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U.S. Environmental Protection Agency

 Office of Air Quality Planning and Standards

 Health and Environmental Impacts Division

Air Economics Group

Final Gold Mine Ore Processing and Production NESHAP – Economic and 

Small Business Analysis (December 2010)

This report is the economic impact analysis for the final gold mine ore processing and 

production NESHAP, which will be signed as per a court-ordered schedule on December 16, 

2010. Implementation of the final rule is required by 3 years after promulgation of the final 

rule. Details on the final rule can be found in the preamble contained in the public docket for 

this rulemaking. 

There are 10 firms that are ultimate parent companies that own gold mines impacted by 

this NESHAP. Most of these firms are multinational, and the majority of these firms have 

revenues above $1 billion for the last full year reported (2008). None of these firms are a small 

business as defined by the Small Business Administration (SBA) for this industry (NAICS 

212221) – 500 employees or less for a parent owner of gold mines.

1

 Thus, there is no significant 

economic impact on a substantial number of small entities (SISNOSE) as a result of this rule. 

Currently, the gold ore mining industry in the US is doing relatively well from a 

historical standpoint. Gold ore mining in the US is driven by the international spot market for 

gold, and current spot prices are now (as of December 2010) at the highest level recorded on a 

nominal (not inflation-adjusted) basis – over $1,400/troy ounce. 

This analysis identified the businesses that will be affected by this rule and provides an 

analysis at a screening level to assist in determining whether this rule is likely to impose a 

significant economic impact on affected businesses. The analysis employed here is a “sales test” 

that computes the annualized compliance costs as a share of sales for each company. 

The “sales test” is the impact methodology 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.

2

 This is because revenues or sales data is commonly available 

data for entities normally impacted by EPA regulations and profits data normally made available 

is often not the true profits earned by firms due to 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. 

 1 U.S. Small Business Administration, Table of Size Standards. November 5, 2010. Found on the Internet at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 2 More information on sales and profit tests as used in analyses done by U.S. EPA can be found at 

http://www.epa.gov/sbrefa/documents/rfaguidance11-00-06.pdf, pp. 32-33. 
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The total annualized cost (TAC) of the final rule is $9.1 million (2008 dollars). These 

costs reflect the requirement of additional monitoring, reporting, and recordkeeping (MRR) that 

is in the rule, and some amount of additional emissions control required with a focus on 

estimating the impacts of the rule on companies that require additional controls for compliance. 

Roughly 12 percent of the TAC ($1.06 million) is from the monitoring requirements, while the 

remaining 88 percent ($8.0 million) is from additional controls necessary to meet the rule

requirements. No impacts for the beyond-the-floor options are included in this economic impact 

analysis. For more information on the cost analysis, please refer to “Estimates of Impacts for the 

Final Mercury Emission Standards for Gold Mine Ore Processing and Production,” prepared by 

the U.S. EPA and available in the docket for this rulemaking. 

Table 1 lists the 10 ultimate parent companies impacted by the rule, the costs of the rule 

for each company basis, the annual revenues for these companies, and then the impact to the 

company on a cost to sales basis. Revenues for each firm were taken from the last available full 

year of financial data. On a firm by firm basis, the annualized cost is no more than 0.85 percent 

of revenue for any affected firm, and the annualized cost is only 0.04 percent of revenue on 

average for any affected firm. It should be noted that this analysis does not presume any 

incidence of the costs on the consumers of gold and other metals mined by these companies. 

Thus, no estimate of the impact of this rule on gold consumers is included in this report. 

However, the direct impact of this rule appears quite minor, and thus it is reasonable to infer that 

the impact on gold consumers from this rule should also be minor. The TAC is taken from the 

cost memorandum prepared by U.S. EPA for the final rule and in that memorandum can be 

found more information on the cost analysis. 

Table 1. Gold Ore Mining Process Companies Affected by the Final Rule,

 and Impacts on Them

Ultimate Parent 

Company

TAC per Company 

(2008$)*

Annual Revenues per 

Company (2008)

TAC per Revenues for Each 

Company (in %)

Barrick Gold $1,764,406 $8,136,000,000 0.0212%

Newmont Mining $6,112,284 7,700,000,000 0.078%

Kinross $135,335 2,412,100,000 0.0056%

Kennecott (owned by 

Rio Tinto)** $173,427 6,300,000,000 0.0024%

Gold Corp.

$71,497 2,419,600,000 0.0030%

Jipangu $242,716 4,972,600,000 0.0051%

Anglo-Gold Ashanti $69,632 3,743,000,000 0.0019%

Queenstake Resources 

(owned by YukonNevada Gold)** $401,781 48,940,000 0.82%

Coeur D'Alene Mining $27,242 189,465,000 0.014%

New Gold $69,632 218,135,000 0.032%

*TAC = Total Annualized Cost

**Rio Tinto is the parent company of Kennecott; Yukon-Nevada Gold is the parent company of 

Queenstake Resources
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References for Parent Company Data:

Barrick Gold

http://www.barrick.com/News/PressReleases/PressReleaseDetails/default.aspx?PressReleaseId=6d028

7d6-9627-4c0f-89fd-3a1ee5270277

Newmont Mining http://seekingalpha.com/article/190726-newmont-mining-corporation-q4-2009-earnings-call-transcript

Kinross

http://www.kinross.com/news-articles/2010/kinross-2009-production-increases-22-percent,-revenueby-49-percent.aspx

Kennecott (owned by 

Rio Tinto) http://www.riotinto.com/shareholders/12331_annual_results_2009.asp

Gold Corp. http://www.goldcorp.com/_resources/GC_FactSheetNov09.pdf

Jipangu

Anglo-Gold Ashanti

http://www.anglogold.com/subwebs/InformationForInvestors/Reports08/AnnualReport08/f/group_inc

ome.htm

Queenstake Resources 

(owned by YukonNevada Gold) http://www.yukon-nevadagold.com/i/pdf/2008-12-31_YNG-FS-MDA.pdf

Coeur D'Alene 

Mining http://www.coeur.com/uploads/file/Bowne%20FINAL.pdf

New Gold

http://newgold.com/Theme/NewGold/Files/documents_financials/resourceNew%20Gold%20AR%20CDN%20GAAP%20December%202008-SEDAR.pdf