6 NYCRR Parts 215, 191 and 621 Job Impact Statement
The purpose of revising Part 215 is to update regulatory requirements in regard to open fires and open burning. The need to update is based on the changes in both the type of materials burned in such fires and the increase in scientific knowledge about the toxic materials released into the air by the combustion of those materials.
The changes that the Department is proposing will establish a general ban on open burning with some limited exceptions. Since household trash will no longer be able to be burned by homeowners in an open fire there may be an increased opportunity for jobs in the solid waste disposal industry.
The purpose of revising Part 191 is to repeal outdated portions of the rule and portions that will become redundant if Part 215 is revised as recommended. The purpose of revising Part 621 is to remove references to the permits required by current versions of Parts 191 and 215 that will become outdated if those rules are revised as recommended.
Nature of Impact
The impact will be statewide. We have no firm number of households or individuals that may be impacted by the rule, it is estimated, however, based on an extrapolation of a study done in St. Lawrence County1, the number of households that burn their waste is thought to be in the tens of thousands. Rather than being burned, most of this waste will be placed in a landfill.
There is a potential increase in available employment associated with the proper disposal of solid waste. There will likely be a need for more employees (or employee hours) at rural solid waste transfer stations and at private waste haulers. Rural solid waste transfer stations are usually small facilities where residents bring their refuse, leaves, brush and recyclables. They typically consist of nothing more than a few roll-off containers into which residents deposit their wastes. When the containers are full, they are carted off to a permitted, composite lined solid waste landfill.
Due to the potential increase in the amount of household waste, brush, and land clearing debris, communities may need to upgrade these transfer facilities. A recent review of the Department's Division of Solid and Hazardous Materials records indicated that most rural transfer stations are located on adequate land for expansion; many of them being located at a former landfill which was closed under 6 NYCRR Part 360 Regulations. Upgrades would primarily consist of large trash compactors for household refuse, and wood chippers or tub grinders for brush and land clearing debris. Some communities currently rent tub grinders on a weekly or monthly basis to reduce brush/limbs to wood chips or mulch. These products can in turn be given back to the residents or used in municipal landscaping projects.
The Department currently has a program through which communities may receive Municipal Solid Waste Grants. These grants will reimburse fifty percent of the purchase price of wood chippers, tub grinders, or additional recycling equipment. There should be no additional costs to municipalities as any additional services they provide will be covered by the additional user fees. There may be a one-time administrative and/or engineering cost associated with upgrading the transfer stations. According to the Division of Solid and Hazardous Materials, there is no shortage of landfill space in the state, so there will be no impact on landfills.
The repeal of Sections 191.1 and 191.5 and the changes to Part 621 will eliminate permits currently required to conduct open burning. However since the revisions to Part 215 would ban most of these fires, there should be no job impacts due to the Part 191 and 621 revisions.
Categories and Numbers of Jobs or Employment Opportunities Affected
While there may be an increased opportunity for jobs handling solid waste, it is difficult to determine the exact number of jobs. The amount of the increase in solid waste to be handled is thought to be a small percentage of the existing amount.
Regions of Adverse Impact
None.
Minimizing Adverse Impact
No adverse impacts.
Self-Employment Opportunities
There may be self-employment opportunity involved with handling solid waste; it is difficult to determine the exact number of jobs.
1 Studies were done by staff of the St. Lawrence County Planning Office in November 1996, November 2002 and November 2006. A Summary Report can be downloaded at
http://www.co.st-lawrence.ny.us/Planning/OpenBurningAwareness/OpenBurningSummary-April2006.pdf
