CAIR Job Impact Statement
6 NYCRR Part 243, CAIR NOx Ozone Season Trading Program, 6 NYCRR Part 244, CAIR NOx Annual Trading Program, 6 NYCRR Part 245, CAIR SO2 Trading Program
Nature of Impact
The Department of Environmental Conservation (Department) proposes to adopt the Clean Air Interstate Rules (CAIR) by promulgating 6 NYCRR Part 243, CAIR NOx Ozone Season Trading Program, 6 NYCRR Part 244, CAIR NOx Annual Trading Program, 6 NYCRR Part 245, CAIR SO2 Trading Program and to revise 6 NYCRR Part 200, General Provisions. The proposed rules and revisions are not expected to have a substantial adverse impact on jobs or employment opportunities in New York State.
Categories and Numbers Affected
The promulgation of Parts 243, 244, and 245 is expected to increase employment for a time period, up to two or more years at each facility that chooses to install controls in order to comply with the requirements of CAIR, 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 rules related to monitoring, recordkeeping and reporting requirements as the affected emission sources are already satisfying these requirements under current New York cap-and-trade programs.
CAIR will have some positive impact on employment. Many generating companies will need to purchase control equipment and construct the facilities to house this equipment. Total capital expenditures include the costs for emissions control equipment, construction materials, labor and design. Each of these activities should have positive impacts on employment in New York. However, because of the lack of detailed information provided to the Department regarding these costs and because the compliance options that are available to facilities, it is impossible to estimate the actual number of jobs that will be created by this capital expenditure.
CAIR will also have a positive impact on the travel and tourism industry. Mitigation of the effects of acid rain will aid in keeping New York State as a preferred vacation destination. In addition to reducing acid deposition, these regulations will also assist in the reduction of primary and secondary formation of fine particulate matter that plays a prominent role in regional haze. Because of regional haze, rural and urban vistas of New York are often obscured which reduces the desirability of travel in and around the State. While it is not possible to quantify the economic or the employment impact of these regulations, it is comprehensible that their implementation will make New York State a more attractive vacation destination.
Regions of adverse impact
None.
Minimizing Adverse Impact
The Department is implementing the CAIR emissions limits through a cap-and-trade program. Allowance based cap-and-trade systems are the most cost effective means for implementing emission reductions from large stationary sources. By implementing CAIR through an allowance based cap-and-trade system, the Department has attempted to minimize the adverse economic impacts including the adverse employment impacts of the program.
Minimizing adverse impacts to generators and obtaining maximum NOx and SO2 reductions is accomplished by dividing the regulations into two phases. 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. In addition to the two-phase system, alignment of compliance dates with other rules being promulgated for the control (i.e., mercury, CO2) may reduce the need for further scheduled outages for electric generating 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 CAIR and a mercury reduction 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.
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.
