Job Impact Statement 6 NYCRR Parts 228, 200, and 201
Nature of Impact:
The New York State Department of Environmental Conservation (Department) proposes to revise 6 NYCRR Parts 228, 200, and 201. The proposed changes to Subpart 228-1, and attendant revisions to Parts 200 and 201, will incorporate seven Control Techniques Guidelines (CTGs) issued by the Environmental Protection Agency (EPA) between April 1996 and September 2008. These federal CTGs establish Reasonably Available Control Technology (RACT) for volatile organic compounds (VOCs) emitted by surface coating processes. Pursuant to the Clean Air Act (CAA), the Department is required to submit the Subpart 228-1 revisions to EPA for state implementation plan (SIP) review and approval. The proposed revisions to Subpart 228-2 make clarifying changes and are non-substantive.
Categories and Numbers of Jobs or Employment Opportunities Affected:
The proposed revisions to Subpart 228-1 affect owners/operators of surface coating processes statewide. The revisions are not expected to adversely impact jobs and employment opportunities in New York State. The proposed revisions to Subpart 228-1 may affect existing surface coating processes by requiring them to lower the VOC content of the materials used in their processes. This may require minimal consultation utilization to evaluate the necessity of process modifications. In such cases, jobs and employment opportunities may increase as a result of the proposed Subpart 228-1 revisions.
Regions of Adverse Impact:
There are no regions of the State where the proposed revisions to Subpart 228-1 would have a disproportionate adverse impact on jobs or employment opportunities.
Minimizing Adverse Impact:
The Department is providing advance notice of these rule revisions to the regulated community so that companies have sufficient time to take the necessary steps to come into compliance with Subpart 228-1. The proposed revision to Subpart 228-1 also includes time for subject sources to come into compliance.
None that the Department is aware of at this time.