Job Impact Statement 6 NYCRR Parts 200 and 201
The New York State Department of Environmental Conservation (Department) is proposing to revise and update 6 NYCRR Parts 200, General Provisions, and 201, Permits and Registrations (Part 201). The last substantial overhaul of Part 201 occurred in 1996. Since that time, many of the requirements in Part 201 have become outdated and in need of revision. The proposed rulemaking will revise several components of the existing Part 201 to further clarify their requirements and simplify its implementation, making it more efficient and cost effective for affected facilities. The scope of the existing Part 201 is not changed as a result of proposed revisions.
The proposed changes to Part 201 include the addition of several exempt and trivial activities, the removal of outdated transition plan requirements and many other minor language corrections. The provisions for emission sources operating on a temporary basis will also be clarified. Permitting thresholds for 62 persistent, bioaccumulative, and/or toxic compounds are also being added in order to more closely monitor and where possible control their emissions. Facility owners and operators still holding outdated certificates to operate will be required to update their current permit by submitting a permit or registration application. Lastly, the Department is proposing to limit the term of issuance for state facility permits and registrations to 10 years, ensuring that the air permits and registrations issued by the Department contain the most up to date information possible.
Nature of Impact
The proposed revisions to Part 201 are not expected to have any measurable impact on jobs or employment opportunities in the state. Affected facilities will continue to comply with their air permitting requirements by utilizing existing staff, or by contracting with outside consulting firms. Due to the nature of the proposed changes, the Department expects resources at affected facilities will be able to be utilized more efficiently.
Categories and Numbers of Jobs or Employment Opportunities Affected
Facility owners and operators affected by Part 201 need professional engineering staff in order to accurately complete any required permit applications, and ensure their facility meets its obligations under their permit. Most facilities already employ the necessary staff to meet these needs. Professional engineering consultants may be retained where dedicated staff is unavailable, but that decision will be made by the facility owner or operator. In addition, the proposed changes will increase the clarity and efficiency of the air permitting process, allowing technical staff and consultants to complete the necessary work more quickly and efficiently.
Regions of Adverse Impact
The proposed revisions to Part 201 are not expected to have any adverse impact on jobs or employment opportunities in the state. Accordingly, there are no regions of the state where there is expected to be a disproportionate or adverse impact.
Minimizing Adverse Impact
The revisions to Part 201 are not expected to have an adverse impact on jobs or employment opportunities.