Category Archives: Air Pollution

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.

Best Practices to Protect Your HVAC Equipment

By Bud Hammer, Atlantic Westchester

As many facilities are having to reduce operating hours or temporarily cease operations, it is important to still maintain your building’s environment as well as your bottom line. Building owners and operators are actually in a position to take precautions to help prevent spread of infections. When you return to full capacity at your building, the reassurance of improved air quality and facility safety is a must.

There are things that can be done with your HVAC systems to support a healthy indoor environment and help protect against the spread of flu viruses like COVID-19. Here are some recommended procedures to follow while buildings are closed or minimally staffed:

1. Keep HVAC systems running. Even if buildings are unoccupied, insufficient temperature and humidity control can lead to mold growth.

2. Reprogram standalone programable thermostats and adjust BAS/DDC temperature setpoints and occupancy schedules to avoid unnecessary spend.

3. Maintain a temperature between 55⁰F and 80⁰F and a proper indoor relative humidity (50% RH) maximum humidity of 60%– Viral transmission occurs at higher rates when indoor humidity levels are either very low or very high. Studies have shown higher person-to-person transmission levels occur when indoor humidity is lower than 40% RH than occur at 50% RH. This has to do with the evaporation process. Increasing the reliance on outside air can help increase the humidity in commercial buildings to an optimum level to help inhibit airborne transmission of viruses.

4. Use high-efficiency filters, preferably HEPA (MERV 13). Upgrade filters. High-performance filters (MERV 14-16) can remove particulates down to the size of the COVID-19 virus. Filters come in a variety of ratings. As their rating increases, so does the price. Standard pleated air filters entrap larger particles and are sufficient for most purposes, but they cannot scrub the air of bacteria and viruses. Improved filtration may be worth the investment given the great concerns about viral transmission. Supplies of these filters are limited.

5. Clean air ducts and coils.

6. Perform any preventive maintenance now (HVAC, power, and lighting assets) while buildings are unoccupied.

7. Exercise your emergency backup power systems to ensure uptime when needed.

8. Augment staff for increased connectivity to suppliers and reduction of potential downtime.

9. Increase the volume of outside air (OSA) to achieve more air changes – HVAC systems are the source of fresh outside air for occupants. Increasing the amount of OSA reduces the amount of recirculated air through the HVAC system. “Ventilation represents a primary infectious disease control strategy through dilution of room air around a source and removal of infectious agents” (CDC 2005). Replacing contaminated indoor air with fresh OSA is an important step in improving occupant health. ASHRAE is the organization that sets the standards for the HVAC industry. Its most recent advisory guidelines states that now is not the time for energy-saving techniques like demand control ventilation (DCV) that reduces the amount of OSA. We recommend increasing outside air levels to 20% – 40% of the air handling capacity of the HVAC unit. The mild temperatures of spring reduce the energy penalty that this action would otherwise create under more extreme summer or winter outdoor temperatures. Units equipped with variable speed fans can cost-effectively accommodate an increase in ventilation rates.

10. Ensure equipment is in proper working conditions. All of the above recommendations assume equipment is in proper working condition and supply fans run continuously whenever the building is occupied. Commercial buildings should never run in the “auto” mode unless steps are taken to periodically “over-ventilate” the building. It is common for retail and small offices to run fans improperly. Make sure to educate your tenants and facility teams on the importance of running fans continuously. It is established in the building codes and national standards.

Atlantic Westchester (AW) is a commercial Heating Ventilation Air Conditioning (HVAC) company dedicated to making buildings smarter while providing the highest quality service in the industry. Since 1961, AW has catered to clients across the NY metro area with proactive maintenance, remediation and installation services based on their unique facility needs. Our professional, well-trained team works as a trusted partner to provide our clients with intelligent, energy-efficient solutions that optimize building performance, lower operating costs, and improve comfort. For more information, AW’s website is: https://www.atlanticwestchester.com/ or contact Ms. Cathy Hoffman at choffman@atlanticwestchester.com or at 914.666.2268.

Reduced Activity Caused by COVID-19 Leads to Drop in GHG and Other Air Emissions

Greenhouse gas (GHG) emissions have fallen sharply since the growth and spread of COVID-19 as activity from business and travel has slowed, according to experts. For example, according to a BBC report, traffic levels are down by about 35% and carbon monoxide levels are down by nearly 50% in New York City compared to the same time last year.

Closures of factories in China during the outbreak caused a significant drop in smog levels. Air pollution levels in Italy have dropped, too. In both nations, millions of people were kept under lockdown or quarantine to slow the virus, reducing business and other activities. The decline in emissions has been confirmed by NASA and European Space Agency satellites. In the US, where 50% of car trips take people to or from work or school, where so many have been closed, similar declines are expected.
According to https://www.bbc.com/news/science-environment-51944780, by May, scientists predict that GHG emissions may be at their lowest levels recorded in a decade, since the Great Recession.

One area where the business slump will significantly reduce GHG emissions is the airline industry as some studies believe CO2 emissions from air travel may have a disproportionate effect on heat trapping. The severe slump that the airlines are facing would mean significant reductions in their contribution. Therefore, airlines are expected to push back against proposed European climate change taxes meant to address the industry’s outsized effects.

There is concern by many in the environmental field that this downward spikes in GHG and other emissions are temporary and will result in a bounce back when economic conditions return to close to normal. In fact, there may be a major increase in emissions as people “catch up” on lost travel and other manufacturing opportunities. This has been observed after financial crises and terrorist attacks as those reductions in economic activity, such as certain manufacturing, driving, and air travel were temporary and then bounce back. On the other hand, some are predicting that social distancing practices that many are implementing, such as more home cooking, remote meetings and working and learning from home, may gain traction and become the norm even after activity approaches normal again, cutting back on manufacturing, transportation, and agricultural GHG and other emissions in the long-term.

CCES has the experts to help you assess your greenhouse gas and other air toxic emissions from your operations and project future emissions in a recovery or for other changes. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Air-conditioned Indoor Spaces Increase Risk of Viral Exposure

A majority of the coronavirus COVID-19 exposure human clusters reported globally are in air-conditioned indoor environments, such as nursing homes, cruise ships, places of worship, hospitals, etc. Why? There are two potential explanations. Clearly, people prefer comfortable air-conditioned indoor environments. Being more comfortable makes occupants spend more time in the space and be more social than if they were less comfortable. At the same time, keeping the air temperature and relative humidity in these comfortable ranges also prolongs the viability of viruses. Such an environment allows COVID-19 and other viruses to live for several days on indoor surfaces and in the air, increasing the likelihood of transfer by human to human contact.

Activities such as touching, coughing, sneezing, and talking generate large quantities of viruses to pass through the air and deposit, not only on other people, but also on indoor surfaces which others can touch and be exposed to. One study showed that viral particles expelled from people are small enough, 0.3 µm or less, to linger in room air for several days. Research shows that both indoor air temperatures and a low relative humidity that people favor also lead to long periods of their viability on surfaces and indoor air. This, therefore, increases the risk of infection with a virus like COVID-19.

This corresponds to “well” air-conditioned spaces, such as the typical, comfortable temperature range of 71⁰F to 75⁰F and a relative humidity range of 60-70%. Research suggests that infectious viruses would lose much of their viability if the temperature of a space is raised to 90⁰F or more and a relative humidity of 90% or more. However, such conditions would lead to the growth of other biologicals, such as mold, and would volatilize chemicals, such as VOCs, in indoor areas, which have their own health impacts, not to mention such conditions are not safe for humans, particularly the elderly.

Of course, the most pragmatic solution, as public health experts have told us, is behavioral. Thorough hand washing water and soap and regular face washing are effective in reducing the risk of getting infected with a virus, social distancing, and staying home if one has any infectious symptoms.

If a building is shut down because of the possibility of COVID-19 presence, a thorough cleaning with disinfectant is useful, but may not be the complete answer. While major areas which people contact (door knobs, bannisters, chairs, etc.) should be thoroughly cleaned, missing one spot could still lead to spreading exposure given COVID-19 can survive for days. Building management may wish to consider, in addition to a thorough cleaning, the temporary raising of the temperature and relative humidity to the levels listed above to aid in reducing the viability of viruses. This may not be the complete solution either, as it depends how effective the HVAC is and whether that temperature and relative humidity can be reached in every affected area of the building where people may be occupying. However, this is something to consider.

CCES has the experts to help you in designing and operating a good, effective, safe HVAC system and can work with public health experts to assess COVID-19 or other potential health impacts. Contact us today at 914-584-6720 or karell@CCESworld.com. Please act and be safe these days!

Something to Remember for a New Decade

We all know that a healthy diet, moderate level of physical activity, normal body weight range, not smoking, and low drug/alcohol intake are lifestyle choices that, according to the literature, should result in significant benefits of reducing occurrences of various illnesses and risk of premature death through stronger immune and cardiac systems.

However, a person adhering to such healthy lifestyles but with regular exposure to toxic air pollutants at high concentrations or low concentrations but for extended periods has a risk of losing these protections and exhibit higher incidents of premature death or illness. For example, the literature shows that certain compounds that enter our bodies can significantly reduce the effectiveness of the immune system, and we can be exposed to many of these compounds through the air we breathe. These adverse effects can occur even if one adheres to the other healthy lifestyles discussed.

An increase in mortality and hospital admission rates and sick building syndrome (SBS) correlates strongly with exposure to airborne particulate matter, ozone, certain volatile organic compounds (VOCs), and other identified toxic air pollutants. Public exposure to these compounds can occur from indoor and from outdoor sources. Given that people spend the majority of their time indoors, indoor levels of toxic air pollutants must be a growing concern.

Yet, we can’t not breathe, right? In the U.S., we have a network of thousands of monitors that tell us the levels of certain pollutants throughout the nation, and we have decades-worth of data. Therefore, a person can choose to move to a “cleaner air” area. However, even if a person moves to such an area, he/she is still at risk for two reasons. First, in some cases even a single exposure of a key air toxic (carcinogen) could, theoretically, cause cancer in that person. Second, even if an area is in attainment of national ambient air quality standards, a micro area, such as a street on which many cars and trucks travel and emit gasoline byproducts or an indoor area both away from a monitor, can provide the source of air toxics to cause adverse health effects.

So while we all made New Years and new decades resolutions to undertake healthier life style choices (and hopefully keeping them, several weeks into the New Year), don’t forget to keep in mind air quality. Take the time to consider potential exposure of you and your family and friends to air toxics that can negate these good lifestyle choices. What can you do? Consider minimize walking or spending time in areas of high automobile or truck usage or endeavor to live and work in indoor areas that are well ventilated and use water-based coatings and cleaners with less toxic compounds.

Have a happy and healthy 2020 and beyond.

CCES has the experts to assess the potential sources of air pollution in your neighborhood or indoor air environment and help you develop a plan to make your spaces cleaner and better for you. Contact us today at karell@CCESworld.com or at 914-584-6720.

Tips for Indoor Painting Projects in Occupied Buildings

The weather is cold out there. You have projects to do for your buildings, but they all must be indoors now. But that leads to problems. Say you have a major painting job in your building, but you are under pressure not to inconvenience staff or customers. The paint job must be completed in a way that is least disruptive to daily operations.

Minimizing disruptions, of course, is something that should be taken into account in all projects, as is the health and safety of occupants and workers. While one normally focuses on keeping aisles clear for occupants to safely move around, it is also important to be aware of maintaining indoor air quality (IAQ). Therefore, look for effective coatings that also contain low or no volatile organic compounds (VOCs). They are not only better for IAQ for those potentially exposed, but give off less odors, reducing distractions.

IAQ issues are easier to address. A growing number of coating manufacturers make a line of paints with definitively lower emissions, and some directed to sensitive groups, such as children and the elderly. This is particularly helpful with projects in schools or healthcare facilities. Quick-drying coatings are advantageous. Odors are more subjective and is up to the individual. Emotions and other factors influence whether odors are detected and found to be annoying or distracting. As they say, “Somebody will always complain.” Odors top this list.

How to Start

Set a schedule so that painting is performed when there are the least users around and arrange ahead of time to stick to this schedule. For some facilities, it may or may not be a good idea to paint early in the morning when only a few people are around. It may be a good long-term strategy to paint late in the day and even let workers go home a little early. And paint into the evening. Perhaps there is a major meeting; that may be a good time to get in an hour or two of painting. Be sure to communicate times to affected staff, including which equipment or functions may not be available at what times to staff.

While Painting Goes On

Have sufficient fans present to blow the air, blowing away odors and VOCs and hastening the drying process. Be sure to rope off the areas that employees or customers should not trespass while painting goes on. One certainly does not want the enmity of somebody who accidentally gets in contact with wet paint.

Do the Job Right

One would like to minimize disturbances in the long-term. Therefore, use high-quality coatings that are durable and can withstand frequent cleaning and other conditions in the space (humidity, people effects, etc.). While this may cost more upfront, the building will save much in the long-term in reduced O&M efforts and costs and not having to paint the space again is some time.

CCES has the experts to help you plan all types of upgrades of equipment, between planning operations to procurement of equipment and commissioning that the installation is effective. Contact us today at karell@CCESworld.com or at 914-584-6720.

Energy Efficiency Programs Can Help Users’ Health

Many articles in this series show how building design can influence energy usage. Characteristics can be built in to save energy usage and cost, independent of behavior. These same energy efficiency strategies can also influence the health of those that spend time in the building, whether residents or workers who spend 40 hours per week there. A recent article from the American Council for an Energy-Efficient Economy compiles recent evidence behind this conclusion. https://aceee.org/research-report/h1901

A poorly-sealed building envelope not only allows conditioned air, which required energy to be expended (electricity or fuel combustion), to leave, but also allows pests, moisture, and air pollution to enter interior spaces, raising the exposure of users to allergens, mold, and disease. Leaky windows and poor insulation can lead to drafts and extreme temperatures, triggering asthma attacks and leading to other respiratory illnesses. Inefficient appliances can affect air quality through incomplete combustion or improper venting. Together, these conditions contribute to increased rates of cancer, chronic respiratory diseases, heart disease, and stroke in the US, disproportionately affecting low-income people.

Energy efficiency programs can make homes healthier and save lives, while directly benefiting families financially. The problem is that energy efficiency upgrades require upfront costs to correct a condition or procure a new or better technology, upfront capital that poorer families (or companies) do not have.

The link between energy efficiency and public health is not recognized as energy efficiency programs have historically been implemented either by energy utility companies or government agencies focused on energy management; there has been no or little contribution from public health institutions. It is recommended that research be done to identify energy program elements that would also have the greatest impact on public health and data collection of collateral public health effects in buildings after undergoing energy upgrades. This bridging the gap may need the intervention of other government agencies, such as departments of health and housing. For example, elements of the national Affordable Care Act can use energy efficiency programs to help its goal of a healthier society (making fewer health insurance claims). If a given community is a focus of a weatherization or home energy efficiency program, data should be collected, not only concerning the amount of Btus of energy saved by the program, but also whether there has been a reduction in the number of emergency room visits for children experiencing asthma attacks, for example.

While the ACEEE study followed 23 potential frequently measured health indicators, most programs tracked 3 or fewer of them. Many of the energy programs did take steps to assess and communicate their health impacts, and, in some cases, bring in health care professionals to raise the effectiveness of the program. More needs to be done to show this cross-effectiveness of energy efficiency and health.

CCES has the experts to help you assess not only the cost savings of a potential energy efficiency program, but the potential health benefits, as well. We can help you design a program to measure and heighten beneficial health effects as your reduce energy usage, costs, and greenhouse gas emissions. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Asia Moving From Smokey Energy To Renewables

Momentum is building for green energy in Asia, a region long known for fossil fuel dependency. Asia uses a lot of some of the most polluting sources of energy around, coal and wood. Particulate pollution from coal power plants and from individuals burning wood in non-professionally designed and built units is thick it coats buildings, cars, and, most important, lungs. There are many images of Asians associated with masks performing routine events on a daily basis.

But things are changing. China was faced with worldwide shame and condemnation at the Olympics it hosted in 2016 by the images of people and athletes wearing masks or breathing from oxygen tanks to avoid the toxic smog – despite efforts to clean the air in the months before the games. Ironically, China was the number one manufacturer of solar panels then, but nearly all for export. However, China quickly changed its policy, learning that the visible and potent air pollution not only made them a laughing stock, but had an adverse effect on their economy given the robust health effects it has on workers (lost productivity) and costs to take care of so many sick – costs and lost lives that could have been avoided. Plus, the government understood that visible air pollution was a factor that could lead to unrest and rioting. China now has the world’s largest installed capacity of renewable power, accomplished in a short time.

Vietnam is another example. This country had been aggressive in growing economically and attracting capital investment in industrial facilities. However, the huge growth in coal-fired power plants and wood burning from convenient jungles has worsened the country’s air quality and causing profound health effects. They are on an ongoing path to reduced fossil fuel combustion coordinated with economic growth.

Other Asian nations have realized that it is critical to invest in clean energy and green technology, not only for the sake of climate change, but also for healthier air quality and a better economy. And they are doing so. The collapse of a fossil fuel power plant in Laos that killed 40 people was another spur toward renewables. Governments are investing in renewable power and have learned it is less labor intensive and now less costly to build. While it is unlikely that renewables will fully replace fossil fuels soon, more Asian countries are investing in renewables.

Working with US and European giants like GE and Siemans, several Asian companies are now planning to build renewable projects. Thailand’s Meta Corporation is a leader, preparing to design a 220-megawatt solar project in Myanmar, the region’s largest project. Philippines’ AC Energy plans to spend over $1 billion on solar and wind projects by 2025. India is expected to invest $80 billion over the next 4 years in wind energy. Like China, India has massive public health problems due to air pollution yet is trying to expand electricity to the over 400 million people who have no access to it.

Of course, coal is still king in such nations as China and Malaysia. While renewable technology can replace coal, these and other governments feel an obligation to coal workers and are afraid of potential disruptions that could happen of anything “new.” So there is a lot to overcome financially and psychologically before Asia is high in renewables.

CCES has the experts to help you assess your company’s energy needs and sources. We can help you plan to have a resilient, flexible group of energy sources and determine if renewable power is right and beneficial for you. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Rooftop Gardens As A Sustainability Strategy

Some entities understand the financial benefits and would like to be more sustainable, but are under some pressure to have a “showcase” project that is more interesting and picturesque than energy efficiency or upgrading sophisticated equipment. If you are in that situation, consider rooftop gardens as an effective way to be more sustainable, gain benefits, and have a great “photo op.” Particularly in urban areas, rooftop gardens bring some greenery and an area for relaxation into a “concrete” space.
Rooftop gardens are essentially backyards atop one’s building, bringing “nature” into an otherwise sterile space. Rooftop gardens can be either vertical or horizontal and is an effective way to reduce the heat load on your AC system, saving on energy bills.

Rooftops are, by nature, urban heat islands, absorbing the sun’s radiation and giving off energy slowly, resulting in massive pockets of hot air. In an urban environment of many dark-colored roof tiles and concrete streets, cities are particularly prone to higher than normal summer temperatures because of heat islands, which contributes to worse air quality and mental and physical health concerns. In addition, energy being kept in and close to buildings raises the demand for air conditioning and other cooling equipment, making it work harder and for longer causing a significant rise in energy usage and putting a strain on the local energy grid, which some utilities have trouble maintaining. In addition, the building owner pays for the urban island effect big time as more utilities put a premium charge on high peak demand during the cooling season (summer). Even if a building has one 15-minute period in a month of very high cooling demand, it will be charged a very high amount for this single short-term spike in demand. In addition, heat islands damage roofing material, requiring the building owner to upgrade it more often than if a rooftop garden is installed and maintained to protect the building’s materials.

Rooftop gardens can mitigate this effect because the plants absorb the sun’s radiation, not the roof shingles or underneath part and the shade offered by plants reduces heat transport, resulting in cooler temperatures and improved air quality.

A recent study found that an exposed roof can get as hot as 158⁰F on a sunny day while an identical roof with a rooftop garden covering most of the roof stayed relatively stable at a temperature of 77⁰F (https://www.thespruce.com/green-benefits-of-a-roof-garden-1708536). In addition to providing natural cooling, rooftop gardens can provide a natural sound barrier, delay stormwater runoff, and provide filtered rainwater.

It is critical that the building owner bring in an experienced qualified roof garden designer and installer, who can check about any local permits and regulations that must be adhered to in your jurisdiction. Be sure that the designer assesses your building to determine whether it can hold a rooftop garden, that it can be waterproofed, or whether normal temperature extremes in your area may damage a roof garden or roof. It is crucial to choose the right types of plants depending on your local climate, such as winds and temperature extremes. If this is an office building with periods of inactivity, it may make sense to include low-maintenance plants, needing little water or pruning.

The cost of a rooftop garden will depend on many factors, such as size, plants selected, and construction materials used. A rule of thumb range of initial cost is $15-$40 per square foot of space. However, you should quickly begin to save money on energy bills and a payback in a reasonable time is likely, plus it should advance the building’s asset value and attractiveness for other potential tenants.

CCES does not perform rooftop garden design or landscaping. But we can manage professionals in these fields to do the proper work to install one to maximize your benefits. In addition, we can perform a sustainability assessment of your buildings, company, or assets to determine which strategies are most effective to become more sustainable and to optimize the financial benefits. Contact us today at 914-584-6720 or karell@CCESworld.com.

US EPA To Classify Wood Burning as Carbon Neutral

The US EPA recently stated its plans to propose a rule that would classify combustion of forest biomass from power plants and other sources as carbon neutral.

The US EPA has struggled to develop an accounting framework for biogenic CO2 emissions for a decade as part of its effort to regulate GHG emissions under the Clean Air Act, as it must based on a Supreme Court ruling. The US EPA has modified Title V, New Source Review (NSR), and other programs accordingly. For example, NSR is triggered by net emission increases of proposed new or modified plants or operations and requires certain emission reductions. How does one count the CO2 generated from wood-burning equipment, given that the carbon given off comes from the ground and the CO2 generated can be absorbed by other biomass? The US EPA has performed a lengthy process to research and assess whether combustion of biomass is truly carbon neutral and whether such treatment of biogenic CO2 emissions is valid.

In 2011 and then again in 2014, the US EPA published draft technical reports containing frameworks for assessing biogenic CO2 emissions associated with biomass combusted for power generation at stationary sources based on a carbon lifecycle approach. Peer review of the second draft report has not been finalized due to accounting and calculation disagreements. Therefore, the answer to the question of how to account for GHG emissions from biomass combustion has not been settled until now.

On April 23, 2018, the US EPA issued a policy (stated as a non-scientific) statement (https://www.epa.gov/sites/production/files/2018-04/documents/biomass_policy_statement_2018_04_23.pdf) that future regulatory actions would treat as carbon neutral biogenic CO2 emissions from the combustion of biomass from managed forests at stationary sources for energy production. The policy statement intended to reduce environmental barriers and, thus, encourage the use of forest biomass for energy at stationary sources.

On April 2, 2019, US EPA Administrator Andrew Wheeler told lawmakers that the agency intends to propose a new rule that would treat biogenic CO2 emissions from power plants as carbon neutral. The proposal is expected this summer and, if adopted, the rule will have implications for the power generation industry

Besides changes in emission accounting in NSR and similar air quality rules based on this potential rule change, this potential rule also has impacts on forest policy. Currently, there are few certifications that qualify a forest for federal procurement opportunities. However, if biomass combustion is considered carbon neutral and less negative compared to the past, then the number of forests that could participate in federal procurement opportunities could increase. In the private sector, this could make it easier for companies to claim sustainable environmental practices and meet established sustainability criteria.

Declaring biomass combustion as carbon neutral may provide states with more options to meet their Renewable Portfolio Standards (RPS). Nearly 40 states have their own RPS, which requires a specified percentage of saleable electricity to come from renewable sources. If biomass combustion is considered carbon neutral, it can be an additional option for a state planning to meet its RPS goal.

CCES has the experts to help your facilities manage your energy usage and to provide workable strategies to diversify your fuels and energy sources for greater future flexibility and meet your sustainability goals. Contact us today at 914-584-6720 or at karell@CCESworld.com.