Adopted Part 246, Mercury Reduction Program for Coal-Fired Electric Utility Steam Generating Units Job Impact Statement
6 NYCRR Part 246, Mercury Reduction Program for Coal-Fired Electric Utility Steam Generating Units and 6 NYCRR Part 200.9, Referenced Material
Nature of Impact
The proposed rule (6NYCRR Part 246) is not expected to have a substantial adverse impact on jobs or employment opportunities in New York State.
Categories and numbers affected
The proposed regulation could impact the cost of generation at coal-fired electric utility stations in New York State. New York currently has thirteen permitted coal-fired electric utility steam generating stations, two of which, AES Hickling and AES Jennison, have been on cold standby at least since October 2000. In addition to the traditional steam generating stations there are two cogeneration facilities, Trigen-Syracuse and the Niagara Generating Facility, generating steam for both electric production and process use that fall within the scope of the proposed rule. The on-site cost of installing, operating, and maintaining mercury emission control equipment that may be required to satisfy the proposed regulation directly reduces the operating margin (similar in concept to profit) of the Mercury Reduction Program units. It is unlikely that the associated small increase in the cost of electric generation would adversely impact employment opportunity at these facilities.
Regions of adverse impact
None.
Minimizing adverse impact
Minimizing adverse impact to the generator and obtaining maximum mercury reduction was best accomplished by dividing the regulation into two phases, an annual facility emission limitation phase in 2010 and a facility-wide average mercury emission rate limit phase in 2015. The first phase will allow utility owners to identify the emission units where the greatest emission reductions can be achieved first and manage their facility with respect to future electrical needs and other regulations such as the Clean Air Interstate Rule (CAIR). In addition to the two-phase system, alignment of compliance dates with other rules being promulgated for the control of SO2 and NOx may reduce the need for further scheduled outages for coal-fired facilities and allow concurrent construction schedules and installations.
There will be no significant adverse impact to job opportunities at those locations that consume electricity at the modeled wholesale Residential, Commercial and, Industrial customer level. The Department in cooperation with NYSERDA has conducted an electricity system modeling analysis to estimate the incremental cost of implementing the CAIR and a mercury rule in New York. The electricity system modeling analysis compared a reference or business-as-usual case (absent either CAIR or mercury) to each of three policy cases: New York's proposed approach for implementing both CAIR and mercury, CAIR only, and mercury only. CAIR and mercury policies (implemented together, as proposed) could increase wholesale electricity prices by an average of 1.7 percent or $1.14 MWh over the 2010 to 2020 timeframe. For a typical residential customer (using 750 Kwh per month), this translates into a monthly retail bill increase of $0.86. Model runs assuming CAIR only (i.e., without mercury) and mercury only (i.e., without CAIR) indicate that virtually the entire incremental electricity price impact of implementing CAIR and mercury together is due to CAIR. There is virtually no incremental electricity price impact due to mercury1.
The promulgation of Part 246 is expected to increase employment for a time period, up to two or more years at each facility, in jobs associated with air pollution control device installation including but not limited to construction steel workers, welders, pipe fitters, and electricians. Therefore, a short-term measurable positive effect on numbers of construction steel, electrical, fan, and pumping and piping jobs is anticipated. Furthermore, there will be no associated adverse impact from the proposed rule related to monitoring, recordkeeping and reporting requirements as adoption of EPA's model rule is required for national reporting, regardless of the promulgation of a State rule. Instead, there will be an increase in jobs associated with the installation, operation, and maintenance of mercury monitoring systems and any laboratory technical staff required to analyze sorbent traps that may be used in place of mercury continuous emission monitoring systems.
Self-employment opportunities
There are no adverse impacts towards self-employment opportunities associated with the proposed regulation. The types of facilities affected by this regulatory addition are larger operations than what would be found in a self-employment situation. Even though it is expected that most design, engineering, and construction will be performed by larger consultation and construction firms, there will be an opportunity for self-employed consultants to advise facilities on how best to comply with the new requirements.
1 NYSDEC, NYSERDA, and ICF International, Modeling Results for CAIR and Mercury. May 18, 2006
