Memorandum
                                       
TO:	Docket for rulemaking, "National Emission Standards for Hazardous Air Pollutants: Leather Finishing Operations Residual Risk and Technology Review" (EPA-HQ-OAR-2003-0194)
DATE:		October 24, 2018
SUBJECT: 	Final Economic Impact Analysis for the Reconsideration of the Risk and Technology Review: Leather Finishing Operations Source Category



This document addresses the economic impacts of the final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Leather Finishing Operations to address the results of the residual risk and technology review (RTR) that the United States Environmental Protection Agency (U.S. EPA) is required to conduct.

The total national cost to comply with the final rule is estimated to be $832 in 2017 dollars, which is incurred through facilities familiarizing themselves with the rule. This cost is a one-time cost that will be incurred in the first year following promulgation of the final amendments. There are no additional emission control costs or additional emission reductions associated with this rule.

There are currently four existing leather finishing operations that were identified as being subject to this action. The estimated cost of $832 is comprised of equal costs incurred by each of the four affected facilities, with each facility estimated to incur one-time labor costs of approximately $208 in order to become familiar with the rule. The methodology for the estimation of the cost is detailed in the memorandum titled Costs for the Leather Finishing Operations Source Category Risk and Technology Review  -  Final Amendments, which can be found in the docket for this action.

Each of the four affected facilities is owned by an ultimate parent entity which has annual sales above one million dollars. The one-time estimated costs are less than 0.01 percent of sales for each of these entities, three of which are small businesses. These costs are not expected to result in business closures, significant price increases, or substantial profit loss. U.S. EPA expects that this action will not have a significant economic impact on the affected entities. Therefore, this regulation is not expected to have a significant impact on a substantial number of small entities (or SISNOSE) according to the Small Business Regulatory Enforcement Fairness Act (SBREFA). In addition, there are no impacts sufficiently significant to warrant analysis or action as required by the Unfunded Mandates Reform Act (UMRA). Finally, no impacts on employment are expected given the minimal economic impact of the action on the affected firms.
