003.
U.S. B ureau of Labor Statistics. 2013 . Producer Price Index

— Clay buildin g material and refractories manufacturing

Clay floor and wall tile, glazed and unglazed Series ID: PCU3271203271202. U.S. Bureau of Labor Statistics. 2013. Producer Price Index

— Pottery, ceramics, and plumbing fixture

manufacturing Vitreous china plumbing f ixture and china and earthenware bathroom accessories Series ID: PCU3271103271101. 0 20 40 60 80 100 120 140

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Price Index

Year

Vitreous china plumbing fixture and china and earthenware bathroom accessories Clay floor and wall tile, glazed and unglazed3

- 1 SECTION 3 COSTS OF THE AFFECTED INDUSTRY

RTI has identified t he major source facilities that are expect ed to be covered by the rule in Section 2, Tab le 2

- 3. There are two companies that own four facilities

. Dal

- Tile
, a wall tile
company , and Kohler Co.
, a sanitary wa re company , are major sources and will incur costs as a result of the rule. However, they w ill not incur any control costs, only emissions testing costs and monitoring, record keeping and reporting costs. Table 3

- 1 shows the costs for the se two companies

. A s shown in Table 3

- 1 the costs for these two companies are extremely low, so economic impacts are expected to be small.

Table 3

- 1. Summar y of Testing and Monitoring Costs

Company Annualized Testing Cost ( thousand 201 1 $) Annual Monitoring Cost ( thousand 201 1 $) Total Annualized Compliance Costs ( thousand 201 1 $) Company

- Ceramic Tile

- Wall Tile
Dal

- Tile

- El Paso 5

. 3 3.0 8

. 3 Sanitary Ware Company
Kohler

- Spartanburg Plant 12.8 11

. 9 24.7
Kohler

- Brownwood Plant 4

. 7 3.0 7. 7
Kohler

- Wisconsin Plant 7

. 4 6.0 13

. 4
Kohler

- All Plants C ombined 24.9 20 .9 45.8 Total, All Companies 30.2 23.9 54.0

Source : CC Testing and Monitoring Costs_5

- 2

- 14

- 1

.4

- 1 SECTION 4 ECONOMIC IMPACT ANAL YSIS

4.1 Description of Entities Affected
As stated in Section 3, there are only two major sources. The se are the two companies that have not installed controls, thu s incurring compliance costs : Dal

- Tile
, a wall tile company
, and Kohler Co.
, a sanitary ware co mpany.

4.2 Economic Screening Analys is
In order to determine the effects of the regulatory program on each company , we compared pollution control costs to total sales for the ultimate pare nt companies of these businesses

. We c alculated the cost

- to

- sales ratio, by dividing an ultimate parent company’s total annual c ompliance cost by its reported revenue:

CSR = � TTTTT i / TT j n

i

w here

CSR = cost

- to

- sales ratio,

TACC i = total annualized compliance costs,

i = index of the number of affected plants owned by company j,

n = number of affected plants, and

TRj = total revenue from all operations of ultimate parent company j.4

- 2 Table 4

- 1. Summary Statistics for Economic I mpact Analysis

Company Parent Company CSR (Cost

- to

- Sales Ratio, %) Company

- Ceramic Tile

- Wall Tile Dal

- Tile

- El Paso Mohawk Industries, Inc. < 0.001 % Company

- Sanitary Ware Kohler

- All Plants Combined Kohler Co. <0.001 %
Sources: Mohawk Industries, Inc. 2012 Form 10

- K

http://www.sec.gov/Archives/edgar/data/851968/000085196813000027/a201210k.htm#s83B6709 C35E312765F1 1526DA34F90DA http://www.forbes.com/companies/kohler CC Testing and Monitoring Costs_5

- 2

- 14

- 1

To identify the total revenue for Mohawk Industries, Inc. the ultimate parent company of Dal

- Tile El Paso, w e accessed the Securities and Exchange Commission (SEC) EDGAR Database. The SEC website describes this database as follows:

“ EDGAR, the Electronic Data Gathering, Analysis, and Retrieval system, performs automated collection, validation, in dexing, acceptance, and forwarding of submissions by companies and others who are required by law to file forms with the U.S. Securities and Exchange Commission (SEC). Its primary purpose is to increase the efficiency and fairness of the securities market for the benefit of investors, corporations, and the economy by accelerating the receipt, acceptance, dissemination, and analysis of time

- sensitive corporate information filed with the agency

. ”

Forbes database was used to obtain the tot al revenue for Kohler Company , which is privately held

. Forbes.com was founded in 1996 and is part of Forbes Digital, a division of Forbes Media LLC. Forbes is a leading source for reliable business news and financial information.

The results of the screening analysis in Table 4

- 1 show that the economic impact of compliance costs is less than 0.001% of sales for both companies affected. Hence, the economic impact for compliance is minimal. Also, as noted in Section 2, neither affect ed firm is a small business. Because no small firms face significant control costs, there is no significant impact on small entities. Thus this regulation is not expected to have significant impact on a substantial number of small entities.5

- 1 SECTION 5 CONCLUSION

The Agency has considered the economic impacts of this rule on companies and found that this rule will have minimal economic impact on the entities affected by the rule. The rule will impact two ultimate parent companies. One of these is the parent company of a wall tile manufacturing company and the other is the parent company of a sanitary ware manufacturing
company. Both of these businesses would have annualized cost of less than .001% of sales associated with meeting the re quirements. Hence, the burden of this rule on these businesses is very small

.6

- 1 SECTION 6 REFERENCES

Ceramic Tile and Stone Consultants. 2013. Ceramic Tile Statistics. http://www.ctasc.com/.docs/pg/332
Federal Reserve Board. 2013. Industrial Production and Capacity Utilization

— G.17. http://www.federalreserve.gov/datadownload/Chart.aspx?rel=G17&series=a0ccc54490f3 f114f44928eb9cb9ec98&lastObs=20&from=&to=&filetype=spreadsh eetml&label=inclu de&layout=seriescolumn&pp=Download (December 20, 2013).
Floor Covering Weekly (July 22, 2013). Statistical Report 2012. http://www.floorcoveringweekly.com/Resource.ashx?sn=STATS

- WEPOST
Hagerty, James R. (Sep 24, 2013). America’s Toilet Tur naround. The Wall Street Journal. http://online.wsj.com/news/articles/SB10001424052702303983904579093463623447196

. (Dec 23 2013)
Ho, M., R. Morgenstern, J. Shih . 2008. Impact of Carbon Price Policies on U.S. Industry. Resources for the Future Discussion Paper DP 08

- 37. http://www.rff.org/documents/RFF

- DP

- 08

- 37.pdf
Kirchen, Rich (Oct 15, 2013). PGA at W histling Straits to offer 'on

- course' suites. The Business Journal Serving Greater Milwaukee. http://www.bizjournals.com/milwaukee/news/201 3/10/15/pga

- at

- whistling

- straits

- to

offer.html?page=all . (Dec 23 2013)

Kohler Co. http://www.forbes.com/companies/kohler and http://www.forbes.com/lists/2011/21/private

- companies

- 11_Kohler_O87B.html
Midwest Research Institute. 1999. Characterization of the Ceramic Manufacturing Industry. Page 2
Mohawk Industries, Inc. 2012. 2011 Annual Report. http:// phx.corporate

ir.net/External.File?item=UGFyZW50SUQ9MTMzMjE1fENoaWxkSUQ9LTF8VHlwZ T0z&t=1

Mohawk Industries, Inc. 2012 Form 10

- K http://www.sec.gov/Archives/edgar/data/851968/000085196813000027/a201210k.htm#s 83B6709C35E312765F11526DA34F90DA

Mohawk Industries, Inc. 2012 Annual Report. http://www.annualreports.com/Company/3634

Monarch Ceramic Tile, Inc. http://www.manta.com/c/mm75yp9/monarch

- ceramic

- tile

- inc6

- 2 Rutherford, T.F. 2002. Lecture Notes on Constant Elasticity Functions. http://www.gamsworld.e u/mpsge/debreu/ces.pdf
U.S. Bureau of Labor Statistics. 2013a. Employment, Hours, and Earnings from the Current Employment Statistics survey (National) Series ID: CEU3132700003.

U.S. Bureau of Labor Statistics. 2013b. Consumer Price Index

— All Urban Consumers Series ID: CUUR0000SA0.

U.S. Bureau of Labor Statistics. 2013c. Producer Price Index

— Clay building material and refractories manufacturing Clay floor and wall tile, glazed and unglazed Series ID: PCU3271203271202.

U.S. Bureau of Labor Statistics. 2013d. Producer Price Index

— Pottery, ceramics, and plumbing fixture manufacturing Vitreous china plumbing fixture and china and earthenware bathroom accessories Series ID: PCU3271103271101.U.S. Census Bureau 2013 (a); Annual Survey of Manufactures: Genera l Statistics: Statistics for Industry Groups and Industries: 2011 and 2010; http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ASM_ 2011_31GS101&prodType=table (19 December 2013).
U.S. Census Bureau. 2013(c). Historical New Re sidential Construction Started. http://www.census.gov/construction/nrc/historical_data/ (August 16, 2013).
U.S. Census Bureau. 2013(d). New Residential Construction Press Release Augus t 16, 2013. http://www.census.gov/construction/nrc/ (August 16, 2013).
U.S. Census Bureau. 2013 (e); Manufacturing: Subject Series: Concentration Ratios: Share of Value of Shipments Accounted for by t he 4, 8, 20, and 50 Largest Companies for Industries: 2007; http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_ 2007_US_31SR12&prodType=table (1 9 Dec ember 2013).

U.S. Census Bureau 2013 (f ); Annual Survey of Manufactures: Value of Products Shipments : Value of Shipments for Product Classes: 2011 and 2010 ; http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ASM_ 2011_31VS101&prodType=table ; (09 December 2013).
U.S. Census Bureau (undated), Census Regions and Divisions of the United States, http://www.census.gov/geo/maps

- data/maps/pdfs/reference/us_regdiv.pdf
U.S. Census Bureau 2013 (g). 2012 NAICS definition, 327110 Pottery, Ceramics, and Plumbing Fixture Manufa cturin g. http://www.census.gov/cgi

bin/sssd/naics/naicsrch?code=327110&search=2012%20NAICS%20Search6

- 3 U.S. Census Bureau. 2013 (h). Geography Area Seri es: County Business Patterns: 2011: Definitions; http://www.census.gov/econ/cbp/definitions.htm
U.S. Department of Commerce, Census Bureau, 2011: Current Industrial Reports for Clay Construction Products

— Summary 2010.
U.S. Department of Commerce, Census Bu reau, 2009: Current Industrial Reports for Clay Construction Products

— Summary 2008.
U.S. Department of Commerce, Census Bureau, 2007: Current Industrial Reports for Clay Construction Products

— Summary 2006.
U.S. Department of Commerce, Census Bureau, 2005: Current Industrial Reports for Clay Construction Products

— Summary 2004.
U.S. Department of Commerce, Census Bureau, 2004: Current Industrial Reports for Clay Construction Products

— Summary 2003.
U.S. Department of Commerce, Census Bureau, 2003: Current Indu strial Reports for Clay Construction Products

— Summary 2002.
U.S. Department of Commerce, Census Bureau, 2002: Current Industrial Reports for Clay Construction Products

— Summary 2001.
U.S. Department of Commerce, Census Bureau, 2000: Current Industrial Repor ts for Clay Construction Products

— Summary 1999.
U.S. Department of Commerce, Census Bureau, 2000. Current Industrial Reports for Clay Construction Products

— Summary 1998.
U.S. Department of Commerce, Census Bureau, 1998: Current Industrial Reports for Clay Construction Products

— Summary 1997.
U.S. Department of Commerce, Census Bureau. 1996. Current Industrial Reports for Clay Construction Products; Summary, 1995.
U.S. Department of Commerce, Census Bureau, 1995: Current Industrial Reports for Clay Constructi on Products

— Summary 1994.
U.S. Department of the Interior, U.S. Geological Survey (May 2013), 2011 Minerals Yearbook, Clay and Shale [Advance R elease], http://minera ls.usgs.gov/minerals/pubs/commodity/clays/myb1

- 2011

- clays.pdf
U.S. Department of Justice and the Federal Trade Commission (April 1997), Horizontal Merger Guidelines, 1.5 Concentration and Market Shares, http://www.justice.gov/atr/public/guidelines/horiz_bo ok/15.html6

- 4 U.S. Department of Transportation, Bureau of Transportation Statistics. 2010. 2007 Commodity Flow Survey United States. Table 15. http://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/commodity_flow_surv ey/final_tables_december_2009/index.html
U.S. Environmental Protection Agency. 2003. “Economic Impact Analysis of the Clay Ceramics Manu facturing NESHAP: Final Rule”, http://www.epa.gov/ttn/atw/brick/clayeiafnl.pdf
U.S. Environmental Protection Agency. 1997. Emission Factor Documentation for AP

- 42, Section 11.3, “Brick and Structural Clay Products Manufacturing: Final Report.” http://www.epa.gov/ttnchie1/ap42/ch11/bgdocs/b11s03.pdf
U.S. Environmental Protection Agency. 1996. Emission Factor Documentation for AP

- 42, Section 11.7, “Ceramic Products Manufacturing: Final Re port.”
U.S. Small Business Administration (SBA). 2013. Table of Small Business Size Standards. http://www.sba.gov/sites/default/files/files/size_table_07222013.pdfA

- 1 APPENDIX A HISTORICAL DATA FOR CERAMIC WALL AND FLO OR TILE MANUFACTURIN GA

- 2 Table A

- 1 . Historical Data for Ceramic Wall and Floor Tile Man ufacturing (thousands of square feet): 1993

– 2010

Year Shipments of Clay Floor and Wall Tile Exports a Imports a Apparent Consumption b

1993 558,700 43 ,3 07 c 641,615 1,157,008
1994 604,408 40,107 c 711,193 1,275,494
1995 568,094 42,649 c 774,571 1,300,016
1996 580,392 41,789 c 884,051 1,422,655
1997 618,978 42,442 1,022,852 1,599,388
1998 636,805 41,635 1,232,974 1,828,144
1999 636,242 30,731 1,494,031 2,099,542
2000 650,483 36,188 1,669,677 2,283,972
2001 591,080 33,304 1,716,360 2,274,137
2002 649,480 41,699 2,034,617 2,642,397
2003 614,850 28,933 2,231,166 2,817,082
2004 695,386 34,854 2,488,165 3,148,698
2005 658,198 37,017 2,638,332 3,259,513
2006 629,672 45,101 2,732,194 3,316,765
2007 544,988 47,469 1,191,974 1,689,494
2008 484,956 50,515 1,685,532 2,119,973
2009 571,255 42,428 c 1,221,085 d 1,749,911
2010 649,057 36,982 c 1,293,726 d 1,905,801 Average Annual Growth Rates
1993

– 2008 e −0.64% 2.33% 9.35% 5.85%
1997

– 2008 e −1.87% 3.32% 8.24% 4.89%
1997

– 2010 e 0.83% 0.59% 5.31% 3. 48 %
1993

– 2010 e 1.28% 0.36% 6.98% 4.66%

Note: Table 2

- 6 presents data for clay floor and wall tile, which, by 2007 NAICS definition, is associated with NAICS 327122,

Ce ramic Wall and Floor Tile Manufacturing. Calculation rules used when computing numbers from the Industrial reports for this table are 1 thousa nd of square feet =

0.092903 thousand of square meters and 1 million square feet = 1,000 thousand square feet

a The export quantities for 1993

– 1996 are not available in the source reports (marked as (X)). The export and import quantities

for 2009 and 2010 are not available in the source report; only the export and import values are given.

b Apparent Consumption = Shipments of Clay Floor and Wall Tile − Exports + Imports (continued)A

- 3 Table A

- 1 . Historical Data for Clay Floor and Wall Tile (thousands of square feet): 1993

– 2010 (continued)

c Because the export quantity data for clay floor and wall tile are not available for 1993

– 1996, and 2009 and 2010, the numbers

for 1993

– 1996 and 2009 and 2010 are estimates for clay floor and wall tile exports. The expo rt numbers for clay floor and wall tile seem to be significantly and negatively correlated to shipment numbers. So we have estimated the numbers for 1993

– 1996 and 2009 and 2010 based on the regression exports = a + b * shipments , using 1997 to 2008 data. The estimate for b is significant at the 5% level.

d Because import quantity data for clay floor and wall tile are not available for 2009 and 2010, the numbers here are based on

estimates. (Only import values are available.) The import quantities exhibit a st eady increasing pattern between 1993 and 2006, a drastic drop in 2007, and a significant increase in 2008. So estimating 2009 and 2010 levels builds on the basic judgment of whether the 2009 and 2010 levels remained at the 2007 and 2008 low or rose quickly toward the 2006 level after the increase in 2008. Numbers of import values suggest that the former case is more likely to be true. Specifically, the impo rt values also experienced a similar drastic drop in 2007 and a significant increase in 2008. But the import values in 2009 and 2010 are between 2007 and 2008 values and closer to the 2007 value. The import values suggest that the import quantities in 2009 and 2010 remained at the 2007 and 2008 low instead of coming back. Further, the yearly average price, computed as the import value divided by the import quantity in a year, remained stable and at about $10 per square meter (Specifically, the import quantities in 2005, 2006, 2007, and 2008 are, respectively, 245109, 253829, 110738, and 156591, all in thous and sq meters, and the import values in 2005, 2006, 2007, and 2008 are, respectively, 2257926, 2365930, 1074328, and 1624960, all in thousands of dollars. Dividing values by quantities yield the four yearly prices as $9.2, $9.3, $9.7, and $10.4), suggesti n g that it is indeed safe to infer the rise and fall in quantities with values. Finally, to estimate, we computed the average of the average prices in 2007 and 2008 to be $10.04 per square meter and used this estimated price and reported 2009 and 2010 impor t values to obtain the estimated 2009 and 2010 import quantities.

e The growth rates have been computed for 1993

– 2008, 1997

– 2008, 1997

– 2010, and 1993

– 2010, because import data for 2009

and 2010 are estimates and export quantities for 1993

– 1996, 2009, and 2 010 are also estimates. Sources: U.S. Department of Commerce, Census Bureau. 2011. Current Industrial Reports for Clay Construction Products

—

Summary 2010. U.S. Department of Commerce, Census Bureau. 2009. Current Industrial Reports for Clay Construction P roducts

— Summary 2008. U.S. Department of Commerce, Census Bureau. 2007. Current Industrial Reports for Clay Construction Products

— Summary 2006. U.S. Department of Commerce, Census Bureau. 2005. Current Industrial Reports for Clay Construction Products

— Su mmary 2004. U.S. Department of Commerce, Census Bureau. 2004. Current Industrial Reports for Clay Construction Products

— Summary 2003. U.S. Department of Commerce, Census Bureau. 2003. Current Industrial Reports for Clay Construction Products

— Summary 2002. U.S. Department of Commerce, Census Bureau. 2002. Current Industrial Reports for Clay Construction Products

— Summary 2001. U.S. Department of Commerce, Census Bureau. 2000. Current Industrial Reports for Clay Construction Products

— Summary 1999.
U.S . Department of Commerce, Census Bureau. 2000. Current Industrial Reports for Clay Construction Products

— Summary 1998. U.S. Department of Commerce, Census Bureau. 1998. Current Industrial Reports for Clay Construction Products

— Summary 1997. U.S. Departme nt of Commerce, Census Bureau. 1996. Current Industrial Reports for Clay Construction Products

— Summary 1995. U.S. Department of Commerce, Census Bureau. 1995. Current Industrial Reports for Clay Construction Products

— Summary 199 4.A

- 4 References:

U.S. Censu s Bureau. 2013 (b); Geography Area Series: County Business Patterns: 1995

- 2011; generated by RTI Internati onal; using American Factfinder. http://factfinder2.census.gov

. ( August 16, 2013).