Author Archives: Marc Karell

Load Shifting Is a Critical Summertime Strategy

The reality is that the energy infrastructure in the US is falling apart. Utilities do not have the billions of dollars to upgrade systems to deliver electricity where needed. Aging equipment and systems has contributed to the problem. In addition, gentrification has raised power demands in neighborhoods that had a low demand, making it difficult to shift delivery. Even technology has contributed to the problem. It used to be that people would come home from work to a hot unit, put on the AC and wait some time to cool off. Now smart phones can turn on a unit’s AC while the person is still in the office so the home is nice and cool when he/she arrives. The AC is on simultaneously in many offices and homes.

Thus, more and more parts of the US are suffering brownouts and blackouts, particularly in the summer when cooling demand raises electricity usage greatly, and particularly during workdays in the afternoon when maximum power is needed. A problem with serving such a high peak is the diversification of sources of power. More utilities are producing or purchasing electricity from renewable sources, such as solar and wind. The problem is that these sources are not reliable. Renewable power will not help on a hot and humid high-demand day which also happens to be cloudy and/or windless. Renewable power cannot churn out the added power to make up for the peak. Many renewable plants are also many miles away from the cities that need the power.

Because the expense of maintaining the system and addressing interruptions is significant, many utilities now charge customers substantial charges for a high short-term demand for electricity during these hours. But this does not seem to deter many.

If changing behavior is not happening, operating more energy equipment (lights, AC, etc.) should help this problem. Another solution is load shifting, moving electricity consumption from a peak time period to another time to “flatten the curve” of electric demand. This can be helpful for by utilities even if the load shifting results in greater electricity usage because their concern is delivering power reliably during peak usage. For now, when activities occur is more important than how much power they use.

An example of load shifting is moving an industrial process to a different shift, such as overnight, rather than during the day. While this may cost the firm more in overtime or duplicate use of equipment at night and day, it can be made up in savings in peak demand cost by eliminating the high peak demand during the day.

Another example of load shifting revolves around energy storage for space cooling, so important in peak periods. Systems exist to make large quantities of ice during the overnight (far from peak) period and allow air to flow around the ice to cool it during the peak period. Power needed for such blowers is much less than for large AC systems, reducing power needed during the peak period. A related approach is charging batteries with grid electricity during the night and use it (and not grid power) during the peak period. These often result in a net increase in total electricity used; but this can reduce costs as usage during the peak, expensive period of summer workday afternoons is reduced. These are examples of storing cooling energy either as ice or in batteries.

Load shifting is something businesses should consider, not only to reduce total electric costs, but also to help the grid supply electricity reliably to the entire community and to promote intermittent renewable energy and thus reducing reliance on fossil fuel-based power plants.

CCES has the experts to evaluate your company or building’s electricity usage. We can recommend cost-effective strategies for your specific situation, such greater efficiency, renewable power, or load shifting, to streamline your energy management system and to reduce greenhouse gas emissions. Contact us today at 914-584-6720 or at karell@CCESworld.com.

White House Issues Executive Orders to Bypass Env. Rules to Aid Economic Recovery

In May and June, President Trump issued several Executive Orders (one: https://www.whitehouse.gov/presidential-actions/eo-accelerating-nations-economic-recovery-covid-19-emergency-expediting-infrastructure-investments-activities/) to address the economic impacts of the COVID-19 pandemic, focusing on certain infrastructure, transportation, and civil works projects. The Orders are intended to expedite infrastructure projects by requiring agencies to take “all reasonable measures to speed infrastructure investments”, including exercising the emergency statutory provisions of various federal environmental regulations in order to bypass their procedural requirements. These apply to projects undertaken and managed by federal agencies, such as the Dept of Transportation, Dept of the Interior, Dept of Energy, Defense Dept, and Army Corps of Engineers.

Citing the state of emergency as a result of the pandemic, the Executive Orders also direct federal agencies to invoke specific emergency authorities found in federal environmental rules, such as NEPA, ESA, CWA, CAA, and others to shorten or eliminate environmental regulatory procedures to hasten projects to better expedite an economic recovery.

For example, the Order encourages agencies to utilize the emergency regulations and procedures under NEPA by allowing agencies to consult with the White House-based Council on Environmental Quality to develop “alternative arrangements” in emergency circumstances. These include statutory exemptions and categorical exclusions.

The Order calls on agencies to review and exercise all opportunities and guidance documents that may provide waivers, exemptions, or other streamlining with regard to agency actions on infrastructure, energy, environmental, or natural resources matters.

Agencies are also directed to:
• identify rules that may slow economic recovery and take legal actions to rescind, modify, or waive them;
• grant extensions of time in enforceable agreements that may harm recovery;
• use, if possible, any emergency authorities available to support economic growth.

Given it is likely that these Orders will be challenged in court, businesses should not believe that environmental rules will go away for them. The Orders may not offer a permanent waiver of legal requirements under federal environmental rules for a project. Therefore, the principals of any project may be subject to future challenges should it skirt established environmental standards.

CCES has the experts to provide technical assistance on compliance with federal and state environmental rules for any proposed project (Please consult legal counsel for determination of legal compliance). Our experts have decades of experience helping diverse processes comply with such air pollution rules. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Reducing Energy Usage of Data Centers

One study estimated that in 2018 global data centers consumed around 200 Terawatt-hours (TWh) of energy, about 1% of the world’s electricity consumption. This percentage has stayed flat for nearly a decade. While this appears to be a low figure, it still makes data centers a large consumer of energy. Certainly for individual businesses, data centers can contribute a considerable percentage of their electric costs.

Here are several trends concerning energy usage by data centers worldwide.

Improve energy efficiency. Given its growing need and use, any way an operator can use data centers more efficiently will save significant costs and equipment wear and tear. One such focus is IT infrastructure. Converged infrastructure (CI) is building blocks of functionalities physically combined in a turnkey product, including software for more efficient computing and storage and networking functionalities. This makes the data center more compact and functionally efficient, reducing electricity needs. In addition, ENERGY STAR recommends server brands that use less electricity than conventional ones. Simple upgrades like placement of equipment and sharing of information can improve electric efficiency, too.

Energy efficiency of IT systems is often measured by power usage effectiveness (PUE), the ratio of total energy used by a data center to that used by computing equipment. PUE has improved from 2.5 in 2007 to 1.67 in 2019, indicating reduced energy contribution from non-IT areas, such as cooling and lighting in energy consumption. Modern data servers are available that can function well at temperatures up to about 100⁰F, reducing cooling needs. Less energy intensive alternatives to air conditioning, such as using cool ambient air or chilled water from a nearby source can work to cool a center.

Increase in on-site energy generation. Data centers need a reliable grid as their source of electricity. But large centers put stress on the existing local grid infrastructure potentially causing instability, and outpacing grid infrastructure capability. Therefore, more data center operators are using on-site power generation from natural gas generators and fuel cells, known distributed energy resources (DER) or microgrid.

On-site power generation may work as a supplement or back up to the grid or be totally independent. Either way, the operator can plan operations based on needs over time. This goes hand in hand with energy efficiency which can minimize on-site power needs.

Focus on Climate Change Goals. Many companies are focusing on reducing greenhouse gas emissions and, therefore, reducing energy usage for functions, such as data centers. As a large user of electricity, data center sources of electricity vary, but most are fossil-fuel based.

Therefore, as companies build larger data centers that are often their own facilities, they have the opportunity to directly use renewable energy to power them. For example, Google is building 2 huge data center campuses, in Tennessee and in Alabama, getting about 72% of their power from devoted solar farms, producing as much as 300 MW of power. While ideally all electricity for such a campus should come from solar, data centers need ready electricity 24/7 which is currently not available from solar farms whose output is intermittent based on the sun. Google is looking into energy storage options to be able to use more renewable power. Some facilities alternatively purchase renewable energy credits (RECs) for renewable sources far away.

CCES has the experts to help you evaluate and implement strategies to reduce energy usage of data centers, as well as other functions of your facility. Contact us today at karell@CCESworld.com or at 914-584-6720.

Major Changes to Building Energy Code Are Coming

The 2021 International Energy Conservation Code (IECC) was all but finalized recently as members voted to go forward to finalize proposed changes to the energy code standards. The draft standards will be published shortly, followed by an opportunity for feedback and revisions before the final standards will be released, probably in late 2020. These standards are often used as a model for new laws and standards for new building design in many municipalities, states, and nations, saving energy usage and costs and cutting air toxic and greenhouse gas emissions from new buildings.

Buildings (residential and commercial) are responsible for about 40% of US energy usage and GHG emissions. Based on the probable final 2021 IECC standards, new buildings will reduce covered energy usage by over 10% on average compared to buildings meeting the 2018 IECC, and by more than 1/3 compared to the 2009 code.

IECC members voted late last year overwhelmingly in support of a number of proposals to strengthen energy efficiency requirements, such as requiring high-efficiency water heating; electric upgrades to allow easier future conversions to electrified equipment; increased installation of electric vehicle charging stations; and an optional pathway for municipalities to encourage construction of Net Zero or ultra-energy efficient buildings that meet their remaining energy needs with renewable energy.
One additional probable change compared to the 2018 IECC is that this edition will likely give building owners flexibility to meet standards in different, science-based, but non-prescriptive ways.

Some critics have complained that the IECC changes too often, every 3 years, and that adversely affects planning. On the other hand, technologies improve so quickly. Also, of course, when a building is built new, it will stay in existence and function (and use excess energy and emit greenhouse and air toxic gases) for decades. One does not want to “miss the boat” of having buildings incorporate proven, improved design or technology to lock in GHG emission reductions.

Speaking of energy codes, ASHRAE’s code, 90.1, was last revised in 2019. ASHRAE is already researching changes to their code that will be published in 2022.

CCES has the experts to help provide technical assistance to help you meet IECC, ASHRAE and other energy standards to minimize your usage and GHG emissions of existing or new buildings. We can help you economically reduce energy usage that not only save significant costs but enhance worker productivity and reduce O&M costs and effort. Contact us today at karell@CCESworld.com or at 914-584-6720.

Re-Opening Commercial Office Space For Viral Safety

More and more regions are allowing businesses to re-open despite a very contagious virus to offset the mounting financial losses of tenant companies, building owners, and employees. The intention, of course, is to allow commerce and other activities, while minimizing any new increase in COVID-19 cases or at least being better prepared to handle a spike in hospital admissions. This balance is the “new normal”.
But even with more businesses opening, the public is wary. Will they have the confidence to come out to shop, eat, work, etc. in your building? It is impossible to bring the risk of infection within a space to zero. But what can building managers do to minimize the risk of coronavirus infection of staff and customers?

Low-cost building upgrades and policies.

1. Communication. Signage, messages of CDC guidelines for people to see

2. Show safe movement. Map travel patterns within tenant, common space

3. Personal limits. Limit capacity of key places, such as conference rooms, kitchenettes

4. Change cleaning procedures. Increase disinfection frequency of high-touch surfaces

5. Provide personal disinfectants. Wipes and hand sanitizer stations

6. New seating arrangements, including installing shields between open desks

7. Automatic, non-touch equipment in restrooms.

8. Take temperature of all employees daily and of guests.

Technical guidance on changes to HVAC systems

Currently, information from major professional organizations focuses on person-to-person transmission of the coronavirus as the primary public health concern, ahead of HVAC operation, where airborne transmission is possible, but not considered high risk. However, changes in HVAC operations can reduce the risk of potential virus exposure. ASHRAE’s Epidemic Task Force recommends:

1. Increase outdoor ventilation (as much as possible) by enabling outside air economizers more often and by opening dampers.

2. Improve filtration to MERV-13 or highest efficiency level feasible. Often not noted is the importance of sealing filters properly to prevent bypass.

3. Provide additional outside air both before and after occupancy daily.

Of course, these changes to the HVAC system comes at a cost: increased energy usage and cost. An evaluation of additional energy use of extending HVAC use hours, upgrading to MERV 13 from MERV 8 filters, and letting in an additional 50% outside air above minimum found that overall these changes together would cause an increase of 3-5% in building energy usage for a typical office building, depending on climate region.

CCES has the experts to help your firm plan for your re-entry into your facility and do so in a safe and economical way. Be safe and do the right thing. We can help. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Roadmap for You to Reduce Energy Usage

As mentioned in another article in this newsletter, it is critical these days for your business to lower expenses, such as your energy costs, to be able to bounce back. Reduce energy usage and still be productive and make your staff and customers comfortable. There is no “magic wand” to achieve this; careful planning is needed. But success can happen! What follows is a roadmap, an approach that works to reduce energy usage and costs smartly.

• Determine your goals; determine your limits. Are you going “all in” on energy savings? Or just looking for economic opportunity? Both are valid, but it’s important to map it out. Conduct meetings with your Facilities staff, tenants, vendors, etc. to discuss the topic.

• Review utility bills and oil invoices. Determine energy use by metered usage. Benchmark your energy. Ideally, create a profile in ENERGY STAR Portfolio Manager to keep track and compare yourself to similar buildings. Review your utility bills. Are you properly classified? Who is your energy supplier? Are you under contract? Are you paying a fair rate? Can you take advantage of Demand Response and related programs to get paid for using little-used equipment?

• Conduct an initial energy assessment of areas or operations that you control and can upgrade. Count lights and plug load equipment. Learn the capabilities of equipment (HVAC, motors, pumps, etc.). Estimate your energy usage based on operations (i.e., number of hours operated). Does this estimate match up with your utility bills?

• Conduct a more thorough energy assessment and identify energy conservation measures (ECMs), strategies to reduce energy usage of key end-use processes that use a significant amount. What are the ROIs and simple paybacks of feasible ECMs?

• Identify opportunities for on-site renewable power (solar, CHP, geo-thermal, etc.)

• Evaluate and choose the ECMs for you, such as LED light retrofits, lighting controls, building envelope upgrades (roof, windows), HVAC repairs or upgrades, VFDs for motors, building automation systems (BAS). Which ones and in what sequence? This also includes identifying and applying for government and utility incentive programs.

• Implement your chosen ECMs. This is a lot of work. It is worth it to hire an experienced energy project manager to bring in bids, select the best vendor(s), and oversee work to ensure you are getting the savings that should occur. So you focus on your business!

• Measure and report results. Was the effort worth it? Are there future potential projects?

• Implement a regular commissioning and maintenance program. What is the use of procuring new, advanced equipment if it will not be properly maintained? Consider such regular commissioning and maintenance an investment, not just to maintain their energy efficiency, but also for them to last longer before needing to be replaced.

You know that smart energy upgrades are a great investment of resources, with an excellent ROI and payback. Emphasis on the word “smart”. This little guide shows you the necessary steps to do your upgrade right and maximize the cost benefits.

CCES has the technical experts to do a complete energy evaluation and project manage the energy upgrades that make the most sense for you. We are here to help you save lots of costs and have others pay some of the bill. Contact us today at 914-584-6720 or at karell@CCESworld.com.

5 Good Reasons To Apply Energy Conservation As Part Of Business Bounce Back

As this is written, the US is debating when and how to re-open businesses to bounce back economically yet maintain safety during the COVID-19 pandemic. While public health and economic experts debate strategies, eventually, businesses will re-open. Good energy management should be a part of the plan for any business. A smart energy conservation program has the following major advantages:

1. It is crucial to cut costs. For nearly all businesses, revenue will be slow to recover. With, sadly, many deaths and high unemployment, there are simply fewer customers to sell to. Thus, cutting costs is crucial to have any chance to make a profit or be viable. Being energy smart is a proven way to reduce expenses. What’s particularly powerful is that one-time actions to reduce energy usage and demand save costs year after year. After all, it’s not like after year 1, you’ll put back in the old, inefficient equipment! Energy conservation has a great ROI and a continual source of cost savings!

2. Financial advantages of being certifiably green. Consider raising the level of your building to LEED or Energy Star-certified. Studies have shown:
o 5-16% rental premium
o 6-31% sales price premium
o 3-6% occupancy rate increase

3. Competition for commercial tenants. Many predict that commercial building occupancy rates will drop in the future as more firms will allow staff to work from home. That means reduced occupancy and more competition to attract tenants. One way to beat the competition is with an energy efficient building allowing a landlord to charge less or, if the tenant pays utilities, reduce their expenses, a good way to attract those who must minimize costs. Plus, smart energy upgrades raise a building’s sales price.

4. Good for sustainability reports. More companies are compiling and posting sustainability reports and scorecards. More energy efficient workspaces, whether leased or owned, are big steps to showing positive results to stakeholders.

5. Others will foot part of the upfront costs. Many companies do not have or are reluctant to spend the needed funds upfront on energy upgrades. While our focus is on COVID-19, many parts of the country also have energy management concerns. Utilities and governments have reason to offer financial incentives to those that do energy upgrades, often paying as much as half the upfront cost. What a great opportunity to get a high ROI, attract more tenants, with others pay some of the upfront costs!

CCES has the technical experts to help you upgrade your energy systems in a smart and financially beneficial manner. We know incentives and can get you the greatest package you qualify for. We can not only tell you where it is best to upgrade, but we can project manage the upgrade to maximize the benefits with the least disruption. Contact us today at 914-584-6720 or at karell@CCESworld.com.

What the COVID-19 Pandemic Teaches Us About Climate Change

The world is fighting hard to minimize the health and economic impacts of the COVID-19 pandemic. Based on news reports, some nations have carried out policies that have achieved moderate success, while, in other cases, there has been failure. The crisis can provide us insights for ways to act for the next big global crisis we face: climate change.

The “good” news of the COVID-19 pandemic is that global actions can be implemented quickly when faced with a crisis. Except for a couple of outliers, just about every nation in the world did act, although some were painfully slow. Many nations deserve credit for actions, imperfect as some are, given that there is no “playbook” for handling this crisis. We are learning about the coronavirus “on the fly” and thus, prescriptive remedies (do this and the virus will disappear) do not exist. It is human nature to be careful and not embark on a strategy unless one is sure of success. That is not the case here. Nations implemented extreme lockdown measures, at the risk of upsetting their populations and causing economic hardship, to slow down the virus’s spread, without a guarantee of success (how compliant would people be? would it actually slow the spread?).

Another bit of “good” news coming out of the COVID-19 pandemic is that the efforts to combat the spread of the virus, such as the lockdown and closing of many businesses has resulted in noticeably cleaner air, as much data now confirms and pictures demonstrate. For those who worry we can never reduce greenhouse gas emissions, here is proof that it can be done. Now, how can we keep reducing levels even more as businesses re-open and people begin to move toward “normal”? Can some of these changes (telecommuting, home school, reduced auto/plane travel) become permanent?

However, the COVID-19 pandemic teaches us hard lessons in case of a future crisis or for dealing with climate change. Ultimately, the world was poorly prepared, despite warning signs, such as other pandemics (SARS, MERS, Ebola) causing huge numbers of deaths in recent decades. If we had planned for this pandemic using the lessons of past ones, COVID-19 would not have been avoided, but probably would have been less deadly. We now see early warning signs of climate change-caused effects on Earth. We should plan and invest smartly to lessen future climate change worst-case scenarios.

Another lessen is that national borders do not hinder the spread of the coronavirus. Thus, coordinated national and international planning and communication are critical. Even the many robust local responses to COVID-19 may be for naught if other places are more lax in containing the virus hastening its spread. We learned cooperation is critical for distribution of equipment (ventilators) and PPE. Thus, we must make an effort to coordinate a global response to climate change. Reducing global GHG emissions and coping with its worst physical impacts will similarly require concerted global action.

Finally, what will our economic recovery be like? It is an opportunity not just to bring economic activity to life, but, with a concern for climate change, we can recover smartly by favoring energy efficiency and clean energy which would also address the next crisis, climate change. It is a simple fact that for most businesses recovery will be slow. With high unemployment, few people have the money to buy what they have to offer. Thus, revenue recovery will be slow. That’s all the more reason that companies need to cut their expenses, and reducing energy costs is a very good, long-lasting way to do so and put yourself in a more competitive situation. CCES has the experts to suggest proven, company-specific strategies to significantly reduce energy costs and manage their implementation for your benefit. To minimize the inconvenience to reduce your expenses. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Spending More Time At Home? Make it Healthier and More Energy Efficient

Many of us are staying home. Whether we are working or staying home for safety, this is the most important thing we can do during the COVID-19 pandemic – stop the spread of the coronavirus. For many, our homes are a place to sleep, have a few meals, watch TV, and, maybe, not much else. But now that we are spending more of our time there, it is important that it be healthy for us and energy efficient for our wallets.

With many people having free time, this is an opportunity to upgrade your home to be more energy efficiency and healthy. The good news is that material is available to help you improve your home in these areas. For some, incentives exist so that others pay part of the cost. Many energy efficiency upgrades improve family health, as well.

Projects, such as improved insulation and sealing, reduce the impacts of extreme weather (the chance that your home will be unhealthily hot or cold) and reduces infiltration by pests and allergens, improving family health (fewer asthma or allergy attacks). If you are hesitant, remember that such projects also reduce the amount of heating and cooling needed, saving energy costs, making the effort more worth it.

And, remember that governments and utilities have incentive programs that pay out billions of dollars annually to building owners who implement an energy efficiency upgrade. The US Dept of Energy has a Weatherization Assistance Program to provide information and resources to help improve inefficient homes by offering costs to implement such projects or even to repair or upgrade existing HVAC equipment.

According to the American Council for an Energy Efficient Economy, in the State of Ohio, energy efficiency programs also resulted in positive health impacts, saving 187 lives and $1.5 billion in avoided costs in 2017. Similar results were seen in other states.

While upgrading one’s kitchen and entertainment equipment, insulation, windows, HVAC equipment, etc. are positive financial investments, simple changes in home procedures can also save energy costs and improve health.

• Cooking has become family fun time. It is best to clean and maintain kitchen equipment and perform operations at the same time.

• Hand washing is so important to inactivate coronavirus. However, many studies show that the water temperature is unimportant. Cold water cleans as well as hot or warm. Therefore, use cold water to wash hands. The use of soap is the key. The same is true of laundry. Cold water is as good as hot. And make sure your laundry and dishwasher is full before using.

• Adjust the thermostat based on actual use. If one is leaving a room or area, make sure the AC or heat is off in the area. Set the temperature to a comfortable and not extreme temperature.

• Use equipment efficiently. It is not good for one parent to watch one video, the other to stream an old show, and each child play separate games. Try to do activities (and use electricity) together and have fun, too.

The COVID-19 pandemic is making us all spend more time at home. Let’s make sure that they (for ourselves, family members, and friends) are healthy for us to live in (so we do not come down with another malady) and is energy efficient, too.

And remember, as we begin to move toward normal, such upgrades will also improve health impacts and energy usage of commercial buildings you work or shop in, too.

CCES can help you and your firm develop and implement appropriate, proven energy-saving strategies to improve health and save significant energy costs. Our technical professionals have done this for many different building and company types. Contact us today at 914-594-6720 or at karell@CCESworld.com.

Exemptions From Environmental Laws Due to Pandemic?

Our lives have turned around given the COVID-19 pandemic. How does this affect federal and state environmental laws? Most of these laws have emergency provisions to bypass or waive certain requirements. It is too early to know which laws are or will be affected due to this crisis, but some future changes can be anticipated.

One example is the dire need for more medical facilities to treat the sudden crush of COVID-19. Building such facilities normally requires the developer to get approved an environmental impact statement (EIS) and obtain environmental permits for potentially large source of air pollution and chemical management, solid waste, and wastewater treatment systems. However, we are clearly seeing under the federal declaration of an emergency in mid-March and state government declarations the rapid construction of medical facilities, typically in large facilities unable to be used for its intended purpose during the crisis, such as a convention center, without permits dictated by the National Environmental Protection Act (NEPA) or EISs.

NEPA contains no emergency exemptions. However, the White House agency, the Council on Environmental Quality, has authorized agencies to go forward with projects independent of NEPA in emergency situations. In addition, after 9/11, the USEPA used that situation to allow certain actions that would otherwise violate the Clean Air Act, such as for trucks needed at the sites during the recovery period.
New York, the state hit hardest by COVID-19 as this is written, has regulations that exempt from needing an EIS emergency actions that are immediately necessary for the protection of life, health, property or natural resources, provided that such actions are directly related to the emergency.

New York also allows its governor to issue an executive order to temporarily suspend any rule or regulation of any agency during a state disaster emergency, if compliance with such a rule would hinder any action necessary to cope with the disaster. Governor George Pataki declared an emergency the day after 9/11 and suspended regulations regarding transportation and management of solid waste during the debris removal operation and the building of the Freedom Tower at 7 World Trade Center. The current governor, Andrew Cuomo has declared a state emergency over COVID-19 and is prepared to suspend rules or policies in order for hospitals to properly function to serve the growing number of distressed patients.

How might the current COVID-19 pandemic affect companies complying with environmental requirements? How might staff illness, sudden lack of revenue (needed to comply with rules), supply chain disruptions, and change in priorities affect firms in the near term? Will agencies recognize the stress that companies are under and relax rules in order temporarily to allow them to survive? Might agencies relax certain rules altogether for all subject facilities?

What happens to companies that are in a consent decree with an agency to perform specific environmental obligations in an emergency? There may be situations where the COVID-19 pandemic may be considered a force majeure event, excusing the firm from some obligations as there is a true inability to obtain equipment needed to comply. Is a company’s lack of revenue due to a lockdown considered force majeure? Traditionally, lack of funds does not qualify, but recent business declines have been so great and sudden that some believe that this should excuse a company from compliance, too.

Please note that this article is not meant to be interpreted as a legal document. It is meant as a general overview. On all related matters, please refer to qualified, experienced legal counsel before making any decisions. CCES can assist you on technical matters related to environmental compliance, providing you with technical options to comply with regulatory, permit, or consent order requirements or standards. Contact us today at 914-584-6720 or at karell@CCESworld.com.