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Proposed Parts 205 and 200 Job Impact Statement

The Department of Environmental Conservation (Department) proposes to adopt revisions to 6 NYCRR Part 205, "Architectural and Industrial Maintenance (AIM) Coatings," and Part 200, "General Provisions" (collectively, Part 205). AIM coatings, such as paint, are applied to stationary structures or their appurtenances at the site of installation, portable buildings at the site of installation, pavements, or curbs. The purpose of this rulemaking is to reduce emissions from AIM coatings by reducing the volatile organic compound (VOC) content limits for some coating categories.

Nature of Impact

Part 205 may impact jobs and employment opportunities with manufacturers producing AIM coatings in New York State. The regulation, as proposed, will require lowered VOC limits which would likely require reformulation of any products which do not meet the new limits. The time and expertise required to reformulate AIM coatings may result in increased employment for consultation and testing. However, reformulation guidance has been made available through the American Coatings Association (ACA) and through raw material chemical distributors so the increase may be limited.

The impact on the Department consists of time for rulemaking development and outreach. Department enforcement staff will continue to conduct enforcement activities to ensure compliance with the current Part 205, and the revised rule is not expected to require additional staff time to implement the rule.

Categories and Numbers of Jobs or Employment Opportunities Affected

Changes to Part 205 may impact coating and raw material manufacturers, distributors and stores that sell coatings. This would include companies that sell or manufacture coatings for New York State sales. In the last New York State survey in 2005 it was estimated that over 75 million gallons of AIM coatings were sold in New York State.

The revisions to Part 205 may lead to increased time and expertise spent reformulating impacted coating categories. Manufacturers that sell into California, Utah and Delaware have already reformulated their coatings, so those companies should not be impacted. Those companies which need to reformulate will either need to spend more in house resources for reformulation or will need to hire outside help to reformulate.

Regions of Adverse Impact

The paint and coatings industry sector which is impacted by this rule are distributed throughout the state. Manufacturers may be found both upstate and in the New York City metropolitan area. Since this is a statewide rulemaking, the Department does not expect it to have any region-specific adverse impacts.

Minimizing Adverse Impact

To minimize any adverse impacts Department staff conducted a stakeholder process with national and local manufacturers and coatings associations on May 12, 2010 in association with the Ozone Transport Commission. Department staff also attended several coatings conferences and meetings with manufacturers, including the American Coatings Association (ACA) on May 14, 2013 and, the Metropolitan New York Coatings Association (MNYCA) on June 12, 2014. Outreach with individual manufacturers and interested parties has also been supported.

The proposed VOC limits have been in effect in California since 2007 and products with these lower limits have already been available and sold in the marketplace. All manufacturers, including small businesses, have had ample time to research, prepare and implement re-formulation strategies.

Self-Employment Opportunities

The adoption of revised Part 205 is not expected to result in negative impacts to self-employment opportunities.

Initial Review

The initial review of this rule shall occur no later than in the third calendar year after the year in which the rule is adopted.


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  • NYSDEC
    Division of Air Resources
    Proposed Part 205
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    Albany, NY 12233-3255
    518-402-8396
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