Monthly Archives: September 2018

Will The USEPA Change Its Mission To Protect Public Health?

When writing virtually any environmental rule, the USEPA performs and publishes its calculations of the financial cost of implementing the rule vs. the gains in terms of extending human life, improving public health, and prevention of environmental degradation. While one can quibble about the approach or formulas, the USEPA is transparent about why it believes a proposed rule or rule change is beneficial to society.

This article is not intended to be political in any way, but a warning that the USEPA is in the process of changing this approach and this will affect future rulesmaking. The current USEPA is looking to de-emphasize the life and health benefits of a proposed rule and emphasize compliance costs instead. The recent proposed change in the Clean Power Plan (CPP) (discussed in another article in this newsletter) openly states that it will decrease the number of prolonged lives compared to CPP and that the increase in greenhouse gases it will cause will have adverse economic effects. But the agency is pushing for this replacement because it will reduce the upfront costs of affected facilities to comply.

It was thought initially that the new approach of the USEPA is to de-emphasize protection of public health benefits to favor an overall evaluation of monetary benefits. But even this does not seem to be the case in the CPP replacement bill, as it would reduce some of the monetary benefits to the nation.

Another irony is that a number of affected industries of Obama-era environmental rules have come out against revising them. Duke Energy, for example, came out against revising CPP because of money already invested in required controls. Since money has already been spent to comply, the rule might as well stay in effect and benefits acrue.

In addition, research into environmental rule effectiveness shows that many rules are achieving public health goals at reasonable costs. The 2011 Clean Air Mercury rule cost utilities – by their estimation – about $18 billion to install compliant technology. Mercury emissions dropped by nearly 70%, resulting in direct health benefits of $4 to $6 billion. The USEPA went on to state that savings of an additional $80 billion per year was achieved due to the indirect benefits of reducing mercury emissions, such as reduction in lung and heart disease, resulting in 11,000 premature deaths delayed per year.

USEPA Administrator Andrew Wheeler stated that the agency is looking into an overhaul of how to calculate the cost and benefits of environmental regulations. His predecessor, Scott Pruitt, stated that he felt that the agency did not properly perform cost-benefit analyses, artificially inflating benefits and underestimating costs. They stated that the agency has been guilty of picking winners and losers and tainting their analyses to encourage the changes it wishes. The formulas in USEPA cost-benefit calculations must be modified, they and their supporters say.

Others complain that the formulas used by the USEPA do not go far enough to show the benefits of a healthier population by not taking into consideration the cost to the US economy of job loss due to layoffs and sick time.

CCES can help your firm keep up with changing environmental rules at the federal, state, and local level and provide you with the information to make the best determination of compliance options. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Benefits of Trees for Sustainable Cities

More than half the population of the world now lives in areas defined as urban. There is growing pressure to convert more open space into residences and commercial buildings to serve the growing urban population than ever before. More people means more customers for entrepreneurs and more businesses means more revenue (taxes) for municipalities. But is this growing dense, urban development costly for urban living?

While this seems trite and inefficient, trees have been shown to be effective in preserving urban ecosystems. Of course, the trend is commonly to chop down trees to build another development. But keeping and increasing the number of trees have been shown to have many benefits for urban residents and businesses. Trees clean the air and water, reduce health costs, improve stormwater management, optimize building energy use, mitigate climate change, and provide many cultureal treats.

According to the US Forest Service, for every dollar invested in planting, cities get a $2.25 return on their investment each year. https://www.fs.fed.us/ucf/supporting_docs/UCF-Brief-Feb2018.pdf

A recent aerial survey of 35 megacities showed that 20% of the average city’s urban core is covered by trees, ranging from just 1% in Lima, Peru to 36% in New York City.

A study published last year aimed to determine how much trees contribute to human well-being in urban locations showed a correlation between the number of trees planted and human well-being. https://linkinghub.elsevier.com/retrieve/pii/S0304380017300960

The study focused on 10 very large cities worldwide. The study estimated that each square kilometer of tree cover saved a city significantly in air pollution health care costs, water runoff, building energy heating and cooling costs, and in the value of CO2 removed. Total savings was estimated to be about $1.2 million per square kilometer of trees, on average in these 10 very large cities.

Despite the feeling that large cities have no room to plant trees, the study indicated that, on average, about 18% of a metropolitan area is available to plant additional trees. Potential locations included sidewalks, parking lots and plazas. Tree trunks can be located in narrow bands, yet the tree’s canopy could shade these areas and allow pedestrians or cars to move freely.

CCES has the experts to help your company or municipality (any size) design a sustainability plan involving trees (as well as other strategies) to maximize benefits, such as the ones above (energy savings, healthier employees, etc.). We can use the latest science to develop a plan that is specific and will benefit you. Contact us today at 914-584-6720 or at karell@CCESworld.com.

The Positive and Negative Impacts of Solar Energy

by Arthur Smith, LEDwatcher  http://www.LEDwatcher.com

Solar energy can be a vast source of power that can provide clean, sustainable electricity. We are now able to use solar panels in all types of weather. It used to be that if it was cloudy the panels would quit charging. But now, with newer technology, solar power can be generated even on snowy and cloudy days. And as we focus more on cleaner power, solar energy is making its way further into our daily lives. https://www.telegraph.co.uk/news/science/science-news/10701064/British-scientists-develop-solar-panels-which-work-better-on-a-cloudy-day.html

Of course, solar energy isn’t perfect. Just like everything else in life it has its positives and negatives. And one of the biggest downfalls of solar energy is its negative effect on the environment. So in this article we will look at both the negative and the positive impacts of solar energy, so you can judge for yourself whether solar energy could be beneficial for your home or business how environmentally-friendly and good solar power actually is.

The Negatives

• Taking Up Space. The more electricity that needs to be produced, the more solar panels you will need. And the more panels are needed, the more space they will take up. Because of this, large solar farms will need to be set up to meet solar energy demands. Rendering this land useless. How to counteract this? By setting up the solar power plants on land that otherwise can’t or isn’t used. This would make the acreage beneficial again, and would mean that no farmland needs to be sacrificed to generate more solar energy.

• Pollution. Although solar panels have the reputation of being pollution-free, pollution is produced while the panels are being manufactured and installed. Hazardous products are used in the manufacturing process of solar panels. The transportation and installation of the panels also emit greenhouse gasses. How to make solar panels a completely pollution-free technology? By creating greener ways of producing the panels, as well as employing electric cars to transport them to the place of installation.

The Positives

• Electricity Savings. Harnessing solar energy and using it to power your home will lower your energy bills. By how much? That will depend on the size of your solar system and your electricity usage. But the good news is that in some countries if you produce more electricity than you consume, you can sell the surplus to your electricity supplier letting you not only save but actually earn money from your solar panels.

• Reduced Greenhouse Gas Emissions. The more energy that we can create with solar power the less fossil fuels we will be burning and the smaller amount of greenhouse gasses we will release into the atmosphere. Solar energy is an amazing way to reduce our greenhouse gas emissions and live greener lives.

• Sustainability and Resilience. Solar energy is also a renewable resource,whereas fossil fuels are not. As long as the sun is shining in the sky we will always have access to solar energy. So solar power is an unlimited energy source, which will be there to meet the energy needs of generations to come.

• Low Maintenance. After installation, solar technology is low-maintenance. Therefore, they are great for rural areas that are off the grid and can’t be accessed easily, and don’t require as much man-power to maintain.

• Cost Advantages. The source of solar energy is free and is in great abundance. Which means that as long as there are discount schemes to help with the solar panel costs, they can also be a great help to people in more remote areas that might not have access to electricity, due to the lack of infrastructure to bring in electricity or fuel or a power plant.

• Energy Independence and National Security.  Finally, relying on fossil fuels can exacerbate many technical, political, and financial issues. We can better safeguard ourselves by collecting our own energy and not being dependent on others. Wars and natural disasters can also put a heavy strain on the existing fuel supplies leading to very high prices. This makes solar power that much more a cost-efficient solution.

For many locations, buildings, and regions, the benefits of solar energy far outweigh its negative effects. Solar should be seriously considered by businesses as not only a cost-effective energy management strategy, but part of the way to a greener, more sustainable future.

Arthur Smith is the lead editor of LEDwatcher, a blog that focuses on solar and LED lighting. With years of experience working in both solar and lighting industries, Arthur has turned to blogging and writing guest articles for different websites to help others learn more about these technologies as well.  See    http://LEDwatchter.com.

USEPA Proposes To Replace The Clean Power Plan

On August 21, 2018, the Trump Administration released its proposed replacement for the Clean Power Plan (CPP), called the Affordable Clean Energy (ACE) Rule. https://www.epa.gov/sites/production/files/2018-08/documents/frn-ace-proposal_8.20.2018.pdf

What’s interesting is that the USEPA’s own analysis open demonstrates that the ACE will result in fewer benefits than the rule it replaces, such as GHG and criteria pollutant emission reductions. So this is a “step backward” in terms of environmental impact. See the ACE Fact Sheet: https://www.epa.gov/sites/production/files/2018-08/documents/ace_overview_0.pdf. ACE is projected to reduce GHG emissions by one-tenth that the CPP is projected to: up to 30 million short tons of CO2e by 2025, compared to 300 million short tons under CPP. Interestingly, the Fact Sheet states that ACE will result in a “monetized domestic climate benefit” of $1.6 billion, compared to no rule at all. This is an interesting admission by this Administration that climate change is real and tangible and also that reducing GHG emissions will result in financial benefits. In addition, if these numbers are true, then reducing GHG emissions by 300 million tons should result in a greater economic benefit to the U.S. Why would the Administration go against such economic logic?

In addition, the Regulatory Impact Analysis prepared for the proposed ACE states that replacement will result in hundreds of additional premature deaths per year due to higher particulate emissions rates allowed by ACE. Most of these deaths will occur in U.S. regions downwind of coal-powered power plants. Proposing a rule change that will reduce reductions of GHG emissions (at a cost to our economy) and raise the number of premature deaths goes against USEPA’s stated priority of protecting public health.

Other changes in the proposed rule include:

• Reducing the USEPA’s authority to regulate and letting more GHG regulation in the hands of states, going against the recent recognition that impacts of air emissions do cross state lines and is, therefore, a federal responsibility.

• ACE applies only to coal-fired power plants, while CPP applies to both coal and gas-fired plants.

• ACE encourages improved efficiecy, rejects carbon capture and sequestration.

• Removal of cumulative GHG emission reduction targets or limits for power plants.

• Trading of GHG credits will not be allowed, although averaging among units in a single facility will be allowed. It is unclear how that may affect an existing trading program, like RGGI.

• While ACE contains USEPA-approved guidelines for reducing GHG emissions, a state’s standards may be less stringent than the USEPA guidelines. The state must explain why meeting USEPA guidelines for GHG emissions is a hardship.

The proposal to implement ACE was published in the Federal Register on August 31, 2018, beginning a public comment period. Comments are due by October 30.

CCES has the experts to help you develop an energy and a GHG emission reduction program to provide you maximum financial benefits and operating flexibility. Contact us today and we can help. karell@CCESworld.com or 914-584-6720.