Author: Abt Associates Inc.

Date Created:

Date Modified: 3/14/2011

Purpose:

This file estimates the impact that compliance requirements will have on facilities' financial performance. This is done using two tests, a 

test of severe impacts - whether a facilities' net present value on a tax-adjusted basis remains positive - and a test of moderate impacts 

which compares a facility's financial health to the lower 25th percentile of firms in it industry.

File Contents:

Worksheet Contents

RFA Tables Summarizes Impacts by Sector for the RFA analysis

Frim Analysis

Calculates firm-level impacts by summing costs for all facilities own by the firms. Analysis is done using two different weighting 

scenarios, one assuming that firms own all the facilities represented by their facilities' weights and second that assumes firms only own 

the facilities they are known to own and other, similar firms own facilities represented by their facilities' weights.

Facility Data Reads in facility data including parent, size, weight, and compliance costs

Total Small Firms by Industry Table of the total number of small firms in each sector (not limited to those in the 316(b) analysis)

Input Files:

External data used in calculations/analysis:

Aluminum Profile Table.xls

Chemicals Profile Table.xls

Food & Bev Profile Table.xls

Man_Cost_Control.xls

Man_Facility_Impact.xls

MN_Facility_Data.xls

P3F MN Survey Data.xls

Paper Profile Table.xls

Man_Parent_Info_Size.xls

Petroleum Profile Table.xls

Steel Profile Table.xls

The original version of this file contains, or is linked to a file that contains, confidential business information (CBI), or information that could be used to reveal CBI. As a 

result, the values for any variables determined by EPA to be CBI, or that could be used to reveal CBI, have been concealed.
IM Only Everywhere (2+MGD)

P3-Survey

2 3 4 5 6 7 8

Firms Owning In-scope Facilities

Costs as percent of firm revenue

<1% 1-3% >3% No Rev

Small 27 24 0 2 1

Large 99 96 0 1 2

ctr_firm_facilwts_Total Total 126 120 0 3 3

Small 67 60 0 2 5

Large 301 294 3 0 4

ctr_firm_firmwts_Total Total 368 354 3 2 9

Case 1 Case 2

Total Sector 

Small 

Manufacturing 

Firms

316(b) Small 

Manufacturing 

Firms

Percent of 

Small Firms 

Subject to 

Regulation

Total Sector 

Small 

Manufacturing 

Firms

316(b) Small 

Manufacturing 

Firms

Percent of Small 

Firms Subject to 

Regulation

Paper 218 9 4.1% 218 29 13.2%

Chemicals 2,506 4 0.2% 2,506 18 0.7%

Petroleum 188 4 2.1% 188 4 2.2%

Steel 1,149 3 0.3% 1,149 8 0.7%

Aluminum 227 2 0.9% 227 5 2.0%

Food 23,546 1 0.0% 23,546 0 0.0%

Firms that own facilities 

in Primary 

Manufacturing 

Industries 27,834 23 0.1% 27,834 63 0.2%

Option

Weights

Assuming Firms Own 

Both Surveyed 

Facilities and those 

represented by their 

sample weights

Assumption Size Firms

Assuming Firms Own 

Only Surveyed 

Facilities (Not those 

represented by their 

sample weights)

Firm Sector
Case 1 Case 2

Total 316(b) 

Manufacturing 

Firms

Small 316(b) 

Manufacturing 

Firms

Percent of 

Regulated 

Firms that are 

Small

Total 316(b) 

Manufacturing 

Firms

Small 316(b) 

Manufacturing 

Firms

Percent of Regulated 

Firms that are Small

Paper 42 9 21.4% 126 29 22.9%

Chemicals 26 4 15.4% 116 18 15.2%

Petroleum 17 4 23.5% 24 4 17.7%

Steel 16 3 18.8% 43 8 19.2%

Aluminum 5 2 40.0% 14 5 31.6%

Food 8 1 12.5% 24 0 0.0%

Multiple 3 0 0.0% 13 0 0.0%

Firms that own facilities 

in Primary 

Manufacturing 

Industries 117 23 19.7% 359 63 17.7%

Other 9 4 44.4% 9 4 44.4%

1

Firm Sector
for RFA

Firm Sector

Total 316(b) 

Manufacturing 

Firms

Small 316(b) 

Manufacturing 

Firms

Small Firms 

with Costs > 

1% of 

Revenue

Small Firms 

with Costs > 3% 

of Revenue

Paper 42 9 0 0

Chemicals 26 4 0 0

Petroleum 17 4 1 1

Steel 16 3 0 0

Aluminum 5 2 0 0

Food 8 1 0 0

Multiple 3 0 0 0

Firms that own facilities 

in Primary 

Manufacturing 

Industries 117 23 1 1

Other 9 4 1 1

rfa_facilwts_Total Total 126 27 2 2

Paper 126 29 0 0

Chemicals 116 18 0 0

Petroleum 24 4 1 1

Steel 43 8 0 0

Aluminum 14 5 0 0

Food 24 0 0 0

Multiple 13 0 0 0

Firms that own facilities 

in Primary 

Manufacturing 

Industries 359 63 1 1

Other 9 4 1 1

rfa_firmwts_Total Total 368 67 2 2

Case 1

Case 2
for RFA tables in doc. Hard-coded

Table 1‐4: Number and Percentage of Small Firms Subject to the Proposed Regulation, by Industry

 1% of 

Revenue 3% of Revenue

1% of 

Revenue

3% of 

Revenue

Option 1: IM Everywhere

Paper 42 9 1 0 126 29 1 0

Chemicals 26 4 0 0 116 18 0 0

Petroleum 17 4 1 1 24 4 1 1

Steel 16 3 0 0 43 8 0 0

Aluminum 5 2 0 0 14 5 0 0

Food 8 1 0 0 24 0 0 0

Multiple 3 0 0 0 13 0 0 0

Firms that own facilities 

in Primary 

Manufacturing 

Industries 117 23 2 1 359 63 2 1

Additional firms that own 

known facilities in Other 

Industries 9 4 1 1 9 4 1 1

Option 2: Cooling Towers for Facilities with DIF > 125 MGD, Else IM 

Paper 42 9 1 0 126 29 1 0

Chemicals 26 4 0 0 116 18 0 0

Petroleum 17 4 1 1 24 4 1 1

Steel 16 3 0 0 43 8 0 0

Aluminum 5 2 0 0 14 5 0 0

Food 8 1 0 0 24 0 0 0

Multiple 3 0 0 0 13 0 0 0

Firms that own facilities 

in Primary 

Manufacturing 

Industries 117 23 2 1 359 63 2 1

Additional firms that own 

known facilities in Other 

Industries 9 4 1 1 9 4 1 1

Small Firms with Costs 

Exceeding 

Firm Sector

Total 316(b) 

Firms

Small 316(b) 

Firms Total 316(b) Firms Small 316(b) Firms

Case 1: Lower bound estimate of number of firms owning facilities 

that face requirements under the regulatory analysis

Case 2: Upper bound estimate of number of firms owning facilities that 

face requirements under the regulatory analysis

Small Firms with Costs 

Exceeding 
Table 1‐4: Number and Percentage of Small Firms Subject to the Proposed Regulation, by Industry

 1% of 

Revenue 3% of Revenue

1% of 

Revenue

3% of 

Revenue

Small Firms with Costs 

Exceeding 

Firm Sector

Total 316(b) 

Firms

Small 316(b) 

Firms Total 316(b) Firms Small 316(b) Firms

Case 1: Lower bound estimate of number of firms owning facilities 

that face requirements under the regulatory analysis

Case 2: Upper bound estimate of number of firms owning facilities that 

face requirements under the regulatory analysis

Small Firms with Costs 

Exceeding 

Option 3: Cooling Towers Everywhere

Paper 42 9 3 0 126 29 3 0

Chemicals 26 4 1 0 116 18 1 0

Petroleum 17 4 1 1 24 4 1 1

Steel 16 3 1 0 43 8 1 0

Aluminum 5 2 0 0 14 5 0 0

Food 8 1 0 0 24 0 0 0

Multiple 3 0 0 0 13 0 0 0

Firms that own facilities 

in Primary 

Manufacturing 

Industries 117 23 6 1 359 63 6 1

Additional firms that own 

known facilities in Other 

Industries 9 4 1 1 9 4 1 1
10 6 9 2

Firm Info

Parent Name Sector Revenues Size Facilities Owned
8

Survey IDs of Facilities Owned

123456789 10 11 12
8

Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12

Facility weights and their associated costs and revenues are color coded from high to low for firms owning facilities with 

different weights
In-scope Facilities 

Owned
Highest ----------------------------------------------------------------------> Lowest

5

Revenues of Facilities Owned

1 2 3 4 5 6 7
Highest ----------------------------------------------------------------------> Lowest

8 9 10 11 12 1 2 3 4
Highest ----------------------------------------------------------------------> Lowest

11

Compliance Costs of Owned Facilities

5 6 7 8 9 10 11 12
Highest ----------------------------------------------------------------------> Lowest

Unique Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12

# Unique 

weights
?????? Leave out the lowest weight? Leaves out the 2nd lowest wgt? Leaves out the 3rd lowest wgt?

Represented Firm Weights Represented Firm Costs

1 2 3 4 5 1 2 3 4 5
rd lowest wgt?

Represented Firm Cost-Revenue

12345
Weighted Costs of Owned Firms

123456789 10 11 12 Total
Wtd Cost / Parent Rev

Represented Firm Sector Represented Firm Size

Weighted Cost-Revenue 1 2 3 4 5 1 2 3 4 5
Largest Weight is Left Out?

Represented Facility Firm Category RFA Impact Category Represented Firm Size & Impact Category

1 2 3 4 5 1 2 3 4 5 1 2 3 4 5
Largest Weight is Left Out?

RFA Size & Impact Category

1 2 3 4 5
RFA Category

Size and RFA 

Category

Chemicals Small <1% <1% Small_<1% Small_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Multiple Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Other Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Petroleum Small <1% <1% Small_<1% Small_<1%

Food Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Petroleum Small <1% <1% Small_<1% Small_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Petroleum Large No Rev No Rev Large_No Rev Large_No Rev

Other Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Paper Large No Rev No Rev Large_No Rev Large_No Rev

Paper Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Small <1% <1% Small_<1% Small_<1%

Chemicals Small <1% <1% Small_<1% Small_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Petroleum Small >3% >3% Small_>3% Small_>3%

Paper Large >3% >3% Large_>3% Large_>3%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Other Large <1% <1% Large_<1% Large_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Petroleum Small <1% <1% Small_<1% Small_<1%

Other Large <1% <1% Large_<1% Large_<1%

Multiple Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Aluminum Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Other Small <1% <1% Small_<1% Small_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Food Large <1% <1% Large_<1% Large_<1%

Steel Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Size (In-scope 

Owning Only)

Impact 

Category

Size & Impact 

Sector Category
10 6 9 2

Firm Info

Parent Name Sector Revenues Size Facilities Owned
8

Survey IDs of Facilities Owned

123456789 10 11 12
8

Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12

Facility weights and their associated costs and revenues are color coded from high to low for firms owning facilities with 

different weights
In-scope Facilities 

Owned
Highest ----------------------------------------------------------------------> Lowest

5

Revenues of Facilities Owned

1 2 3 4 5 6 7
Highest ----------------------------------------------------------------------> Lowest

8 9 10 11 12 1 2 3 4
Highest ----------------------------------------------------------------------> Lowest

11

Compliance Costs of Owned Facilities

5 6 7 8 9 10 11 12
Highest ----------------------------------------------------------------------> Lowest

Unique Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12

# Unique 

weights
?????? Leave out the lowest weight? Leaves out the 2nd lowest wgt? Leaves out the 3rd lowest wgt?

Represented Firm Weights Represented Firm Costs

1 2 3 4 5 1 2 3 4 5
rd lowest wgt?

Represented Firm Cost-Revenue

12345
Weighted Costs of Owned Firms

123456789 10 11 12 Total
Wtd Cost / Parent Rev

Represented Firm Sector Represented Firm Size

Weighted Cost-Revenue 1 2 3 4 5 1 2 3 4 5
Largest Weight is Left Out?

Represented Facility Firm Category RFA Impact Category Represented Firm Size & Impact Category

1 2 3 4 5 1 2 3 4 5 1 2 3 4 5
Largest Weight is Left Out?

RFA Size & Impact Category

1 2 3 4 5
RFA Category

Size and RFA 

Category

Size (In-scope 

Owning Only)

Impact 

Category

Size & Impact 

Sector Category

Multiple Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Other Small >3% >3% Small_>3% Small_>3%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Small No Rev No Rev Small_No Rev Small_No Rev

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Small <1% <1% Small_<1% Small_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Aluminum Small <1% <1% Small_<1% Small_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Aluminum Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Aluminum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Other Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Other Small <1% <1% Small_<1% Small_<1%

Food Small <1% <1% Small_<1% Small_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Other Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Chemicals Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Chemicals Small <1% <1% Small_<1% Small_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Petroleum Large <1% <1% Large_<1% Large_<1%

Paper Large <1% <1% Large_<1% Large_<1%

Aluminum Large <1% <1% Large_<1% Large_<1%

Steel Small <1% <1% Small_<1% Small_<1%

Paper Small <1% <1% Small_<1% Small_<1%

Steel Large <1% <1% Large_<1% Large_<1%

Steel Large <1% <1% Large_<1% Large_<1%
1

234

12

346

Facility 

Survey ID Parent Parent_Order

Parent Revenue 

($)
5 6 7 8 9 10 11

3 4 5 6 7 8 9

9 12 8 7 6 22

Parent 

Size

Facility 

Sector

Tech 

Weight

Econ 

Weight In-Scope

SID (Inscope)

Annualized Aftertax Compliance 

Costs
1

234

12

346

Facility 

Survey ID Parent Parent_Order

Parent Revenue 

($)
5 6 7 8 9 10 11

3 4 5 6 7 8 9

9 12 8 7 6 22

Parent 

Size

Facility 

Sector

Tech 

Weight

Econ 

Weight In-Scope

SID (Inscope)

Annualized Aftertax Compliance 

Costs
1

234

12

346

Facility 

Survey ID Parent Parent_Order

Parent Revenue 

($)
5 6 7 8 9 10 11

3 4 5 6 7 8 9

9 12 8 7 6 22

Parent 

Size

Facility 

Sector

Tech 

Weight

Econ 

Weight In-Scope

SID (Inscope)

Annualized Aftertax Compliance 

Costs
1

234

12

346

Facility 

Survey ID Parent Parent_Order

Parent Revenue 

($)
5 6 7 8 9 10 11

3 4 5 6 7 8 9

9 12 8 7 6 22

Parent 

Size

Facility 

Sector

Tech 

Weight

Econ 

Weight In-Scope

SID (Inscope)

Annualized Aftertax Compliance 

Costs
Sector Firms with <500 employees

Paper 218

Chemicals 2506

Petroleum 188

Steel 1149

Aluminum 227

Food 23,546

Source: SUSB 2006