
MEMORANDUM

TO:	Dockets for rulemaking, "Printing, Coating and Dyeing of Fabrics and Other Textiles (Subpart OOOO)" (EPA-HQ-OAR-2017-0668)
DATE:		April 13, 2018
SUBJECT:	Economic Impact and Small Business Screening Assessments for Proposed Amendments to the National Emission Standards for Hazardous Air Pollutants for the Printing, Coating and Dyeing of Fabrics and Other Textiles (Subpart OOOO)

Introduction
      
This document summarizes economic impact and small business screening assessments for the proposed amendments to the National Emission Standards for Hazardous Air Pollutants for the Coating and Dyeing of Fabrics and Other Textiles (40 CFR part 63, Subpart OOOO) based on the residual risk and technology review. The costs estimated for the proposed amendments to subpart OOOO are associated with familiarization with the rule requirements and changes to the Startup, Shutdown, and Malfunction (SSM) requirements for all 43 affected entities. A discussion of the regulatory options evaluated and their detailed cost estimates is provided in the December 12, 2017 technical memorandum entitled "Costs/Impacts of the Proposed 40 CFR Part 63 Subparts NNNN, OOOO and RRRR Monitoring Review Revisions," available in the docket.

Costs of the Proposed Amendments

This proposal will require that the emission standards be met at all times, including during startup, shutdown, and malfunction, and will require the use of the electronic reporting tool for annual reports, performance testing, and notifications. The burden associated with this rule is the recordkeeping requirement for startup, shutdown, and malfunction, and the requirement that facilities use the electronic reporting tool. While the electronic reporting requirement is expected to be no more burdensome than the current reporting requirement, there are costs associated with becoming familiar with the rule requirements and electronic reporting system, as well as re-evaluating previously developed SSM record systems. The one-time total cost of this rule is estimated to be $90,000 for the 43 affected entities.

Economic Impacts

Economic impact analyses focus on changes in market prices and output levels. If changes in market prices and output levels in the primary markets are significant enough, impacts on other markets may also be examined. Both the magnitude of costs needed to comply with a proposed rule and the distribution of these costs among affected facilities can have a role in determining how the market will change in response to a proposed rule. The per-facility costs for familiarization with the rule requirements and changes to the SSM requirements were compared to the total sales for the ultimate owner of the affected facilities to estimate the total burden for each facility. The total costs associated with Subpart OOOO's proposed requirements range from 0.000005 to 0.42 percent of annual sales revenue per affected entity. These costs are not expected to result in a significant market impact, regardless of whether they are passed on to the purchaser or absorbed by the firms.

The EPA prepared a small business screening assessment to determine if any of the identified affected entities are small entities, as defined by the U.S. Small Business Administration (SBA). The affected facilities that perform coating and dyeing of fabrics and other textiles fall into one of the following North American Industry Classification System (NAICS) codes, where the associated SBA small entity size threshold appears in parentheses: 313110, Fiber, Yarn, and Thread Mills (1,250 or fewer employees); 313210, Broadwoven Fabric Mills (1,000 or fewer employees); 313310, Textile and Fabric Finishing Mills (1,000 or fewer employees); 313320, Fabric Coating Mills	(1,000 or fewer employees); 314110, Carpet and Rug Mills (1,500 or fewer employees); 314999, All Other Miscellaneous Textile Product Mills (500 or fewer employees); 322220, Paper Bag and Coated and Treated Paper Manufacturing (750 or fewer employees); 323111, Commercial Printing (except Screen and Books) (500 or fewer employees); 325211, Plastics Material and Resin Manufacturing	(1,250 or fewer employees); 326130, Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing (500 or fewer employees); 326220, Rubber and Plastics Hoses and Belting Manufacturing (750 or fewer employees); 326299, All Other Rubber Product Manufacturing (500 or fewer employees); 334290, Other Communications Equipment Manufacturing (750 or fewer employees); 334418, Printed Circuit Assembly (Electronic Assembly) Manufacturing (750 or fewer employees); 335932, Noncurrent‑Carrying Wiring Device Manufacturing (1,000 or fewer employees); 336390, Other Motor Vehicle Parts Manufacturing (1,000 or fewer employees); or 336992, Military Armored Vehicle, Tank and Tank Component Manufacturing (1,500 or fewer employees).
Eighteen of the potentially affected entities are small entities. However, the annualized costs associated with Subpart OOOO's proposed requirements for these 18 affected small entities range from 0.001 to 0.42 percent of annual sales revenues per affected entity. Therefore, there are no significant economic impacts on a substantial number of small entities (SISNOSE) from these proposed amendments.
