Memorandum
                                       
TO:	Docket for rulemaking, "National Emission Standards for Hazardous Air Pollutants: Wet-Formed Fiberglass Mat Production Residual Risk and Technology Review" (EPA-HQ-OAR-2004-0309)
DATE:		January 11, 2018
SUBJECT: 	Proposal Economic Impact Analysis for the Risk and Technology Review: Wet-Formed Fiberglass Mat Production Source Category



This document addresses the economic impacts of proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Wet-Formed Fiberglass Mat Production to address the results of the residual risk and technology review that the United States Environmental Protection Agency (U.S. EPA) is required to conduct.

The costs and cost savings associated with this action are detailed in the memorandum titled Cost Impacts of Wet-Formed Fiberglass Mat Production Risk and Technology Review Proposal which can be found in the docket for this action. As described in this memorandum, these costs and cost savings are expected to be incurred during the three-year period following promulgation of the final amendments. The total annual cost incurred in each of these three years is estimated to be approximately $200 in 2016 dollars. This estimated total annual cost is comprised of estimated annual costs of about $1,390 less the estimated annual cost savings of about $1,190. Costs associated with this action relate to time for facilities to review the amended rule requirements. Cost savings associated with this action relate to the proposed removal of recordkeeping and reporting requirements specific to startup, shutdown, and malfunction events. There are no additional emission control costs or additional emission reductions associated with this rule. For further details on the costs and cost savings, please see the previously cited memorandum.

As the estimated annual cost of $200 is to be incurred in each of the three years following promulgation, the present value of the total costs over the first three years is approximately $550 in 2016 dollars under a three percent discount rate. The present value of the total costs over the first three years is approximately $510 in 2016 dollars under a seven percent discount rate.

There are currently seven existing facilities that were identified as being subject to this action, being owned by four different ultimate parent entities. One entity owns three of the facilities and a different entity owns two facilities. The remaining two facilities are each owned by entities owning only one of the seven facilities.

Each of the seven facilities is owned by an ultimate parent entity which has annual sales above one billion dollars. The one-time estimated costs are less than 0.0001 percent of sales for each of these entities, none 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.
