4­
1
CHAPTER
FOUR
IMPACT
ANALYSIS
This
chapter
presents
the
estimated
impacts
associated
with
the
proposed
Tier
III
rule.
Because
the
proposed
rule
creates
cost
savings
rather
than
imposing
costs
on
the
regulated
universe,
a
SBREFA
analysis
is
not
required.
However,
to
characterize
the
impacts
of
Tier
III
on
TRI
filers,
EPA
estimated
average
annual
revenues
for
the
three
industries
with
the
highest
reported
releases:
Metal
Mining
(
SIC
10),
Chemicals
and
Allied
Products
(
SIC
28),
and
Primary
Metal
Industries
(
SIC
33).
These
revenues
were
then
compared
with
the
estimated
cost
savings
per
form
to
evaluate
the
impacts
of
the
proposed
rule.
Table
4­
1
shows
the
average
annual
revenue
per
establishment
in
the
three
industries.
The
table
shows
that
facilities
in
Metal
Mining,
Chemicals
and
Allied
Products,
and
Primary
Metal
Industries
have
average
annual
revenues
of
approximately
$
20
million,
$
37
million,
and
$
32
million,
respectively.

TABLE
4­
1
AVERAGE
REVENUES
BY
INDUSTRY
SIC
SIC
Description
1997
Establishments
1997
Revenues1
($
000)
2004
Revenues
($
000)
Average
Revenues
(
2004
Dollars)

10
Metal
Mining
696
$
11,546,138
$
16,589,279
$
20,108,217
28
Chemicals
and
Allied
Products
12,371
$
400,084,778
$
32,340,537
$
37,111,370
33
Primary
Metal
Industries
6,275
$
188,774,795
$
30,083,633
$
31,917,118
1
Based
on
value
of
shipments
which
are
used
by
Census
instead
of
revenues
for
the
manufacturing
and
mining
industries.

The
average
annual
revenues
in
Table
4­
1
were
compared
with
the
estimated
cost
savings
per
form
from
Chapter
Three
in
Tables
4­
2
and
4­
3.
Tables
4­
2
and
4­
3
show
that
cost
savings
per
form
represent
less
than
0.001%
of
average
annual
revenues
for
all
three
industries.
4­
2
TABLE
4­
2
SAVINGS
IMPACTS
FOR
FIRST
YEAR
REPORTERS
Form
R
Form
A
Form
Type
Non­
PBT
Forms
PBT
Forms
Non­
PBT
Forms
SIC
10
(
Metal
Mining)

Average
Revenues
$
20,108,217
$
20,108,217
$
20,108,217
Cost
Saving
per
Form
$
40.89
$
97.05
$
21.59
Savings
to
Revenue
Ratio
0.0002%
0.0005%
0.0001%

SIC
28
(
Chemicals
and
Allied
Products)

Average
Revenues
$
37,111,370
$
37,111,370
$
37,111,370
Cost
Saving
per
Form
$
40.89
$
97.05
$
21.59
Savings
to
Revenue
Ratio
0.0001%
0.0003%
0.0001%

SIC
33
(
Primary
Metal
Industries)

Average
Revenues
$
31,917,118
$
31,917,118
$
31,917,118
Cost
Saving
per
Form
$
40.89
$
97.05
$
21.59
Savings
to
Revenue
Ratio
0.0001%
0.0003%
0.0001%
4­
3
TABLE
4­
3
SAVINGS
IMPACTS
FOR
SUBSEQUENT
YEAR
REPORTERS
Form
R
Form
A
Form
Type
Non­
PBT
Forms
PBT
Forms
Non­
PBT
Forms
SIC
10
(
Metal
Mining)

Average
Revenues
$
20,108,217
$
20,108,217
$
20,108,217
Cost
Saving
per
Form
$
15.72
$
46.99
$
3.58
Savings
to
Revenue
Ratio
0.0001%
0.0003%
0.00002%

SIC
28
(
Chemicals
and
Allied
Products)

Average
Revenues
$
37,111,370
$
37,111,370
$
37,111,370
Cost
Saving
per
Form
$
15.72
$
46.99
$
3.58
Savings
to
Revenue
Ratio
0.00004%
0.0001%
0.00001%

SIC
33
(
Primary
Metal
Industries)

Average
Revenues
$
31,917,118
$
31,917,118
$
31,917,118
Cost
Saving
per
Form
$
15.72
$
46.99
$
3.58
Savings
to
Revenue
Ratio
0.00005%
0.0001%
0.00001%
