Climate change is a relatively new area of engineering, with the concern for climate change and desire for solutions growing in the last two decades. As it is also highly evolving, new approaches and terminology are being incorporated. Here is a peek at where things stand now; terms and approaches may change quickly in the future!

Climate change vs. global warming. The popular press interchanges these two terms and, in fact, uses global warming more often. But there is a difference between the two and climate change is the preferred term in most cases. While initially, we were concerned with the planet warming, subsequent studies have pointed out that not all of the Earth will warm. In fact, some areas may cool slightly or not change in temperature appreciably. One example that modelers point out is extreme western Europe whose warmth is contributed to by the Gulf Stream. However, if cold water from melting glaciers from the north reach the north Atlantic, it could neutralize the Gulf Stream and lessen its warming effect. Thus, areas like Portugal, Spain, western France, and Ireland can actually cool over the years. There are many other effects like the Gulf Stream. Certainly, the climate will change and, thus, climate change is the preferred term.

Climate change is centered around “carbon” emissions. This is, in my opinion, an unfortunate term because it is carbon dioxide that is the main greenhouse gas and many other “carbon” compounds have no appreciable effect on trapping radiation. But “carbon” has become so ingrained that it is now accepted. And thus, many terms derive from “carbon”. For example, the new term about the study of the economics of carbon pricing, regulations and reduction strategies is now called ”carbonomics”.

This is not a new term, but an approach companies are using to analyze their carbon emissions is life cycle analysis (LCA). LCA is an analysis of the impacts of a process or a product through its life cycle. Just imagine an item you have right now: the shirt you are wearing, the laptop on which you are reading this article, a pen, a cup of coffee, etc. What is the life cycle of that item? What investment was made for the infrastructure to make it (factory, roads, trucks, etc.)? What is its supply chain? How is it fabricated or manufactured? How is it distributed from the factory to the warehouse or store? How is it sold and how is it used by the consumer? And the final step of the product’s life cycle is its end-of-life (recycling, landfill, etc.). Each one of these six portions of an item’s life cycle has greenhouse gas (GHG) emission and energy usage implications. An analysis of GHG emissions of each of these six areas can reveal where GHG emissions are greatest and what would make the most sense to focus on. By the way, LCA can be used for other analyses, too (water usage, waste generation, etc.). A growing amount of data is being published on LCA procedures and results.

Carbon regulation and incentives are not commonplace currently in the US, but significant worldwide, and worth understanding nomenclature. This is highlighted by emission trading systems (ETSs) that encourage the development of carbon credits based on the trading system or regulation. A common ETS is “cap and trade”, which gives a limit (cap) of GHG emissions. If an entity emits less than its cap, it can sell (trade) the excess emissions not emitted as credits. For entities having trouble finding feasible ways to reduce GHG emissions, purchasing such credits is a viable option; the developer of the credits is financially rewarded. Another ETS is simply a “carbon tax”, a payment required for emitting GHGs, which, of course, goes up with greater GHG emissions. Finally, a feature of most ETSs is “offsets”, the reduction of GHG emissions outside your facility. Being a global problem, reductions of GHG emissions does not need to occur within your property lines to be effective. If it is cheaper to reduce GHG emissions – even thousands of miles away – than to reduce it at your facility, then take advantage. It’s all good.

I hope this has been helpful to discuss new or existing nomenclature on climate change that is not discussed all that often.

CCES has the technical experts to help you assess and reduce your GHG emissions in an economic manner to save you significant costs and other benefits. Contact us today at karell@CCESworld.com or at 914-584-6720.

On September 22, 2022, the US Dept of Energy opened applications for a $7 billion H2Hubs program with the goal of creating 6 to 10 regional clean hydrogen (H₂) hubs across the country. This expenditure, covering fiscal years 2022 through 2026, would likely be the largest investment of funds in DOE history. The H2Hubs program will focus on the production, processing, delivery, storage and end use of hydrogen. This is part of the broader goal of supporting the US’s commitment to achieving a carbon-free electric grid by 2035 and a net zero emissions by 2050.

The H2Hubs program will be managed by the US DOE’s Office of Clean Energy Demonstrations. Each eventual H2Hub must be a collaboration of multiple partners to integrate diverse hydrogen technologies to meet the production, delivery, etc. goals of above.

DOE anticipates an estimated performance period for each hub of 8 to 10 years. However, DOE will encourage and expect a shorter period of performance depending on one’s level of readiness to proceed.

DOE has set a deadline of November 7, 2022 for Concept Papers outlining proposed research projects and April 7, 2023 for full applications. Selection notifications are anticipated in Fall 2023.

Hydrogen is both the most efficient fuel (on a weight basis) and is the “cleanest” from a climate change point of view. Combustion of hydrogen is carbon-free; it forms no GHGs. The problem is that, currently, little naturally occurring hydrogen exists. Hydrogen must be manufactured by other means, which itself uses energy and emits greenhouse gases. Finding effective ways to minimize or eliminate this energy use for its formation would make it a more attractive and economical fuel source. An initial US DOE guidance established a GHG emission target of no more than 4.0 kgCO2_e / kgH₂ for the lifecycle of H₂ production, transportation, storage, and utilization. 

In addition, hydrogen can be quite explosive. Thus, safety concerns must be addressed, too, in its lifecycle before it can become a commonplace fuel source. In order to get to a carbon-free electric grid and net zero GHG emissions nation, much greater hydrogen usage for energy is likely necessary and these obstacles need to be overcome.

CCES has the experts to help you evaluate your energy sources so you can use that which is most available and cleanest – to stay ahead of changing regulations and to improve your energy efficiency to meet climate change goals and reduce costs. Contact us today at karell@CCESworld.com or at 914-584-6720.

Upon promulgation of the IRA in August, 2022, clients began asking me about whether they can take advantage of incentives now. No, it will take some time for the specific programs to be finalized, approved, and instituted. But on October 6, 2022, a step forward toward this happened. The Treasury Dept and IRS issued 6 public notices requesting feedback on proposed IRS Code sections pertaining to the new Inflation Reduction Act. See the link to the specific request, including background.

Clean Vehicles – Notice 2022-46

Sec. 30D Clean Vehicle Credit

Sec. 25E Previously Owned Clean Vehicle Credit

Advanced Manufacturing – Notice 2022-47

Sec. 45X Advanced Manufacturing Production Credit

Sec. 48C Advanced Energy Project Credit

Home and Business Energy Incentives – Notice 2022-48

Sec. 25C Energy Efficient Home Improvement Credit

Sec. 25D Residential Clean Energy Credit

Sec. 45L New Energy Efficient Home Credit

Sec. 197D Energy Efficient Commercial Buildings Deduction

Energy Generation – Notice 2022-49

Sec. 45 Renewable Electricity Production Credit

Sec. 48 Energy Investment Credit

Sec. 45U Zero-Emission Nuclear Power Production Credit

Sec. 45Y Clean Electricity Production Credit

Sec. 48E Clean Electricity Investment Credit

Credit Payment Structures – Notice 2022-50

Sec. 6417 Direct Payment of Certain Credits

Sec. 6418 Transfer of Certain Credits

Bonus Credit Requirements – Notice 2022-51

Prevailing Wage – (Secs. 30C, 45, 45L, 45Q, 45U, 45V, 45Y, 45Z, 48, 48C, 48E and 179D)

Apprenticeship – (Secs. 30C, 45, 45Q, 45V, 45Y, 45Z, 48, 48C, 48E and 179D)

Domestic Content – (Secs. 45, 45Y, 48 and 48E)

Energy Communities – (Secs. 45, 45Y, 48 and 48E)

Incentives as part of Sec. 45V (Hydrogen Production) and 45Q (Carbon Capture) are not included in this request for public comment and are still being finalized.

Public comments are due on November 4, 2022. It is still a long way until the IRS codes are modified and go into effect. Not going forward with a smart energy upgrade and waiting for a code to be finalized is not a good idea. That means you are continuing with equipment or a system that is less effective and costs you money in the meantime. It is better to go forward with smart upgrades now, even if it is too soon for some of these credits. And, you never know, many may end up with retroactive opportunities for benefits in the provisions.

CCES has the technical experts to help you implement smart energy upgrades to save you significant costs right away, reduce the costs and aggravation of O&M, modernize your operations, and maximize the comfort and effectiveness of your customers and staff. Contact us today at 914-584-6720 or at karell@CCESworld.com.

On October 5, 2022, NYC issued proposed clarifications and changes to LL 97, the rigorous greenhouse gas (GHG) emission rule that goes into effect for many covered buildings in 2024. See: chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www1.nyc.gov/assets/buildings/pdf/proposed_greenhouse_gas.pdf

The proposed changes are not official yet and must go through public comment. The NYC DOB hopes it will be incorporated into LL 97 soon and the program go into effect January 1, 2024. Some highlights of the proposed changes based on a quick non-legal review of the published changes:

Differentiation of building type. The original LL 97 contained 10 building types and defined GHG emission limits for each. But mixed-use buildings were not addressed. It is certainly known that many subject buildings may have operations that fit more than one type, such as the common multi-family residential building with retail units (supermarket, pharmacy, bank, etc.) at the ground level. LL 97 now requires such a subject building to differentiate the space of different functions (how many square feet is multifamily residential, how many are retail) and apply total energy usage proportionally to the different areas. At the same time, the proposed change raises the number of building types to 61, each with its own GHG emission limit (in metric tons CO2e / sf) for the building owner to assess.

Allowance of Time of Use (TOU) to calculate GHG emissions from electric usage. LL 97 initially required total electric usage no matter when it was being used (peak time during the afternoon vs. preferred time, such as night). The proposed change allows a change in GHG emissions based on TOU. A subject building looking to take advantage of this must be able to meter its electric usage hour by hour for a long period, whether through the utility or with approved meters it operates. The proposed changes contain new GHG factors encouraging off-hour electric usage to develop lower GHG emissions.

Use of RECs and solar panels to lower GHG emissions. The initial version of LL 97 left open policy about being able to deduct GHG emissions if one had registered Renewable Energy Credits (RECs). There was some thought of allowing this, but restricting RECs to those generated within NYC or New York State. This change allows one to deduct one’s GHG emissions from electricity usage only with registered RECs, and does not appear to limit it from where it was generated geographically. A building can also reduce its GHG emissions for LL 97 compliance by implementing solar panels or other renewable source. The proposed change states that one must calculate total power generated by the renewable source (and presumably, put into the grid) and the use of total electricity by that building. A building owner cannot “double dip” and take credit for RECs for a solar panel array on one’s property and deduct GHG emissions based on electricity generated, too.

Further exemptions from reporting.
1. A new building does not have to report GHG emissions per LL 97 until after its first full calendar year of operation.
2. The proposed change exempts a new owner of a building from being responsible for submitting the annual LL 97 report until it is owned for a full calendar year. The change does not appear to state whether the building is thus exempt from submitting a report for the calendar year that the building changed ownership or whether the previous owner is still responsible.
3. An owner of a subject building for which a full demolition permit has been issued is not required to submit a LL 97 report for the calendar year during which demolition work has begun; the owner must submit a written certification by a registered design professional that one or more energy-related systems within the building has been compromised and legal occupancy is not possible.

Public comment is due on November 14, 2022. A public hearing will be held that day. This is only a preliminary review of the changes. Please have experienced, professionals review the changes in detail, including legal counsel, before undergoing any changes in response to it.

CCES is a technical firm that can help you assess your potential compliance with LL 97 GHG emission limits and develop and manage for you smart, cost-saving strategies to reduce potential LL 97 fines or achieve compliance. Contact us today at karell@CCESworld.com or at 914-584-6720.