     Economic Analysis of the Parent Company Definition for TRI Reporting

                        DRAFT  -  Do not cite, quote, or distribute

                                       July 28, 2022

                              Prepared by Abt Associates for:
                                  Data Collection Branch
                           Data Gathering and Analysis Division
                         Office of Pollution Prevention and Toxics
                    Office of Chemical Safety and Pollution Prevention
                           U.S. Environmental Protection Agency

ES.	Executive Summary	iii
1.	Background and Overview of Analysis	1-1
1.1	Statutory Authority	1-1
1.2	Statutory and Regulatory History	1-1
1.2.1	Emergency Planning and Community Right-to-Know Act	1-1
1.2.2	Overview of TRI	1-1
1.2.3	Pollution Prevention Act	1-2
1.2.4	Changes to the List of Chemicals	1-2
1.2.5	Alternate Threshold	1-3
1.2.6	Executive Orders	1-3
1.2.7	Changes to the List of Industries	1-4
1.2.8	Changes for Chemicals of Special Concern	1-4
1.2.9	Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Rule	1-4
1.2.10	TRI Dioxin and Dioxin-like Compounds Toxic Equivalency (TEQ) Information Rule	1-5
1.3	Defining the Reporting Requirements for Facility Parent Company Information	1-5
1.4	Organization of This Report	1-6
2.	Estimated Number of Facilities and Forms Potentially Affected	2-1
3.	Cost Estimates	3-1
3.1	Estimation of Burden	3-1
3.1.1	Rule Familiarization	3-2
3.1.2	Form Completion	3-3
3.1.3	Summary of Unit Burden Estimates	3-3
3.2	Estimation of Cost	3-4
3.3	Total Incremental Industry Burden Estimates	3-6
3.4	Total Incremental Industry Cost Estimates	3-6
3.5	Annualized Incremental Cost Estimates	3-6
4.	Small Entity Analysis	4-1
4.1	Impact on Small Entities	4-1
4.2	Definitions of Small Entities	4-1
4.3	Methodology Overview	4-2
4.4	Impacts on Small Businesses	4-4
4.4.1	Identify Universe of Affected TRI Facilities	4-5
4.4.2	Characterize Facility-Parent Relationships	4-6
4.4.3	Estimate Number of Small Parent Entities	4-6
4.4.4	Estimate Annual Revenue of Parent Entities	4-7
4.4.5	Estimate of Parent Entity Compliance Costs	4-7
4.4.6	Estimate of Cost Impact Percentages	4-7
4.5	Impacts on Small Governmental Jurisdictions	4-8
4.5.1	Identify Universe of Affected TRI Facilities	4-8
4.5.2	Characterize Facility-Parent Relationships	4-9
4.5.3	Estimate the Number of Small Parent Entities	4-9
4.5.4	Estimate Annual Revenue of Small Parent Entities	4-9
4.5.5	Estimate Small Parent Entity Compliance Costs	4-10
4.5.6	Estimate Cost Impact Percentages	4-10
4.6	Summary of Small Entity Impacts	4-10
5.	Benefits	5-1
6.	Paperwork Burden and Other Analyses	6-1
6.1	Paperwork Burden Analysis	6-1
6.2	Unfunded Mandates Reform Act	6-2
6.3	Executive Order 13132 - Federalism	6-2
6.4	Executive Order 13175 - Tribal Implications	6-2
6.5	Executive Order 13045 - Protection of Children	6-2
6.6	Executive Order 12898  -  Environmental Justice	6-3
7.	References	7-1

 Executive Summary
 Introduction
Under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), and section 6607 of the Pollution Prevention Act (PPA), certain facilities are required to file annual reports to the United States Environmental Protection Agency (EPA), States, and Indian Country officials on their releases, transfers, and other waste management practices for certain toxic chemicals if they are manufactured, processed, or otherwise used above certain threshold amounts. This information is included in a publicly available database known as the Toxics Release Inventory (TRI).
 Need for the Rule
TRI requires facilities to report their highest-level United States-based parent company information annually in Part I, Section 5 of the TRI Forms R and A. No text currently exists in 40 CFR part 372 related to this important data field, and current guidance has led to differing interpretations on the definition of parent company between EPA and reporting facilities. In addition, the corporate structures for internationally-headquartered parent companies are often confusing, and facilities may not even know their highest-level U.S.-based parent company.
Each year, EPA standardizes parent company names submitted to TRI. This process involves aligning submissions to a set of business rules (e.g., Corporation is changed to Corp) in addition to researching submitted names to ensure proper reporting by using online sources and other datasets. Each year, EPA has needed to standardize at least 15 percent of the forms received.
In addition to misinterpretation of parent company reporting guidance, there are several company ownership scenarios where current guidance does not explicitly address how to report the parent company, such as facilities that are publicly-owned or have no owner with at least 50 percent of the company's voting stock.
 Regulatory Options for Defining the Reporting Requirements for Facility Parent Company Information
The rulemaking further defines and clarify reporting requirements for facility parent company information. There were three options that EPA considered as possible scenarios under the proposed rule:
 Option 1: Parent company definition is codified and included in the Reporting Forms and Instructions (RFI). The appropriate highest-level U.S.-based parent company would continue to be reported in the current data elements under Part I, Section 5.1 and its Dun & Bradstreet Number in Part I, Section 5.2.
 Option 2: Option 1, plus including instructions for how to report a foreign parent company in Part I, Section 5.1 and its Dun & Bradstreet Number in Part I, Section 5.2 instead of the highest-level U.S.-based parent company. No new data elements to the reporting forms would be added. (Thus, the parent company data elements would reflect either a U.S.-based or foreign parent company, whichever is appropriate for the facility.)
 Option 3: Combination of Options 1 and 2, which would both codify reporting the highest-level U.S.-based parent company and add two new data elements similar to Part I, Sections 5.1 and 5.2 for reporting the name of a foreign company and its Dun & Bradstreet number. Thus, facilities would report both the highest-level U.S.-based parent company and the highest-level foreign parent company, when applicable.
EPA is finalizing Option 3 in this rule, to codify the definition of "parent company" and require facilities to report both their U.S.-based parent company and foreign parent company and their Dun & Bradstreet numbers, when applicable.
 Estimated Reporting Activity
The potential options associated with changes to parent company reporting requirements are not expected to change the total number of facilities reporting to TRI nor the number of forms (Form R or Form A) filed. As a result, EPA used data from Reporting Year 2020 to estimate that 21,154 facilities and 76,815 forms are potentially affected by the rule, as shown in Table ES-1.
Table ES-1 Total Estimated Forms and Facilities Affected by the Rule

                                  Facilities
                                     Forms

                                    Form Rs
                                    Form As
                                    Total
Total Unique Number of Forms/Facilities
                                    21,154
                                    68,414
                                     8,401
                                    76,815
  Source: U.S. EPA (2022)
 Costs of the Rule
The rule will result in associated incremental costs to industry. Affected facilities will spend time reporting the required information to EPA on a Form R or a Form A. The burden and cost associated with the rule is considered incremental, as EPCRA section 313 has already established reporting requirements for qualifying facilities in qualifying industry sectors. This rule adds to those existing requirements.
For the rule, the incremental burden and cost potentially incurred by industry are estimated using comparisons to the Ratio-Based Burden Methodology (RBBM), which is a simplified formulation of the previously employed burden methodology (U.S. Environmental Protection Agency, 2011a).
In this rule, all TRI reporters are expected to incur rule familiarization costs associated with reading the new requirements as well as reporter compliance determination costs. Additionally, all TRI reporters are required to submit additional information related to their foreign parent company (by providing either the foreign parent company name or not applicable). First year and steady state burden is calculated using the RBBM and other previous economic analyses for TRI rulemakings for all cost incurring activities.
The incremental costs potentially incurred by industry are estimated using the Weighted Average Wage Rate (WAWR), representing the average loaded cost for a mix of Managerial, Technical, and Clerical labor per hour of TRI reporter burden. The WAWR is calculated using data from Bureau of Labor Statistics' Employer Costs for Employee Compensation (2022), updated quarterly, and is equal to $69.51 (in 2021 dollars).
Tables ES-2 and ES-3 present the total incremental industry burden and cost, respectively, of the first year of the rule and in the steady state. Table ES-4 presents annualized incremental industry costs annualized over 10 years at discount rates of 3 percent and 7 percent.
Table ES-2 	Estimated Total Incremental Burden by Activity
                                   Activity
                           First-Year Burden (hours)
                          Steady State Burden (hours)
Rule Familiarization
                                    10,577
                                       0
Form Completion
                                     7,256
                                      205
Total
                                    17,833
                                      205

Table ES-3 	Estimated Total Incremental Cost by Activity
                                   Activity
                                First-Year Cost
                               Steady State Cost
Rule Familiarization
                                   $735,207
                                      $0
Form Completion
                                   $504,365
                                    $14,238
Total
                                  $1,239,572
                                    $14,238

Table ES-4 	Annualized Total Incremental Industry Cost
                             Annualized Cost (3%)
                             Annualized Cost (7%)
                                   $160,338
                                   $194,732

 Small Entity Analysis
The Regulatory Flexibility Act (RFA) of 1980 (U5 U.S.C. § 601 et. seq.) requires Federal agencies to assess the effects of regulations on small entities, and in some instances, to examine alternatives to the regulations that may reduce adverse economic effects on significantly impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility analysis for each rule unless the Agency certifies that the rule will not have a significant economic impact on a substantial number of entities.
This analysis uses annualized cost impact percentages to measure potential impacts on small entities. The cost impact percentage is defined as annualized compliance costs resulting from the rule as a percentage of annual revenue or sales. For purposes of determining small entity impacts, comparing annualized compliance costs to annual revenues provides a reasonable indication of the magnitude of the regulatory burden relative to a commonly available and objective measure of a company's business volume. Where regulatory costs represent a small fraction of a typical firm's revenue, the impacts of the regulation are likely to be minimal.
EPA estimated small entity impacts for small businesses in sectors for which information is available from the 2017 U.S. Census Statistics of U.S. Businesses (SUSB), as well as small governmental jurisdictions. Annual revenues for small businesses were obtained from the 2017 SUSB, while annual revenues for governmental jurisdictions were modeled using available data on population and per-capita government jurisdiction revenues available from the U.S. Census Bureau.
Based on the results of the small entity analysis, a total of 7,669 small parent entities were estimated (7,653 private businesses and 16 municipalities). None of these potentially affected small parent entities are expected to incur compliance costs greater than 1 percent of revenues under the rule, as shown in Table ES-5.
Table ES-5 	Summary of Small Entity Analysis Results
                                  Facilities
                                Parent Entities
                             Small Parent Entities
                                 Discount Rate
           Number of Small Parent Entities by Cost Impact Percentage

                                    < 1%
                                   1% to 3%
                                    > 3%
                                    21,145
                                     8,571
                                     7,669
                                   3 Percent
                                     7,669
                                       0
                                       0

                                   7 Percent
                                     7,669
                                       0
                                       0
Note: nine facilities reported NAICS codes not required for TRI reporting and were not included in the small entity analysis.
 Benefits of the Rule
The benefits of the rule include clarity of TRI reporting requirements, increased data quality of a standardized data element, and improved decision-making related to the provision and distribution of information on releases and waste management aggregated at the parent company level. The provision of information can lead to follow-on activities that create additional costs and benefits. In particular, this information can lead to voluntary initiatives by industry to review production processes, set goals for reductions in emissions, and institute "good-neighbor" policies.
EPA has not attempted to monetize the benefits of the rule due to a lack of quantitative information characterizing the range of users and non-users of TRI data and the substantial analytical challenges associated with conducting an analysis that accurately predicts behavioral responses to the provision of information. In addition, the potentially large number of beneficiaries who are not users, or who are otherwise unaware of the data (e.g., the general public), further limits EPA's ability to quantify potential benefits. However, the experience since the first forms were submitted to TRI in 1987 suggests that reporting under EPCRA section 313 has produced real gains in understanding communities' exposure to toxic chemicals. In its report entitled The Toxics Releases Inventory in Action: Media, Government, Business, Community and Academic Uses of TRI, EPA has documented numerous examples of how multiple stakeholders have used TRI data (U.S. Environmental Protection Agency, 2013). Moreover, a cursory search on Google Scholar(TM) reveals thousands of academic articles referencing the Toxics Release Inventory. Improving the parent company information and/or adding international parent company information should provide similar incremental gains in understanding TRI releases and waste management at the parent company level.
Background and Overview of Analysis
Statutory Authority
This rule is issued under EPCRA sections 313, 42 U.S.C. 11023 et seq., and 328, 42 U.S.C. 11048 et seq., and PPA section 6607, 42 U.S.C. 13106. EPCRA, also known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), created a broad range of emergency response planning and reporting requirements for manufacturers, processors, and users of toxic chemicals in the United States. Under section 313 of EPCRA, certain facilities are required to submit annual reports to the EPA and to States and Indian Country officials on their release(s), transfer(s), and waste management activities for certain toxic chemicals if they are manufactured, processed, or otherwise used above threshold amounts. In addition, the Pollution Prevention Act (PPA) of 1990 requires these same facilities to report prevention, recycling, and other waste management information for these same chemicals. EPA maintains the data collected under EPCRA section 313 and the PPA in a database known as the Toxics Release Inventory (TRI).
This report analyzes the economic impacts of the rule. To understand the effects of the rule, however, it is first necessary to understand how EPCRA section 313 and TRI currently operate. This chapter provides an overview of TRI followed by a description of the rule and of the organization of the report.
Statutory and Regulatory History
Emergency Planning and Community Right-to-Know Act
In 1986, Congress passed the EPCRA in response to the accidental release of methyl isocyanate gas in Bhopal, India, in December 1984, and to a number of chemical accidents in the United States, including one in Institute, West Virginia. These accidental releases highlighted the lack of information readily available to the public about toxic chemicals being manufactured, processed, used, and transported within their communities. EPCRA is based on the premise that the public has the right to know about the use of chemicals, as well as their routine and accidental releases. The broad purposes are to encourage planning for responses to accidental chemical releases as well as daily management of routine releases, and to provide the public and government agencies with information about the presence, release, and management of toxic chemicals.
EPCRA contains four main provisions:
      Planning for chemical emergencies (sections 301-303),
      Emergency notification of chemical accidents and releases (section 304),
      Reporting of hazardous chemical inventories (sections 311-312), and
      Toxic chemical release reporting (section 313).
Because this rule falls under section 313 of EPCRA, the remainder of this overview only addresses the reporting provisions of section 313.
Overview of TRI
The first regulations implementing EPCRA section 313 were promulgated on February 16, 1988 (53 FR 4500) and are codified at 40 CFR part 372. Under these original regulations, owners or operators of certain facilities must complete and submit one or more Toxic Chemical Release Inventory Reporting Form R reports. Form R reporting requirements include, but are not limited to, information on releases to air, water, and land, as well as on-site waste treatment and transfers of the chemical to off-site locations.
A facility must report under section 313 if it meets all of the following three criteria:
 It is in a Standard Industrial Classification code covered by the regulations;
 It has 10 or more full-time employees (or the hourly equivalent of 20,000 hours per year or greater); and
 It manufactures, processes, or otherwise uses any of the listed toxic chemicals or chemical categories above the applicable reporting threshold.
Additionally, a facility is required to report to TRI if the EPA Administrator determines such reporting is appropriate under EPCRA 313(b)(2), and the facility exceeds applicable reporting thresholds for listed toxic chemicals.
A completed Form R must be submitted for each listed toxic chemical manufactured, processed, or otherwise used above threshold levels at each regulated facility as described in 40 CFR part 372. For most chemicals, threshold levels are set at 25,000 lb for manufacturing and processing and 10,000 lb for otherwise use (40 CFR § 372.25). The EPCRA section 313 list currently contains 775 individually listed chemicals and 33 chemical categories (hereinafter, "TRI chemicals"). Reports for each calendar year are due by July 1 of the following year.
TRI is unique among environmental databases because of the multimedia data it collects, and because it was designed for public access. The primary purpose of TRI data is to inform the public of releases and other waste management activities of toxic chemicals in their communities and enable citizens to make informed decisions regarding the consequences of such activities to human health and the environment. TRI data are also used by the federal, state, and local governments for prioritization purposes and to assess pollution prevention activities. Researchers, public interest groups, and other entities use TRI data for a variety of purposes. In general, TRI data have proven to be a powerful tool in environmental decision-making.
Pollution Prevention Act
In 1990, Congress passed the PPA, which adopted as national policy an environmental hierarchy that establishes pollution prevention as the first choice among waste management options (42 U.S.C. § 13101-13109). For waste that cannot be prevented at the source, recycling is considered the next best option, and treatment or disposal should be considered only when source reduction and recycling options cannot be implemented. Section 6607 of the PPA requires facilities to also provide information on their pollution prevention, recycling, and other waste management activities. This information complements the information reported under EPCRA section 313 by providing information about the waste management activities related to the reported chemicals. The data elements required by the PPA are included as Section 8 of Form R.
Changes to the List of Chemicals
When Congress passed EPCRA, it provided an initial list of approximately 300 chemicals and chemical categories subject to TRI reporting. The statutory list was derived from chemical lists used in New Jersey and Maryland. Congress also included a provision in EPCRA that allows EPA to amend the list of chemicals subject to TRI reporting. Under section 313(d), EPA has the authority to add a chemical to the list if it determines that the chemical can cause or can be reasonably anticipated to cause:
 Adverse acute human health effects at concentration levels reasonably likely to exist beyond facility site boundaries as a result of continuous or frequently recurring releases;
 In humans, carcinogenic or teratogenic effects, serious or irreversible reproductive dysfunction, neurological disorders, heritable genetic mutations, or other chronic health effects; or
 A significant adverse effect on the environment. See, 42 U.S.C. § 11023(d).

EPA has added chemicals to the list through its authority under section 313(d). EPA may also remove a chemical from the list if it does not meet any of the above criteria found in 313(d). According to section 313(e) of EPCRA, any person may petition EPA to add or delete a chemical from the list on the basis of whether or not it meets the above criteria (see 42 U.S.C. § 11023(e)). All changes to the list are made through the rulemaking process under the Administrative Procedures Act (APA).
Section 7321 of the National Defense Authorization Act for Fiscal Year 2020 (NDAA) added 172 per- and polyfluoroalkyl substances (PFAS) to the list of chemicals covered by the TRI under Section 313 of the EPCRA and provided a framework for additional PFAS to be added to TRI on an annual basis. The NDAA automatically added four additional PFAS to the TRI list that will be reportable for the 2021 reporting year (i.e., reports due July 1, 2022) and four additional PFAS for the 2022 reporting year (i.e., reports due July 1, 2023), bringing the total to 180 reportable PFAS.
Alternate Threshold
On November 30, 1994, EPA finalized the "TRI Alternate Threshold for Facilities with Low Annual Reportable Amounts" (59 FR 61488). This rule was intended to reduce the compliance burden associated with EPCRA section 313. It established a streamlined reporting option for facilities that manufacture, process, or otherwise use a TRI chemical in annual quantities of one million pounds or less and where the annual reportable amount of the chemical does not exceed 500 pounds. Under such circumstances the facility has the option of filing a two-page certification statement known as a "Form A" instead of the longer Form R (40 CFR 372.27). Completion of the Form A certifies that the facility is not required to file a Form R for the chemical because the facility did not exceed 500 pounds for the total annual reportable amount for that chemical, and that their amounts manufactured, processed, or otherwise used did not exceed one million pounds. EPA has excluded certain TRI chemicals that are of special concern (see Section 1.2.8) from Form A eligibility.
Executive Orders
On August 3, 1993, Executive Order 12856, "Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements" (58 FR 41981), was signed by the President. The Executive Order required federal facilities to comply with EPCRA requirements beginning with the 1994-reporting year. The Executive Order also asked all federal agencies to set a voluntary goal of 50% reduction from baseline quantities of their releases and transfers by 1999. Subsequent Executive Orders have not changed this requirement.
Changes to the List of Industries
On May 1, 1997, EPA added facilities in seven industry groups to the list of facilities subject to the reporting requirements of section 313 (62 FR 23833). The first reports from these facilities were required to be submitted by July 1, 1999 for the calendar year 1998. Prior to this action, reporting was limited to facilities in the manufacturing section (Standard Industry Classification codes 20-39) and federal facilities. This action added facilities in the following sectors:
 Metal mining,
 Coal mining,
 Electric utilities,
 Commercial hazardous waste treatment, storage, and disposal facilities,
 Chemicals and allied products-wholesale,
 Petroleum bulk terminals and plants-wholesale, and
 Solvent recovery services.

In November 2021, EPA announced the addition of natural gas processing facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of section 313 (86 FR 66953).
In December 2021, EPA announced the extension of the TRI reporting requirements to certain contract sterilization facilities under its discretionary authority through EPCRA 313(b)(2) (86 FR 73764). Pursuant to this authority, EPA determined there is a need to extend the reporting requirements for ethylene oxide releases and other waste management activities to 29 contract sterilization facilities; 16 of those facilities must also report for ethylene glycol activities.
Changes for Chemicals of Special Concern
On October 29, 1999, EPA published a final rule that lowered the reporting thresholds to 10 or 100 pounds for certain TRI chemicals (persistent, bioaccumulative, and toxic chemicals, or PBT chemicals) that are of special concern (64 FR 58666). In the same rule, EPA also added to the section 313 list of toxic chemicals certain PBT chemicals that were not already listed, including a dioxin category with a reporting threshold of 0.1 grams. Additionally, this rulemaking also included other changes to PBT chemical reporting, such as disallowing the use of the de minimis exemption, range reporting, and Form A for PBT chemicals (40 CFR § 372.28(b)). On January 17, 2001, EPA published a final rule that designated lead and its compounds as PBTs, lowered the reporting threshold for these chemicals to 100 pounds, and applied the same limitations that are applied to other PBT chemicals (40 CFR §372.28).
Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Rule
On June 6, 2006 (71 FR 32464), EPA published a final rule requiring facilities reporting to TRI to use North American Industry Classification System (NAICS) codes in place of the Standard Industry Classification (SIC) codes previously used on TRI reporting forms. This rule required facilities that report to TRI to use 2002 NAICS codes on reporting Form R and the Form A Certification Statement. The 2007 NAICS Revision Final Rule published on June 9, 2008, required facilities to use 2007 NAICS codes on TRI reporting forms. NAICS reporting requirements were revised most recently on December 26, 2017. Under the 2017 NAICS Revision Final Rule, facilities are required to use 2017 NAICS codes when submitting forms for reporting years 2017 and beyond.
TRI Dioxin and Dioxin-like Compounds Toxic Equivalency (TEQ) Information Rule
On May 10, 2007 (72 FR 26544), the Toxics Release Inventory Program issued a final rule expanding reporting requirements for the dioxin and dioxin-like compounds category. There are seventeen distinct members of this chemical category that are included on the EPCRA section 313 list of toxic chemicals. The final rule requires that, in addition to the total grams released for the entire category, facilities must report the quantity for each individual member on a new Form R schedule 1. EPA will then use the individual mass quantity data to calculate TEQ values for that will be made available to the public along with the mass data. The final rule also removes the requirement to report the single distribution of compounds in the category.
Defining the Reporting Requirements for Facility Parent Company Information
TRI requires facilities to report their highest-level United States-based parent company information annually in Part I, Section 5. There previously was no codified definition of this data field in 40 CFR part 372, and available guidance led to differing interpretations on the definition of parent company between EPA and reporting facilities. Facilities relied on the following guidance in the TRI Reporting Forms and Instructions when determining the appropriate parent company:
      "Your parent company is the highest-level company, located in the United States, and that directly owns at least 50 percent of the voting stock of [the facility's] company.... [A] facility that is a 50:50 joint venture is its own parent company. When a facility is owned by more than one company and none of the facility owners directly owns at least 50 percent of its voting stock, the facility should provide the name of the parent company of either the facility operator or the owner with the largest ownership interest in the facility."
Each year, EPA standardizes parent company names submitted to TRI. This process involves aligning submissions to a set of business rules (e.g., Corporation is changed to Corp) in addition to researching submitted names to ensure accurate reporting by using online sources and other datasets. Parent company name standardization provides benefits to EPA as well as public data users. Each year, EPA has needed to standardize at least 15 percent of the forms received.
After identifying suggested changes to the submitted parent company name, EPA contacts these facilities to inform them of plans to use the standardized name rather than the submitted name. This correspondence allows the facility to dispute the change and provide an explanation for their submission.
Through the parent company name standardization and subsequent correspondence with facilities, EPA identified various causes for misreporting of parent company information to TRI:
 Facilities with several levels of ownership that misinterpret the use of the word "directly" in the parent company reporting guidance to mean the company that directly owns the facility, which may be the subsidiary of a higher-level company based in the United States
 Facilities whose highest-level parent company is based outside of the United States and report an international company as the highest-level company, often while not knowing the highest-level U.S.-based parent company
In addition, there are several company ownership scenarios where existing guidance does not explicitly address how to report the parent company:
 Facilities with multiple owners and no owner with at least 50 percent of voting stock
 Companies that own multiple facilities that report to TRI but have no parent company
 Facilities that are publicly-owned (e.g., municipal power plants)
On September 28, 2021, EPA proposed a rule to define and clarify reporting requirements for facility parent company information (86 FR 53577). There were three options considered as possible scenarios under the proposed rule:
 Option 1: Parent company definition is codified and included in the Reporting Forms and Instructions (RFI). This would include reporting the highest-level U.S.-based parent company the current data elements under Part I, Section 5.1 and its Dun & Bradstreet Number in Part I, Section 5.2.
 Option 2: Option 1, plus including instructions for how to report a foreign parent company in Part I, Section 5.1 and its Dun & Bradstreet Number in Part I, Section 5.2 instead of the highest-level U.S.-based parent company.
 Option 3: Combination of Options 1 and 2, which would both codify reporting the highest-level U.S.-based parent company and add two new data elements similar to Part I, Sections 5.1 and 5.2 for reporting the name of a foreign company and its Dun & Bradstreet number in addition to reporting the largest U.S.-based parent company.
EPA is finalizing Option 3 in this rule, to codify the definition of "parent company" and require facilities to report both their U.S.-based parent company and foreign parent company and their Dun & Bradstreet numbers, when applicable.
Organization of This Report
This report examines the potential impact to industry and the Agency of the rule for defining reporting requirements for parent company information. Examination of the potential impacts for Options 1 and 2 may be found in the draft economic analysis for the proposed rule (U.S. Environmental Protection Agency, 2021) but are not further included here. The remainder of this report is organized as follows:
 Chapter 2: Estimated Number of Facilities and Forms Potentially Affected summarizes the expected number of facilities and forms affected by the rule.
 Chapter 3: Cost Estimates presents the methodology used to estimate costs, as well as the total incremental cost to industry and total incremental cost to EPA to define the reporting requirements for facility parent company information.
 Chapter 4: Small Entity Analysis examines the impacts of the rule, specifically those impacts on "small" entities as required by the Regulatory Flexibility Act of 1980.
 Chapter 5: Benefits evaluates the benefits of the rule.
 Chapter 6: Paperwork Reduction Act & Other Analyses reviews the impacts of this action under additional Executive Orders and statutes.
 Chapter 7: References provides references cited in this analysis.

 -  -  -  - Estimated Number of Facilities and Forms Potentially Affected
This chapter presents estimates of the number of additional forms and facilities that would result from the rule. These estimates are used to calculate the costs to the regulated community and to EPA (see Chapter 3) and to evaluate the impacts on small entities (see Chapter 4). The changes to parent company reporting requirements are not expected to change the total number of facilities reporting to TRI nor the number of forms (Form R or Form A) filed.
As described in Section 3, the rule will create a one-time rule familiarization burden for all facilities that are required to submit forms to TRI. Facilities will also incur ongoing incremental form completion burden associated with reporting an additional element on each TRI form, which is expected to be minimal when using the TRI reporting software, TRI-MEweb, and its ability to re-populate facility-level information from the previous reporting year, as well as applying facility-level information across all reporting forms from a single facility.
Reporting year (RY) 2020 data, shown in Table 2.1, are used to characterize the potentially affected facilities and forms. As such, an estimated 21,154 facilities and 76,815 forms are potentially affected by the rule.
Table 2.1 	Number of Facilities and Forms Reported to TRI in RY 2020

                                  Facilities
                                     Forms

                                    Form Rs
                                    Form As
                                    Total
Total Unique Number of Forms/Facilities
                                    21,154
                                    68,414
                                     8,401
                                    76,815
  Source: U.S. EPA (2022)

Cost Estimates
This chapter presents the estimated industry costs associated with the three options of the rule. Incremental industry burden and costs associated with the rule are estimated using ratio-based burden methodology (RBBM). RBBM is a simplification of the previous methodology used to estimate reporting burden and cost for TRI reporting (U.S. Environmental Protection Agency, 2011a). Section 3.1 describes the estimation of industry burden using RBBM. Section 3.2 describes the estimation of incremental industry cost using RBBM. Sections 3.3 and 3.4 present the resulting incremental industry burden and cost estimates. Section 3.5 presents annualized incremental industry costs.
Estimation of Burden
Facilities engage in a number of facility-level and form-level activities in order to comply with the EPCRA section 313 reporting requirements. In general, the set of compliance activities associated with TRI reporting includes the following:
Facility-Level
   Rule Familiarization: Facilities must read the reporting package and become familiar with the revised language and/or reporting requirements. As part of doing so, facility staff will be able to ascertain whether the facility is reporting parent company information accurately per the codified definition.
   Compliance Determination: Facility staff must determine whether the facility is reporting parent company information accurately per the codified definition. Under the rule, there is no incremental burden expected for Compliance Determination since facilities already know how they are currently reporting parent company information and whether that complies with the parent company information identified during Rule Familiarization.
   Non-Reporter Compliance Determination: In any given reporting year, a group of eligible facilities will complete compliance determination but will not file a Form R or a Form A. Given that the rule will not change any reporting requirements that might change the universe of eligible facilities, no non-reporter compliance determination is expected.
Form-Level
   Form Completion: Facilities must gather data to provide the information required on Reporting Form R or Reporting Form A. This activity includes the time required to search data sources for parent company information and complete and review the information.
   Recordkeeping and Submission: Affected facilities must maintain recordkeeping systems and submit their forms to EPA and the state in which the facility is located. This activity includes the time required to transmit or otherwise disclose the information. Under the rule, there is no incremental burden expected for Recordkeeping and Submission activities.
The skills required to comply with the section 313 reporting requirements (including the requirements associated with Section 6607 of the PPA) are expected to vary from facility to facility, depending upon factors such as: the complexity of the facility's processes and activities; the chemicals used at the facility; and the types of use and disposition of TRI chemicals at the facility. Individuals responsible for determining whether their facility is required to report and, if so, completing a Form R and Form A reports (or multiple Form R and Form A reports) often have an engineering, scientific, or technical background. These reporting determinations, however, do not require an engineering or other similar degree.
At a minimum, an understanding of the facility's chemical purchases and production processes are needed. Necessary skills may include the ability to evaluate and interpret records, understand safety data sheets, and determine throughput or production volumes. Depending on the facility, estimates may be calculated using: (1) existing data collected under federal, state, or local regulations; (2) emissions factors; (3) design data supplied by the equipment manufacturer; (4) mass balance techniques; or (5) engineering calculations. Each technique requires varying skills and levels of sophistication to complete. EPA industry- and chemical-specific guidance documents assist reporters in making the necessary calculations to comply with section 313 reporting requirements. In addition to technical labor, requirements for managerial and clerical staff are also considered when estimating burden and costs.
In this rule, all TRI reporters are expected to incur rule familiarization costs associated with reading and applying the new requirements. Additionally, all TRI reporters with foreign parent companies are required to submit additional information by either providing the foreign parent company name and its Dun & Bradstreet (D&B) Number or indicating not applicable).
Details about the estimated unit burden associated with each compliance activity are listed below and separated out by the three different options considered for the rule.
Rule Familiarization
For this rule, management and technical time are required in the first year. All burden estimates are accrued at the facility level. The burden is estimated to be five minutes management time and 25 minutes technical time for the first year. This assumption includes 20 minutes to read the rule (technical only) and five minutes to brief management (management and technical).
Facility staff are assumed to fully comprehend the rule and associated requirements by the subsequent year (i.e., 0 minutes for rule familiarization in steady state).
Form Completion
The rule adds two data elements to Part I, Section 5 for the foreign parent entity. Incremental reporting burden is calculated by addition of the same reporting burden in the RBBM as Part I, Sections 5.1 and 5.2. However, whereas management time is assumed to accrue per form during the review process, technical time for form completion is applied at the facility level since the same parent company information can be entered for all form submissions through the online submission portal (TRI-MEweb). Once parent company name data are entered, they remain in TRI-MEweb and are automatically populated for each form. The first-year burden is calculated using the RBBM as 0.16 minutes of management time per form and 20 minutes technical time per firm. Steady state burden only requires management time for reviewing purposes (0.16 minutes per form) since the information will already be recorded in TRI-MEweb.
Summary of Unit Burden Estimates
A summary of the estimated unit burdens associated with each activity, labor category, and period is presented in Table 3.1.
Table 3.1 	Estimated Unit Burden by Activity, Labor Category, and Period
                                   Activity
                                Labor Category
                            First-Year Burden (min)
                           Steady State Burden (min)
Rule Familiarization
(Per Facility)
Management
                                       5
                                       0

Technical
                                      25
                                       0

Clerical
                                       0
                                       0
Report Completion
(Per Facility)
Management
                                       0
                                       0

Technical
                                      20
                                       0

Clerical
                                       0
                                       0
Report Completion
(Per Form)
Management
                                     0.16
                                     0.16

Technical
                                       0
                                       0

Clerical
                                       0
                                       0
Total
(Per Facility)
Management
                                       5
                                       0

Technical
                                      45
                                       0

Clerical
                                       0
                                       0
Total
(Per Form)
Management
                                     0.16
                                     0.16

Technical
                                       0
                                       0

Clerical
                                       0
                                       0

Estimation of Cost
To estimate total reporting cost, RBBM uses the Weighted Average Wage Rate (WAWR), which is the average loaded cost for a combination of Managerial, Technical, and Clerical labor per hour of TRI reporting burden. WAWR is based on the total cost to employ an individual and includes the cost of salaries, fringe benefits (e.g., paid leave), health insurance, retirement savings, legally required benefits, and other overhead costs, such as office space, furniture, equipment and computers, supplies, and other business expenses.
According to feedback from existing TRI filers, the role of each labor category in the TRI reporting process at the facility level is as follows:
 Managerial staff are responsible for reviewing and certifying the accuracy of all TRI submissions and supporting documentation, including calculations, data sources, and assumptions. Managerial staff are briefed by technical staff once annually regarding TRI submissions and any changes to TRI reporting requirements. All sections of the Form are reviewed by managerial staff at this time.
 Technical staff possess the facility knowledge and familiarity with the TRI program required to understand which processes and activities at the facility should be considered in making threshold determinations for TRI chemicals. Technical staff gather the required data, make threshold determinations, calculate release and waste management quantities, and enter the required data on the TRI form, either by hand or electronically using TRI reporting software. Technical staff are also responsible for briefing managerial staff once annually regarding TRI submissions and any changes to TRI reporting requirements.
 Clerical staff are responsible for organizing, photocopying, and cataloging all TRI submissions and supporting documentation in accordance with TRI recordkeeping requirements. Note that as reporting facilities are predominantly filing TRI reports electronically, clerical time is minimized.
WAWR is calculated using data from the Bureau of Labor Statistics on "Wages and Salaries" and "Total Benefits" for three labor categories: Managerial (the "Management, Business, and Financial" occupational category), Technical (the "Professional and Related" occupational category), and Clerical (the "Office and Administrative Support" occupational category) (U.S. Bureau of Labor Statistics, 2022). Total Compensation is equal to the sum of Wages and Salaries and Total Benefits. EPA's guidelines suggest using an overhead multiplier of 20% applied to a wage rate already loaded with fringe benefits, based on industry- and occupation-specific overhead rates affected by EPA regulations in previous EPA regulatory impact analyses (U.S. Environmental Protection Agency, 2020). The sum of Total Compensation and Overhead is equal to the Total Loaded Hourly Wage Rate. The Total Loaded Hourly Wage Rates for these labor categories are weighted by the relative contribution of each labor category to TRI reporting activities derived from Engineering Studies conducted by Abt Associates (Abt Associates Inc., 2004). The calculation of WAWR is shown in Equation 3-1.
--------------------------------------------------------------------------------
Equation 3-1: Weighted Average Wage Rate Calculation
--------------------------------------------------------------------------------
WAWR=wManagerialxpManagerial+wTechnicalxpTechnical+wClericalxpClerical
--------------------------------------------------------------------------------
Where:
	wi = Total Loaded Hourly Wage Rate for labor category i, given by the formula:
	Total Loaded Hourly Wage Rate = Wages and Salaries + Total Benefits + (20% x (Wages and Salaries +    	Total Benefits))
	pi = Proportion of overall reporting burden borne by labor category i
As shown in Table 3.2, WAWR is equal to $69.51 (in 2021 dollars).
Table 3.2 	Derivation of Weighted Average Wage Rate (2021 Dollars)
                                   Wage Type
                                  Managerial
                                   Technical
                                   Clerical
Wages and Salaries
                                    $51.32
                                    $40.73
                                    $20.29
Total Benefits
                                    $23.72
                                    $19.11
                                     $9.65
Overhead
                                    $15.01
                                    $11.97
                                     $5.99
Total Loaded Hourly Wage Rate
                                    $90.05
                                    $71.81
                                    $35.93
Labor Burden Weights
                                     0.03
                                     0.89
                                     0.08
Weighted Average Wage Rate (WAWR)
                                   $69.51[a]
[a] Individual numbers may not add to the total due to rounding.
First Year Total Cost and Steady State Total Cost are calculated by multiplying the relevant total burden by WAWR.
Total Incremental Industry Burden Estimates
Total industry burden is calculated by aggregating the unit burdens across all facilities and forms in the affected universe, as presented in Table 3.3.
Table 3.3 	Estimated Total Incremental Burden by Activity
                                   Activity
                           First-Year Burden (hours)
                          Steady State Burden (hours)
Rule Familiarization
                                    10,577
                                       0
Form Completion
                                     7,256
                                      205
Total
                                    17,833
                                      205

Under this rule, industry is estimated to incur between approximately 17,833 burden hours in the first year and between approximately 205 burden hours in the steady state.
Total Incremental Industry Cost Estimates
To estimate the incremental cost of the rule, total first-year and total steady state industry incremental reporting burden is multiplied by the WAWR. The first-year and steady state incremental costs are presented in Table 3.4.
Table 3.4 	Estimated Total Incremental Cost by Activity
                                   Activity
                                First-Year Cost
                               Steady State Cost
Rule Familiarization
                                                                       $735,207
                                                                             $0
Form Completion
                                                                       $504,365
                                                                        $14,238
Total
                                                                     $1,239,572
                                                                        $14,238

Under the rule, industry is estimated to incur incremental costs of approximately $1,240,000 in the first year and approximately $14,000 in the steady state.
Annualized Incremental Cost Estimates
The total incremental cost to industry associated with the rule is annualized over a ten-year period using Equation 3-2 below.
--------------------------------------------------------------------------------
Equation 3-2: Cost Annualization
--------------------------------------------------------------------------------
Annualized Cost=Present Value of Costs x r x 1+r101+r10-1
--------------------------------------------------------------------------------
Where:
	Present Value of Costs=t=1t=10Costtx11+rt
	and r = 3% or 7%
Ten years is assumed to be a reasonable timeframe for annualization, as approximately 50 percent of TRI facilities reported every year from reporting year 2011 to reporting year 2020. The annualized cost reflects both the first-year costs and steady state costs presented in Section 3.4. Industry costs are annualized both at a 3% discount rate and a 7% discount rate for the lower and upper bound estimates, resulting in total annualized costs of $160,338 (under 3% discounting) and $194,732 (under 7% discounting). Total annualized industry costs are presented in Table 3.5.
Table 3.5 	Annualized Total Incremental Industry Cost
                             Annualized Cost (3%)
                             Annualized Cost (7%)
                                   $160,338
                                   $194,732

Small Entity Analysis
This chapter addresses the potential impacts of the rule on small entities. Section 4.1 discusses the regulatory requirement for this analysis. Section 4.2 provides the definition of small entities for the industry groups affected by the rule. Section 4.3 describes the methodology used to determine if the rule results in a significant economic impact to a substantial number of small entities. Section 4.4 uses this methodology to estimate the impacts of the rule on small businesses, and Section 4.5 uses the methodology to estimate the impacts of the rule on small government jurisdictions. The results of the small entity analysis are summarized in Section 4.6.
Impact on Small Entities
The Regulatory Flexibility Act (RFA) of 1980 (5 U.S.C. § 601 et. seq.) requires federal agencies to assess the effects of regulations on small entities, including businesses, nonprofit organizations, and governments, and, in some instances, to examine alternatives to the regulations that may reduce adverse economic effects on significantly impacted small entities. Section 604 of the RFA, as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996, requires an agency to perform a regulatory flexibility analysis for a rule unless the agency certifies under section 605(b) that the regulatory action would not have a significant economic impact on a substantial number of small entities. The RFA does not specifically define "a significant economic impact on a substantial number" of small entities.
Definitions of Small Entities
The RFA uses the definition of a "small business" found in the Small Business Act, which authorizes the Small Business Administration (SBA) to define "small business" by regulation. This analysis uses the SBA's definition of a small business for the industry affected by the rule (U.S. Small Business Administration, 2022). SBA's small business size definitions vary by industry. In establishing size standards, SBA considers a number of economic and market characteristics that may allow a business of concern to exercise dominance in an industry. Size standards are based on criteria -- such as annual receipts or number of employees -- that represent a measure of these characteristics. These standards represent the largest size that a for-profit enterprise (together with its affiliates) may be and still qualify as a small business.
The SBA small business size standards are expansive, classifying most businesses as "small" (U.S. Small Business Administration, 2022). For example, the smallest SBA size standard for manufacturing industries (NAICS 31-33) is 500 employees. According to the U.S. Census Bureau's Statistics of U.S. Businesses, 246,034 of 252,782 manufacturing firms have fewer than 500 employees (U.S. Census Bureau, 2021). Therefore, at least 97.3 percent of manufacturing firms are classified as a small business according to the SBA definition.
The RFA defines a "small governmental jurisdiction" as the governments of a city, county, town, school district, or special district with a population of less than 50,000 people.
Collectively, this analysis refers to small businesses and small governmental jurisdictions as small entities. The small entity definitions relevant to this rule are:
 Businesses, where the small entity definition is based on annual receipts or number of employees; and
 Government jurisdictions, where the small entity definition is based on population.
A third class of small entities defined by the RFA, not-for-profit organizations, is not impacted by this rulemaking and is not considered further.
Methodology Overview
This analysis uses annualized cost impact percentages to measure potential impacts on small parent entities that own facilities affected by the rule. The annualized cost impact percentage is defined as annualized compliance costs resulting from the rule as a percentage of annual revenues or sales, a commonly available and objective measure of a company's business volume.
The compliance costs associated with the rule in the first year include the costs of rule familiarization and form completion. In the steady state, the compliance costs associated with the rule are limited to form completion (see Chapter 3). Table 4.1 presents the compliance costs associated with each of the individual components of the total costs (e.g., the cost associated with rule familiarization) incurred, and then aggregates these costs to calculate the total compliance cost for a facility potentially affected under the rule.
Table 4.1 	Per-Facility Compliance Costs Incurred under the Rule
                                   Activity
                                First-Year Cost
                               Steady State Cost
Rule Familiarization
                                    $34.76
                                     $0.00
Form Completion
                                    $23.84
                                     $0.67
Total
                                    $58.60
                                     $0.67

The compliance costs are annualized over a ten-year time period at a three and seven percent discount rate, as discussed in Chapter 3. The annualized compliance costs are shown in Table 4.2.
Table 4.2 	Annualized Per-Facility Compliance Costs (2020 Dollars)
                             Annualized Cost (3%)
                             Annualized Cost (7%)
                                     $7.58
                                     $9.21

The rule affects many industry sectors (i.e., NAICS codes) as well as several government jurisdictions. This small entity analysis considers facilities in all of the industry sectors that reported to TRI in RY 2020. In RY 2020, facilities in a total of 425 NAICS code industry subsectors reported to TRI (U.S. Environmental Protection Agency, 2022). It should be noted that industry information is only available at the facility level; the information reported to TRI does not indicate the NAICS code of the parent company. For this reason, this analysis assumes that the NAICS code reported by each TRI facility in RY 2020 is also the NAICS code of its parent.
Employment and revenue data available for each of these 6-digit NAICS code subsectors vary, but are categorized into the general categories presented in Table 4.3 for the purpose of this analysis. The categories were developed based on the small business definition in Section 4.2 and data sources used. Category #1 includes all privately-owned facilities in NAICS codes for which employment and revenue data are readily available from the U.S. Census Statistics of U.S. Businesses (SUSB). Category #2 is government jurisdictions, where the small business threshold is defined in terms of population and data from the U.S. Census of Governments was used to estimate revenue (see Section 4.5.1 for more information on how these facilities were identified). Each year, some facilities in sectors outside of TRI-reporting requirements voluntarily submit TRI reporting forms, most significantly from the agricultural sector (NAICS 11). These facilities are grouped together in Category #3 and are not considered in this analysis, even if SUSB data were available for the NAICS code.
Table 4.3 	Categorization of Facility Types Affected by Rule
                                Category Number
                             Category Description
                       Number of Facilities in Category
                                       1
Privately-owned facilities
                                    20,625
                                       2
Government-owned facilities
                                      520
                                       3
Facilities outside of TRI-reporting requirements
                                       9
Total Number of TRI Facilities
                                    21,154

The general methodology used to estimate impacts on small entities consists of the following steps:
 Step 1: Identify the universe of affected TRI facilities.
 Step 2: Characterize the relationships between facilities and their ultimate parent entities.
 Step 3: Identify small parent entities based on SBA or RFA definitions (see Section 4.2).
 Step 4: Estimate annual revenues of parent entities.
 Step 5: Develop parent entity annualized compliance cost estimates (at three percent and seven percent discount rates), based on the number of facilities per parent estimated in Step 2.
 Step 6: Calculate the entity-level impact percentages, defined as annualized compliance costs as a percentage of annual revenues, to measure regulatory burden.
 Step 7: Estimate the number and percentage of small parent entities with entity-level impact percentages in each of three categories: (1) less than one percent of annual revenues; (2) between one and three percent of annual revenues; and (3) greater than or equal to three percent of annual revenues.
The specific assumptions and calculations used to estimate impacts for each category of facilities are described in more detail in the sections that follow. Section 4.4 considers the impacts of the rule on small businesses in sectors for which information is available from the 2017 SUSB. Potential impacts of the final rule on small governmental jurisdictions are considered in Section 4.5, based on the Census of Governments data related to government organizations, finances, and employment.
Impacts on Small Businesses
The vast majority of TRI reporting facilities are privately-owned and operate in sectors with revenue and employment data available from the SUSB. Potential small parent entities can be identified by matching the relevant employment or revenue data from SUSB with the small business definitions relevant to each 6-digit NAICS code included in the TRI reporting data. All TRI-covered NAICS codes for privately-owned facilities were matched with SUSB data at the 6-digit NAICS code. The sectors relevant to privately-owned TRI facilities with data available from SUSB are summarized in Table 4.4.
Table 4.4 	Sectors with Revenue and Employment Information in SUSB for Privately-Owned TRI Facilities
                                 2-Digit NAICS
                               NAICS Description
                        Number of 6-Digit NAICS Codes
                                      21
Mining, Quarrying, and Oil and Gas Extraction
                                      17
                                      22
Utilities
                                       7
                                      23
Construction
                                       2
                                     31-33
Manufacturing
                                      340
                                      42
Wholesale Trade
                                      10
                                     44-45
Retail Trade
                                       1
                                     48-49
Transportation and Warehousing
                                       5
                                      51
Information
                                       1
                                      54
Professional, Scientific, and Technical Services
                                       1
                                      56
Administrative and Support and Waste Management and Remediation Services
                                       8
                                      81
Other Services (Except Public Administration)
                                       3
Total Number of TRI-Covered 6-Digit NAICS Codes with Information in SUSB
                                      395
Source: U.S. EPA (2022)
The SUSB provides annual data for U.S. business establishments by geography, industry, and enterprise size, covering all business establishments with paid employees. The data provided annually includes counts of establishments, firms, employees, and payroll. Data about total receipts are also provided by SUSB every five years. The data available from the SUSB can therefore be used to identify the number of small parent entities affected under the final rule, construct annual revenue estimates, and calculate cost impact ratios.
A 6-digit NAICS code sector's small business definition is based on either its annual revenue or the number of its employees, depending on the sector. The SUSB provides information tabulated by employment size or revenue size. For those sectors with revenue-based small business definitions, profiles were developed for each revenue size category. For sectors with employment-based small business definitions, profiles were developed for employment size categories.
Identify Universe of Affected TRI Facilities
The NAICS code of each affected TRI facility is known based on its RY 2020 submission. Note that if a facility reported multiple NAICS codes (e.g., a facility includes multiple establishments that fall within different NAICS codes), the first NAICS code is used in this analysis. In some cases, facilities submitted NAICS codes that were invalid at the 6-digit level (e.g., 311000). In these cases, the analysis considers the facility at the most applicable NAICS level (e.g., 311). Based on information submitted by TRI filers, 20,625 facilities reported to TRI in RY 2020 from the 395 6-digit NAICS codes with data in SUSB. The distribution of these facilities across NAICS codes is shown at the 2-digit level in Table 4.5.
Table 4.5 	Universe of Affected TRI Facilities in Sectors with Data in SUSB
                                 2-Digit NAICS
                               NAICS Description
                             Number of Facilities
                                      21
Mining, Quarrying, and Oil and Gas Extraction
                                      151
                                      22
Utilities
                                      339
                                      23
Construction
                                       3
                                     31-33
Manufacturing
                                    18,934
                                      42
Wholesale Trade
                                      968
                                     44-45
Retail Trade
                                       1
                                     48-49
Transportation and Warehousing
                                       8
                                      51
Information
                                       1
                                      54
Professional, Scientific, and Technical Services
                                       3
                                      56
Administrative and Support and Waste Management and Remediation Services
                                      211
                                      81
Other Services (Except Public Administration)
                                       6
Total Number of TRI Facilities in Sectors with Information in SUSB
                                    20,592
Source: U.S. EPA (2022)
Characterize Facility-Parent Relationships
For this analysis, compliance costs and impacts are estimated at the parent entity level, where a parent entity may own one or more facilities. The average number of facilities filing reports to TRI per parent company for the TRI sectors with information in SUSB is estimated by taking the average of the number of RY 2020 reporters associated with each parent company with a facility in that sector. Note that a single average of number of facilities per parent is used for each sector. The average number of facilities per parent in each sector is used to calculate the number of parent entities of the facilities presented in Table 4.5 above. Because it is not possible to distinguish small parents from large parents in the TRI data, these averages are estimated using large parent companies as well as small. Thus, they are likely to overestimate the number of facilities per small parent entity, which will result in estimates of the cost to small parent companies that are conservative (i.e., since large parent companies are also included and tend to own more facilities, the estimated average number of facilities for small parent companies is likely larger than the actual number and will lead to an overestimate of the compliance costs).  Based on the RY 2020 data, there are 8,524 unique parent companies.[,]
Estimate Number of Small Parent Entities
EPA estimates the number of small parent entities in each NAICS code by distributing the total number of TRI facilities in each NAICS code among the employment or revenue size classes based on the overall distribution of establishments among the size classes in the SUSB data. For example, in NAICS 325180: Other Basic Inorganic Chemical Manufacturing, approximately 83% of firms in SUSB meet the SBA definition for a small business (less than 1,000 employees). Applying this rate to 315 facilities in NAICS 325180 for RY 2020 results in 261 facilities estimated to be owned by small entities.
Next, the average number of TRI facilities per parent company in a NAICS code is determined. For each six-digit NAICS code, total number of facilities was divided by the count of unique parent companies. Using the NAICS 325180 example, 169 unique parent entities were identified among the 315 total facilities, resulting in an average of 1.86 facilities per small parent entity.
In order to obtain a count of small parent entities by NAICS code, the total number of TRI facilities owned by small entities is divided by the average number of TRI facilities per parent in that NAICS code. Continuing with the NAICS 325180 example, the 261 TRI facilities owned by small entities is divided by 1.86 facilities per small parent entity, yielding an estimated 140 small parent entities. Applying this method for all NAICS codes and summing the results yields a total of 7,653 small parent entities that will be potentially affected by the rule.
Estimate Annual Revenue of Parent Entities
The SUSB data include the total annual receipts (defined as the revenue for goods produced, distributed, or services provided) for each NAICS/revenue or employment size class combination. For each of the 395 TRI sectors with data in SUSB, EPA calculates average revenue per small entity using the appropriate employment size or revenue tabulation. To do this, the total revenue and total number of firms are summed across all small revenue or employment size classes for each NAICS code. The total revenue of all small revenue or employment size classes is then divided by the number of small firms in each size class to calculate an average revenue per small firm by 6-digit NAICS code.[,]  The total revenue of all small revenue or employment size classes is then divided by the number of small firms in each size class to calculate an average revenue per small firm by 6-digit NAICS code.
Because the SUSB data reflect 2017 annual revenue, it was necessary to inflate the revenue to current dollars using the GDP inflation index (U.S. Bureau of Economic Analysis, 2022).
Estimate of Parent Entity Compliance Costs
Affected parent entities will incur the annualized cost for each TRI facility they own. Therefore, the annualized per-facility compliance cost is multiplied by the average number of facilities per parent to calculate the total annualized per parent compliance cost for each NAICS code affected under the rule. For small parent entities that own only one affected facility, the largest possible annualized parent entity compliance cost is $9.21 assuming a 7 percent discount rate under Option 3. Under the same framework, the cost for a small parent entity owning multiple affected facilities would be a multiple of $9.21 assuming a 7 percent discount rate.
Estimate of Cost Impact Percentages
Cost impact percentages for small parent entities are calculated by dividing annualized parent entity compliance costs by the average parent entity's annual revenue in each NAICS code. The estimated impacts on small parent entities using a 3% and 7% discount rate are presented in Table 4.6. Based on the calculations, no small parent entity is expected to incur an impact of greater than 1% of annual revenue. The largest cost impact percentage is 0.01325% for small parent entities in NAICS 562112 (Solid Waste Landfill).
Table 4.6 	Estimated Impact of the Rule on Small Parent Entities for Privately-Owned Facilities
                                  Facilities
                                Parent Entities
                             Small Parent Entities
                                 Discount Rate
           Number of Small Parent Entities by Cost Impact Percentage

                                    < 1%
                                   1% to 3%
                                    > 3%
                                    20,625
                                     8,524
                                     7,653
                                   3 Percent
                                     7,653
                                       0
                                       0

                                   7 Percent
                                     7,653
                                       0
                                       0

Impacts on Small Governmental Jurisdictions
As noted previously, the RFA defines small government jurisdictions as governments that serve a population of less than 50,000 people. A separate methodology based on information from the U.S. Census of Governments (U.S. Census Bureau, 2005) is used to estimate the potential impacts of the rule on small government parent entities. The sections that follow discuss the method used to calculate the impacts on small government jurisdictions that own TRI facilities.
Identify Universe of Affected TRI Facilities
TRI facilities potentially owned by government entities were identified based on the following reported RY 2020 TRI data elements:
 categorized under 2-digit NAICS codes 92 (public administration) or 22 (utilities),
 were flagged as federal agencies,
 had facility or parent names containing one of the following key words: "public", "authority", "department", "municipal", "board", "city of", "county", "station", or "plant."
In total, 927 TRI facilities met one or more of these criteria, and were then manually reviewed to determine whether they were owned by government entities. Our review identified 520 TRI facilities that are government-owned at the federal, state, or municipal level (see Table 4.7).
Table 4.7 	Count of Government-Owned RY 2020 TRI Facilities by Jurisdiction Level
                              Jurisdiction Level
                             Number of Facilities
Federal
                                      466
State
                                      20
Municipal
                                      34
Total
                                      520

The facilities owned by the federal or a state government do not meet the definition of a small government jurisdiction as they serve a population of greater than 50,000 people and are excluded from this analysis. The remaining 34 facilities are owned by municipal governments and may meet the definition for small government jurisdictions.
Characterize Facility-Parent Relationships
Compliance costs are estimated at the parent entity level, where a parent entity may own one or more facilities. Therefore, it is necessary to consider municipalities owning multiple TRI facilities. Because the universe of TRI facilities owned by municipalities is based on a unique list of facilities matched to individual municipal governments, it is possible to determine the number of TRI facilities owned by each municipality and calculate the number of facilities per parent based on the known number of facilities owned by each municipality. A total of 29 unique municipalities were identified as owning the 34 facilities.
Estimate the Number of Small Parent Entities
To determine which government entities owning TRI facilities meet the definition of small government jurisdictions, the 29 unique municipalities were matched to a government on the Census of Governments list of municipalities. Any government owning a TRI facility serving a population of 50,000 or fewer based on the 2020 population was considered to be a small parent entity. In total, 16 municipalities of the 29 affected municipalities were identified as meeting the definition for small governmental jurisdictions.
Estimate Annual Revenue of Small Parent Entities
Because the most recent Census of Governments data does not provide revenue data for individual municipalities, it is necessary to develop a method to estimate revenue based on available information. The Government Finance series in the 2002 Census of Governments provides information at the state level regarding the per capita revenue of municipalities by population-size range (U.S. Census Bureau, 2005).
To estimate the annual revenue for each affected municipality, the inflated per capita revenue is multiplied by the population of the municipality. Population information was obtained from the U.S. Census 2020 Population Estimates (U.S. Census Bureau, 2022).
Note that the 2002 Census of Governments per capita revenues must be inflated to 2021 dollars. The Gross Domestic Product (GDP) inflation index, which is a measure of overall economic output, is used to inflate 2002 revenue to 2021 dollars. Note that this method may overstate current revenue because the GDP is a measure of overall economic output and does not correlate directly to government revenue.
Estimate Small Parent Entity Compliance Costs
All 16 small municipalities would be impacted by the rule. Affected parent entities will incur the annualized compliance cost once for each TRI facility they own. Therefore, the annualized per-facility compliance cost was multiplied by the number of facilities owned by each municipality to calculate the total annualized compliance cost for each parent entity affected under the rule. This calculation is performed at a 3% and 7% discount rate.
Estimate Cost Impact Percentages
The cost impact ratios for small municipalities are estimated by dividing the total annualized compliance cost for that entity by the annual revenue of the municipality. Based on this calculation, no small municipality is expected to incur an impact of greater than 1% of annual revenue. These results are summarized in Table 4.8. The largest cost impact percentage is 0.0046%, estimated for the city of Trenton, MO. Because the impact incurred by any small municipality is less than 1%, there is likely no significant impact to any small municipality.
Table 4.8 	Estimated Impact of Rule on Small Government Jurisdictions
                                  Facilities
                           Government Jurisdictions
                        Small Government Jurisdictions
                                 Discount Rate
      Number of Small Government Jurisdictions by Cost Impact Percentage

                                    < 1%
                                   1% to 3%
                                    > 3%
                                      34
                                      29
                                      16
                                   3 Percent
                                      16
                                       0
                                       0

                                   7 Percent
                                      16
                                       0
                                       0

Summary of Small Entity Impacts
This chapter estimates small entity impacts for small businesses in sectors for which information is available from the 2017 U.S. Census Statistics of U.S. Businesses (SUSB), as well as data from the 2002 Census of Governments for small governmental jurisdictions. Based on the results of the small entity analysis, as shown in Table 4.9, no entities are expected to incur a cost impact of 1% or greater associated with the annualized compliance costs resulting from the final rule.
Table 4.9 	Summary of Small Entity Analysis Results
                                  Facilities
                                Parent Entities
                             Small Parent Entities
                                 Discount Rate
           Number of Small Parent Entities by Cost Impact Percentage

                                    < 1%
                                   1% to 3%
                                    > 3%
                                    21,145
                                     8,571
                                     7,669
                                   3 Percent
                                     7,669
                                       0
                                       0

                                   7 Percent
                                     7,669
                                       0
                                       0
Note: nine facilities reported NAICS codes not required for TRI reporting and were not included in the small entity analysis.

Benefits
In enacting EPCRA and the PPA, Congress recognized the significant benefits of providing information on the presence, releases, and waste management of toxic chemicals. The TRI program has proven to be one of the most powerful forces in empowering the federal government, state and local government, industry, environmental groups, and the general public to fully participate in an informed dialogue about the environmental impacts of toxic chemicals in the United States. The TRI database provides several types of information, including quantitative information on toxic chemical releases and other waste management practices. Starting in 1987, the collection of this information enhanced the ability for the public, government, and the regulated community to understand the breadth and magnitude of chemical releases in the United States, and to assess the need to reduce the releases and transfers of toxic chemicals. TRI data enable all interested parties to establish credible baselines, to set realistic goals for environmental progress, and to measure progress in meeting these goals over time. As such, the TRI program has become a yardstick by which progress can be measured by all interested or affected stakeholders.
The information reported to TRI increases community knowledge and awareness of quantities of toxic chemicals released to the environment, and potential pathways of exposure to those chemicals. This knowledge:
 Improves scientific understanding of the health and environmental risks of toxic chemicals;
 Allows the public to make informed decisions on where to work and live;
 Enhances the ability of corporate leaders and purchasers to more accurately gauge a facility's potential environmental liabilities;
 Provides reporting facilities with information that can be used to save money as well as reduce emissions; and
 Assists federal, state, and local authorities in making better decisions on acceptable levels of toxic chemicals in the environment.
The benefits of the rule include reduced confusion and level of effort for facilities when determining and the parent company name for their TRI reporting. A codified definition will explicitly address facilities owned by public entities and scenarios where facilities are owned by subsidiaries or divisions of larger corporations or multiple owners, including any foreign ownership. In addition, this rule will reduce EPA's level of effort needed to standardize the submitted parent company names each reporting year. A clear, legally defensible definition of parent company will allow EPA to provide specific guidance to facilities that have previously misinterpreted the definition. The resulting standardized parent information will benefit data users as it will more clearly indicate ultimate facility ownership, better allowing data users to examine data at the parent company-level. The resulting parent company information for TRI will also better align with other EPA reporting programs (e.g., Chemical Data Reporting and Greenhouse Gas Reporting Program).
Making TRI information available to the public may provide incentives for facilities to reduce TRI chemical releases. For example, the public availability of release information aggregated at the parent company level may induce parent companies to encourage facilities to reduce TRI chemical usage or releases when such information present in the public domain would not be in the parent company's interest. Potential social benefits derived from voluntary follow-on activities include decreased costs of waste treatment and disposal, lower probability of accidental releases and lower clean-up costs in the event of such releases, reduced contamination of natural resources, improved air and water quality, and reduced risks to human health. Such social benefits are partially offset by the potential social costs of voluntary follow-on activities, such as transitions to energy-intensive waste treatment solutions (e.g., flare gas treatment) or substitutions to non-TRI chemicals with comparable hazard to human or environmental health. The net social benefits of the information provided by the rule and the possible follow-on activities equal the difference between the total benefits and the total costs of the activities.
The potential benefits of additional TRI reporting can be understood by examining the ways in which different groups of affected stakeholders -- consumers, industry, governments, and the general public -- use TRI data. Non-federal governments may use the data in lieu of, or in support of, their own environmental protection activities. The general public may use the data to make more informed decisions about where they work and live and to enter into constructive dialogue with facilities in their communities. Non-users of the TRI data benefit from its public provision whenever others' use of the data results in improvements in environmental quality.
Some examples of the ways in which various stakeholders have utilized TRI data include:
 Use of the Data by Community and Public Interest Groups: Communities use TRI data to begin dialogues with local facilities and to encourage them to reduce their emissions, develop pollution prevention plans, and improve safety measures. Public interest groups use the data to educate the public about toxic chemical emissions and potential risks, and in environmental justice activities.
 Use of the Data by Education and Research Institutions: TRI data are being used in many environmental education programs, particularly at the high school and university levels. Students learn about toxic chemical releases, the potential health and environmental effects of those releases, pollution prevention activities and opportunities, and the social and political aspects of environmental protection. Some organizations also are conducting educational outreach programs using TRI data.
 Use of the Data by the Financial and Business Communities: Investment analysts use TRI data to provide recommendations to clients seeking to make environmentally sound investments. Insurance companies look to TRI data as one indication of potential environmental liabilities. Consultants and others use the data to identify business opportunities, such as marketing pollution prevention and control technologies to TRI reporting facilities. Demand for environmental performance information by investors, insurance companies, and the public has led many companies to develop environmental annual reports similar to annual reports on financial information traditionally prepared for investors.
 Industry Use of TRI Data: TRI data have been used by industry for activities such as developing waste reduction strategies and improving companies' understanding of their own production processes. Industry also uses TRI submission information to show environmental progress and as a starting point for engaging with communities.
 Government Use of TRI Data: Government organizations such as the media-specific and core offices at EPA, EPA Regional offices, and other national, state, and local government agencies routinely use TRI data. TRI data have been used to: develop inspection targeting and enforcement tools; analyze and prioritize long-term trends in waste minimization; identify candidates for the National Primary Drinking Water Regulations; coordinate environmental data internationally through agreements and organizations such as the Commission for Environmental Cooperation; and set priorities and allocate increasingly scarce environmental protection resources to the most pressing problems.
EPA has not attempted to monetize the benefits of the rule due to a lack of quantitative information characterizing the range of users and non-users of TRI data and the substantial analytical challenges associated with accurately predicting behavioral responses to the provision of information (Moody & Walsh, 1999; Palm, 1981). The analysis was not able to consider variations in quality or other attributes of TRI data access methods. The potentially large number of beneficiaries who are not users or who are otherwise unaware of the data (e.g., the general public) further limits EPA's ability to quantify potential benefits.
The experience since the first forms were submitted to TRI in 1987 suggests that reporting under EPCRA section 313 has produced real gains in understanding communities' exposure to toxic chemicals. In its report The Toxics Releases Inventory in Action: Media, Government, Business, Community and Academic Uses of TRI, EPA has documented numerous examples of how multiple stakeholders have used TRI data . Moreover, a cursory search on Google Scholar(TM) reveals thousands of academic articles referencing the Toxics Release Inventory. Improving the parent company information and adding international parent company information should provide similar incremental gains in understanding TRI releases and waste management at the parent company level.
Paperwork Burden and Other Analyses
In addition to the cost analysis presented in Chapter 3 and the small business analysis presented in Chapter 4, several other types of impacts are important to consider in evaluating the effects of a regulation. This chapter presents the incremental impact of the rule on:
          Paperwork burden, as required by the Paperwork Reduction Act;
          State and local governments, as required by the Unfunded Mandates Reform Act;
          Federalism, as required by Executive Order 13132 - Federalism;
          Tribal governments, as required by Executive Order 13175 - Consultation and Coordination with Indian Tribal Governments;
         Children, as required by Executive Order 13045 - Protection of Children from Environmental Health Risks and Safety Risks;
          Environmental Justice, as required by Executive Order 12898 - Environmental Justice.
Paperwork Burden Analysis
This section presents a summary of the burden and associated costs for the respondents associated with the requirements of the rule. The detailed paperwork burden analysis is presented in the information collection request (ICR) supporting statement for this rulemaking.
The paperwork burden and associated costs of this rule are analyzed below. Under this rule, all TRI reporting facilities are expected to incur rule familiarization costs associated with reading the new regulatory text. Facilities which report to TRI currently rely on guidance for this required data element but lack a codified definition. Additionally, all TRI reporters with foreign parent companies would be required to submit additional information (i.e., indicating either the foreign parent company name and D&B Number or not applicable).
Table 6-1 presents the total burden and costs in the ICR, including the rule familiarization and form completion activities. See Chapter 3 for a more detailed description of how the time burden and wage rates were estimated.
Table 6-1 	First Year and Steady State Incremental Industry Cost
                                   Activity
                                First-Year Cost
                               Steady State Cost
Rule Familiarization
                                                                       $735,207
                                                                             $0
Form Completion
                                                                       $504,365
                                                                        $14,238
Total
                                                                     $1,239,572
                                                                        $14,238

Unfunded Mandates Reform Act
Title II of the Unfunded Mandates Reform Act of 1995, Pub. L. 104-4, establishes requirements for Federal agencies to assess the effects of their regulatory actions on State, local, and Tribal governments, and the private sector. Under section 202 of the UMRA, EPA generally must prepare a written statement, including a cost-benefit analysis, for proposed and final rules with "Federal mandates" that might result in expenditures by State, local, and Tribal governments, in the aggregate, or by the private sector, of $100 million or more (when adjusted annually for inflation) in any one year. This action does not contain any unfunded mandate as described in UMRA, 2 U.S.C. 1531 - 1538, and does not significantly or uniquely affect small governments. The action imposes no enforceable duty on any State, local or Tribal governments or the private sector.
Executive Order 13132 - Federalism
Executive Order 13132, entitled Federalism (64 FR 43255, August 10, 1999), directs federal agencies to consider whether a rule has federalism implications (i.e., whether it has substantial direct effects on the states, on the relationship between the national government and the states, or on the distribution of power and responsibilities among the various levels of government, as specified in Executive Order 13132).
EPA has concluded that this action does not have federalism implications. It will not have substantial direct effects on the states, on the relationship between the national government and the states, or on the distribution of power and responsibilities among the various levels of government. This action would codify a definition of a data element already required of facilities that submit annual reports under section 313 of EPCRA and require those facilities to report both the U.S. parent company and the foreign parent company, the latter of which would not apply to any TRI reporters owned by a public entity in the U.S. Thus, Executive Order 13132 does not apply to this action.
Executive Order 13175 - Tribal Implications
Executive Order 13175, "Consultation and Coordination with Indian Tribal Governments" (59 FR 22951, November 6, 2000), directs federal agencies to consider whether a rule has tribal implications (i.e., whether it has substantial direct effects on tribal governments, on the relationship between the Federal government and the Indian tribes, or on the distribution of power and responsibilities between the Federal government and Indian tribes). This rule will not impose substantial direct compliance costs on Indian tribal governments, nor would it change the relationship between the Federal government and Indian tribes. This action does not have tribal implications as specified in Executive Order 13175. Thus, Executive Order 13175 does not apply to this action.
Executive Order 13045 - Protection of Children
Under Executive Order 13045, a regulation must be reviewed if the regulatory action is economically significant and concerns an environmental health risk or safety risk that may disproportionately affect children. This action is not subject to Executive Order 13045 because it does not concern an environmental health risk or safety risk. It is not an economically significant regulatory action as defined by Executive Order 12866.
Executive Order 12898  -  Environmental Justice
Executive Order 12898 (59 FR 7629, February 16, 1994) establishes Federal executive policy on Environmental Justice (EJ). Its main provision directs Federal agencies, to the greatest extent practicable and permitted by law, to make EJ part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the U.S. EPA believes that this action is not subject to Executive Order 12898 because it does not establish an environmental health or safety standard. This regulatory action is a procedural change and does not have any impact on human health or the environment.
References
Abt Associates Inc. (2004). Abt Associates Engineering Study (TRI Reporting Burden Estimates).
Moody, D., & Walsh, P. (1999). Measuring the Value of Information: An Asset Valuation Approach.
Palm, R. (1981). Public Response to Earthquake Hazard Information. Annals of the Association of American Geographers, 71(3), 398 - 399.
U.S. Bureau of Economic Analysis. (2022). National Income and Products Accounts Table, Table 1.1.9: Implicit Price Deflators for Gross Domestic Product. http://www.bea.gov/iTable/index_nipa.cfm
U.S. Bureau of Labor Statistics. (2022). Employer Costs for Employee Compensation -- December 2021. https://www.bls.gov/news.release/archives/ecec_03182022.pdf
U.S. Census Bureau. (2005). Finances of Municipal and Township Governments: 2002 (Volume 4, Number 4, Government Finances). https://www.census.gov/prod/2005pubs/gc024x4.pdf
U.S. Census Bureau. (2016). Population of Interest-Municipalities and Townships. Lists & Structure of Governments. https://www.census.gov/govs/go/municipal_township_govs.html
U.S. Census Bureau. (2021). The Number of Firms and Establishments, Employment, Annual Payroll, and Receipts by State, Industry, and Enterprise Employment Size: 2017. https://www.census.gov/data/tables/2017/econ/susb/2017-susb-annual.html
U.S. Census Bureau. (2022). City and Town Population Totals: 2020-2021. https://www.census.gov/data/tables/time-series/demo/popest/2020s-total-cities-and-towns.html
U.S. Environmental Protection Agency. (2011a). Revising TRI Burden to Ratio-Based Methodology. TRI Regulatory Development Branch. https://www.epa.gov/sites/default/files/documents/136321RatioBasedMethodology.pdf
U.S. Environmental Protection Agency. (2011b). Economic Analysis of the Electronic Reporting Proposed Rule: Community Right-to-Know; Toxic Chemical Release Reporting.
U.S. Environmental Protection Agency. (2012). Economic Analysis of the Toxics Release Inventory (TRI) Reporting for Facilities Located in Indian Country Final Rule.
U.S. Environmental Protection Agency. (2013). The Toxics Release Inventory in Action: Media, Government, Business, Community and Academic Uses of TRI Data. http://www2.epa.gov/sites/production/files/documents/tri_in_action_final_report_july_2013.pdf
U.S. Environmental Protection Agency. (2020). Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other EPA Actions (EPA-236-B-15-001). https://www.epa.gov/sites/production/files/2020-12/documents/epa_handbook_on_valuing_changes_in_time_use_121520_final_508.pdf
U.S. Environmental Protection Agency. (2021). Economic Analysis of the Proposed Parent Company Definition for TRI Reporting. https://www.regulations.gov/document/EPA-HQ-OPPT-2018-0155-0003
U.S. Environmental Protection Agency. (2022, May 25). Toxics Release Inventory -- Updated Dataset 2020. https://www.epa.gov/toxics-release-inventory-tri-program/tri-data-and-tools
U.S. Small Business Administration. (2022, May 2). Table of Small Business Size Standards Matched to NAICS Codes.