Category Archives: Climate Change

Be Careful Of What We Say In Environmental Communications

There has been a lot of talk and concern about the lack of scientific thought in many of the pronouncements of the Trump Administration. Scientific facts are discarded and simplistic non-truths are becoming the backbone of some decisions in the energy, environmental, and health areas. I don’t mean to play politics here, but this seems to be predominantly the doing of the “Tea Party” and other right-wing groups, trying to deny the validity of climate change and the importance of environmental stewardship, all in the name of “small” government or short-term economic and jobs growth.

As an engineer and citizen, I feel this is terrible. But, this has been well-covered, and I don’t wish to “pile on” here. I do want to note that this is not unique to the right wing of the US political spectrum. I have seen examples of scare tactics and lack of reasoning from the left wing environmental community, also. We need to be vigilant and hold all sides accountable. Everyone (right or left) is entitled to their opinions, but not their facts.

What brings this to mind is an environmental group local to where I live (which shall remain nameless) which puts out many misleading emails and articles, that a common situation is so untenable, that it will lead to public health or environmental disaster. The other thing they do is attack a certain facility or process, demanding it be shut down without discussing what would replace it.

I know the person who runs the organization. She’s smart and has quite a personal story. I have tremendous respect for her. But she has only superficial knowledge of environmental matters, and, again, feels that everything is a tragedy about to happen.

A few years ago, we both gave presentations at a local environmental event. I gave an overview for the general public about what climate change is and what scientists know about it. In explaining greenhouse gases, I stated the fact that GHGs are not in and of themselves toxic even at elevated concentrations, but cause the trapping of radiation to conserve energy from leaving into outer space. We have lived in balance with a certain GHG concentration in the atmosphere, but now are affecting it adversely. Afterwards, she took me aside and berated me for saying anything “positive” about GHGs. They were the bad guys, in her view, and needed to be seen as such. I challenged her to find any published article that states that GHGs have direct toxic effects and I’ll personally apologize to the event organizer and reach out to every attendee with a correction. She never did (of course). I told her the only way we can fight climate change effectively is for the public to fully understand the topic. It is not simple (“good guy” vs. “bad guy”) with a simple solution if only governments understood as she does.

Her organization is sponsoring a movie about zero waste and she put out an email about it and advocating the shutdown of our county’s waste-to-energy facility. It releases toxic compounds, she wrote, affecting all our health. We are in a dangerous area with high ozone and particulate levels. We must shut down the facility ASAP.

There are so many holes to her arguments. Zero waste is a great concept; I am for it. However, cities (San Francisco comes to mind) have had this as a formal goal and spent millions to research and implement and has failed. This is not something that will be achieved overnight. Even if the techniques and technologies are developed to do so, there is always the implementation by cities, counties, etc. and the willingness of the public to use them (many don’t like change or an added expense). As for the waste-to-energy facility, yes, it is certainly not emissions-free, but it operates under a Title V Permit which mandates compliance with several state and federal air quality rules specific for such facilities, developed with public health in mind. It has continuous emission monitors and does annual testing to ensure these emission standards are met.

The county that the facility is in (as well as where the movie is being shown) was recently moved from severe to moderate ozone non-attainment, and has not had an exceedance in nearly 3 years. Besides, it has been demonstrated that most of the ozone forerunners come from sources many miles upwind of our county. This facility is not the cause of the current ozone non-attainment, nor would shutting it down solve this. The county meets the particulate attainment standard (why did they say it does not?).

Finally, the statement from the group demands the immediate shut down of the facility. Fine. But what would one do with the garbage? The alternative is to truck it to a landfill, hundreds of miles away. Given the size of the facility, that would mean hundreds of trucks traveling this distance daily, combusting diesel fuel oil. The use of any fossil fuel is another frequent target of their attack. So they are indirectly promoting a solution they oppose. Conveniently not mentioned in the email! Not to mention this alternative would require many workers to be in contact with the waste, risking their health. And not to mention the methane gas and other pollutants potentially emitted from the landfill. Methane is 21 times more potent than the CO2 emitted from the waste-to-energy facility.

So, we in the environmental community also need to be careful what we say in our writings. That what we say and write is scientifically grounded, thorough, and accurate; is not wishful thinking nor simplistic; and that alternative scenarios are thought through.

I am curious your thoughts and experiences. Please let me know what you think of this.

CCES can help your company develop a science-based, effective environmental and energy program that can meet achievable goals and can help you communicate this with the public and with regulators. Contact us today at 914-584-6720 or at karell@CCESworld.com

Changes to Lights: You Won’t Recognize Them!

Lights as we know them are changing radically and probably quite fast.
In many technological upgrades, the upgrade is introduced first, but is slowly implemented as it is expensive. But as more competitors get into the business, both raw materials and the manufacturing process drop in cost, so that the upgrade becomes more affordable and with its advantages, takes over the market. This is exactly what we are seeing with LED lights. Initially, many people and companies while recognizing the steep drop in electricity usage, put off purchasing them because the upfront price was so expensive, even with government and utility rebates. But now raw material costs and global competition have forced prices downward, shortening the payback. So much so that many government and utility LED incentive programs are being slashed or even eliminated. Why provide a rebate when the technology is affordable? The payback is shortening so much and LEDs are so useful and reliable that it is a real “no-brainer”.

Similarly, occupancy sensors and other controls will be fairly standard, too. They have become more reliable since the days when sitting still in a room would lead to lights turning off. And, now due to “Alexa”, the whole concept of lighting control has changed.

Which leads me to my main point. Not only is lighting control changing, but the concept of lights is changing. For a century, lights were these bulbs that emit lumens of light after an external signal (electricity) turns on and off the mechanism of burning (in tungsten in an incandescent). A physical effect causing the ability of the bare bulb to produce light. But now, lights are no longer items that just produce light. Lights in a ceiling or outdoors are now becoming little computers that can both do many things and be controlled easily through the internet. Besides being turned on and off, they can be dimmed or made into strobes or other waves, or emit different color light over time, such as dimming or making a warmer tone close to bedtime. The miniaturization that allows a whole host of functions on an easy-to-hold cell phone can allow a simple “light bulb” in a high hat in a ceiling to perform many functions – even outside of lighting, such as being a sensor with a loud alarm or projecting onto a screen.

These functions can be controlled (turned on and off or made more or less intense and timed) using a cell phone or another computer hooked up to the Internet. You have probably already seen how Amazon’s “Alexa” can turn on and off lights (and other appliances and devices) with simple verbal instructions. There may be a day very soon where light switches on the wall are obsolete and no longer designed in buildings, as all lights will be controlled by a human voice. Apple’s “Siri” and Google’s “Home” are moving in this direction, as well.

The major LED light manufacturers (Philips, Cree, Lutron) already sell “smart” bulbs that can be wirelessly controlled though your home’s Wi-Fi. You are probably familiar with those circular timers that are plugged into an outlet and the lamp plug goes into it. When the time is a certain time, the raised portion turns on or off the electricity turning on or off the lamp. This same effect can now be done wirelessly. You can program into your PC or cell phone the times to turn on and off lights (for example, on at sunset, off at bedtime). You can program them to turn on or off groups or individual lights in a room or change their brightness to create the atmosphere you want (for doing desk work, for cooking, for eating, for watching TV) when you want.

The voice-activated systems, like “Alexa”, allow quick changes from programmed timers. Alexa does not have to be in the room with the lights whose timing needs to be changed. Certainly an advantage of any of the voice-activated system is to turn on lights in the dark when one is concerned about falling or tripping. Alexa, of course, operates through Google’s “Echo” voice system, a physically standing system in one or several rooms. Apple does not operate such a system for Siri. One would need to speak into a cell phone to give Siri directions which it could use to control lights. Cell phones are often forgotten or misplaced. A standard Echo system always in a particular room may – for some – be more reliable.

Smart lights can also be used for commercial purposes. Imagine a retail store changing the lighting patterns to emphasize certain products on shelves or mannequins based on the outdoor light and customers present and other factors. Imagine a manufacturing facility adjusting lights to the needs at a particular phase of the manufacturing process.

And – here’s a scary thought after we have spent so much time educating the public on LEDs – may they soon be obsolete? Growing research shows that lasers can be used in many lighting applications successfully and using less energy. Stay tuned.

CCES has the experts to help you evaluate, design, and install the most efficient, sturdy, and flexible lights for your building and usage, while maximizing the financial benefits. Contact us today at 914-584-6720 or at karell@CCESworld.com.

New Leadership at the USEPA and Its Impacts

Scott Pruitt has been confirmed and is now the Administrator of the USEPA. His history and stated opinions about environmental compliance are different from probably every previous Administrator. What are the implications for us environmental professionals?

During the campaign, Donald Trump spoke robustly about his disdain for environmental regulations, probably because of the costs and delays he had to endure as a real estate developer. He clearly believes in removing barriers to short-term business growth and that complying with environmental regulations is one example. He has also stated a belief in using whatever source of energy is most convenient, cheaper, and home-grown, and not concerned about whether it is cleaner or not. Finally, President Trump has expressed strong skepticism about the science of climate change, although he has moderated his stance more recently. Scott Pruitt appears to mirror these beliefs of the President, and has shown to perform actions to argue against environmental laws to help industry produce more, faster, with less to clean up.

Therefore, we can expect to see an attempt to boost production of US-produced coal, natural gas and oil. While Pruitt may attempt to remove environmental barriers to business and energy growth, there are other factors at play, such as a nation with an oversupply of cheap oil from domestic producers looking for markets and foreign companies needing the revenues. Plus, we already have an excess of natural gas due to fracking. Even if environmental rules are relaxed, coal may well be the source of energy left out because of the large cost to mine and process it and to combust it.

As this is written, it appears to be a certainty that President Trump will issue executive orders to keep older coal plants competitive and to repeal (or never put in place) the Clean Power Plan, meant to reduce greenhouse gas (GHG) emissions. The Clean Power Plan was written and signed into law by President Obama as the US’s response to the Paris Climate Conference to reduce GHG emissions significantly.

Administrator Pruitt has written that he believes that it should be more the states and less the federal USEPA that make most environmental decisions as they are closer to the impacted populations than a Washington bureaucracy. The problem with this is that pollutants know no borders and can drift and impact the health of people in other states.

Ultimately, President Trump and Administrator Pruitt value business growth and the American jobs that will come from them more than cleaner air, a more stable climate, etc. They believe that this is a zero-sum game and that you cannot have good business growth while respecting the environment. This despite the calls of hundreds of major American companies to retain many current federal environmental rules and of a growing number of Republicans to introduce a carbon tax with the proceeds returned to the public to reduce GHG emissions. Even major oil industries, which are big in Pruitt’s home state of Oklahoma, have put out statements in favor of a carbon tax to replace the patchwork of international climate change rules. They well may favor this, too, because many also produce and sell natural gas and many are investing in renewable energy.

Another concern for all of us in the industry is the research and development function of the USEPA. There is talk that Administrator Pruitt will end or greatly reduce the research funding that the USEPA provides, research into alternative ways to treat contaminated air, soil, etc. and cleaner energy, not to mention the communication of such advances. All to reduce the budget deficit. Some Republicans have said that it is not right to “bet” public money on certain technologies. On the other hand, that little upfront funding has resulted in breakthrough technologies that are cheaper than older ones. There is a long history of federal funding of new technologies, such as through NASA. It is almost certain that Administrator Pruitt will cut some R&D; how much is the question. Might there be enough private money to continue such research, such as sponsored by Elon Musk, Bill Gates, and others?

Perhaps the biggest concern about the new administration of the nation and energy and environmental policy is whether it will be taken over and impacted by idealogues or whether some practicality and stability will remain. There has been talk about eliminating an agency; the Dept of Energy is now being headed by Rick Perry, someone who called for its elimination a short time ago. It is not likely to happen because Energy oversees nuclear weapons and the public would not allow scenes that are in the news recently of people in China, India, Poland, and other countries having to walk around with masks on during routine walks and travel. It is likely that the new administration will cut down on regulations and their enforcement, but keep enough on the books to save companies compliance fees, but not cause a catastrophic deterioration of quality of life. Of course, if they miscalculate and an accident happens, the tide can turn. Also, it is certainly important and proven that being energy efficient and conserving the environment makes good economic sense to all businesses.

It is unlikely that even repealing many existing rules and paring back the operations of the agencies will impact us in the long-term. Energy and environmental issues will not go away; neither will ignoring climate change. In fact, more private businesses – in a competitive field – understand good environmental policy is good business. And we professionals will be needed to implement the best science to move forward.

CCES has the experts to keep you abreast of changes in environmental and energy rules and their impacts to your operations. We can perform the technical assessments for you to determine compliance and recommend appropriate, cost-effective technical strategies. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Despite New Administration, Regional, State Climate Change Rules Progress

While the Trump Administration has stated its skepticism about climate change and actions to combat it, a number of states are planning to continue existing programs to address climate change issues and reduce greenhouse gas emissions (GHGs). These programs also help in encouraging energy conservation and reducing the need for infrastructure upgrades, resulting in greater reliability of the electric grid and significant cost savings for businesses and consumers.

On the day of President Trump’s inauguration, Jan. 20, 2017, the California Air Resources Board (CARB) released a draft Scoping Plan to reduce state GHGs. Under the state’s climate change law, Assembly Bill (AB) 32, CARB is required to produce a scoping plan every 5 years. The proposed plan may result in changes to the state’s GHG emission rules and cap and trade program in order to meet California’s enacted goals to reduce GHGs by 40% from 1990 levels by 2030. The proposed plan would extend the state’s cap-and-trade program out to 2030. CARB auctions off remaining emission allowances to sources of GHG emissions as the cap declines to the long-term reduction goal. The proposed plan would also require oil refineries to reduce their GHG emissions by 20%. CARB plans to issue a final Scoping Plan by the spring of this year.

The proposed plan makes no change to the state’s current Renewable Portfolio Standard of 50% of electricity from renewable energy sources by 2030. It adds a goal of reducing methane and hydrofluorocarbon emissions by 40% from 2013 levels by 2030.

CARB’s grand 40% GHG emission reduction goal was planned to be met mainly by the cap and trade program with enactment of some mandatory GHG emission reductions by certain industries. However, because there is litigation against the program (that the state does not have the legal authority to manage a mandatory cap and trade program) the proposed scoping document looks into alternative strategies for CARB to pursue, including additional industry-specific GHG emission reduction rules, a carbon tax, or a “cap and tax” system, which would consist of a more flexible cap and trade system together with a carbon tax for each ton of GHG emitted.

The Regional Greenhouse Gas Initiative (RGGI) composed of 9 Northeast and Mid-Atlantic states’ cap and trade program for utilities continues to progress well. The 2016 RGGI adjusted cap was 64.6 million short tons, decreasing 2.5% each year until 2020. The average price of CO2 allowances at the latest auction was about $3.55/ton. An estimated $4 billion in funds over the length of the program has been returned to the 9 states to implement energy efficiency programs.

While these are rules pertaining directly to climate change, there are myriad more rules that many states, cities, etc. are enacting and enforcing that will result in reducing GHG emissions. These include many energy benchmarking and conservation rules. New ones appear to be coming up “every day”. (For example, St. Louis just finalized an energy benchmarking rule.)

CCES has the experts to help you assess your GHG emissions and help you reduce it to maximize your financial benefits whether you are in a GHG program or not. Contact us today at 914-584-6720 or at karell@CCESworld.com

Little-Known Federal Appliance Standards Rank as #2 Energy-Saving Tool

There is much concern as the new Trump Administration must now administer such well-publicized environmental standards, such as Clean Power Plan, Paris Climate Treaty, new vehicle fuel efficiency standards and more that it has inherited. The Trump Administration has been open about their disdain for many new environmental programs and their desire to abrogate or weaken them.

However, a couple of other existing USEPA and DOE programs have quietly been quite effective in reducing toxic air emissions, energy usage, greenhouse gas (GHG) emissions: the corporate average fuel economy or CAFÉ standards and the National Appliance Energy Conservation Act (NAECA).

According to a recent study, CAFE standards for cars and trucks saved more energy in the US in 2014 (7.3 quadrillion BTUs) with US appliance standards coming in second at 5.3 quadrillion BTUs of energy saved in 2014.

While abandoning the US’s pledge for the Paris Climate Treaty (26-28% reduction in CO2e emissions by 2025) and repealing the Clean Power Plan (cutting CO2e emissions by about 220 million metric tons by 2030) will not be positive for energy savings and GHG emission reductions, there is certainly a movement among US consumers to save energy, and, thus, GHG emissions, as the cost of excess energy usage comes from their pockets.

Current CAFÉ standards were finalized in August 2012, highlighted by an agreement with 13 large automakers to increase fuel economy to 54.5 miles per gallon for cars and light-duty trucks by model year 2025. Even the immediate improvement in fuel economy for limited models has resulted in the great energy and GHG emission savings noted above. These savings will increase more rapidly as the years go on as the standards increase and more models hit the road.

Quietly, though, national appliance standards have also effectively reduced energy use and GHG emissions. The original National Appliance Energy Conservation Act of 1987 (NAECA) was signed into law by President Ronald Reagan. It created uniform federal standards in response to complaints by the industry that it was difficult to keep track and comply with a myriad of different state standards. It contains minimum efficiency standards for a variety of appliances. It also prohibits manufacturers from advertising a product as meeting their energy efficiency standard unless it performed testing under federal guidelines that confirms this and that the testing is available to the public.

National appliance standards have been estimated to save the average US household about $500 per year on utility bills. In 2015, the appliance standards has been estimated to avoid 300 million tons of CO2e emissions.

The DOE has periodically updated the NAECA standards, mainly as part of the Energy Act of 2005. Over 50 consumer products are now covered by these standards. Despite being called an “Appliance” standard, NAECA covers other consumer, home-based products found in the residential, commercial and industrial sectors, such as battery chargers, pool heaters, and furnace fans. See http://www.appliance-standards.org/national. Some products have minimum energy standards found only at the state level. California, Connecticut, and Oregon have been the most aggressive, with minimum standards for televisions, DVD players, and game consoles.

Energy savings due to the NAECA has grown to 13% of electricity consumption in 2015 and 4% of natural gas consumption. And these energy savings are achieved without the consumer doing anything or investing in anything. And there is no risk of failure as the appliances will meet the standards of lower energy usage.

These savings are expected to grow in the future as future, more stringent standards will come in line for new or existing products. The USDOE has issued new standards for rooftop air conditioners and commercial warm air furnaces that are predicted to reduce energy usage by an additional estimated 5.8 quadrillion Btus over 30 years.

So while other prominent energy and environmental accords and rules have garnered a lot of publicity and have the risk of being eliminated or curtailed, the NAECA is an act that has quietly been successful in reducing a significant amount of energy for people in the residential and manufacturing areas with no loss of availability or function with no hassle or bureaucracy for the end-user. And with little or no complaint from the appliance industry. There appears no talk that it will be streamlined in the new administration. And let’s hope that the CAFE standards, the most successful government act in reducing energy usage, does not materially change, although there is some talk about that.

CCES can help you evaluate the energy usage of your building, whether it be commercial, industrial, or residential and determine many ways to reduce energy usage and peak demand, saving you money, creating other financial benefits, and with minimal risk or disruption. Join the many who have used CCES to save money in the short- and long-term. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Think Unconventionally in 2017

Usually I write fact-driven blog articles about news and trends in energy, environment, sustainability, etc. to inform and prepare you for what’s new. I hope I’ve been helpful. But I want to take this opportunity to be a little different and share some personal thoughts for 2017 and beyond. Some of this is based on the recent presidential election and what it may do to our livelihoods, and some independent of that.

I want to start off by sharing with you an unusual activity I really enjoy doing, something unconventional. I am 60 years old, yet I play in a pickup, full-court basketball game weekly and I love it. I go up mainly against guys who are less than half my age. This is certainly not a “normal” activity given my age and body type (I am not in the best of cardiovascular shape and, yes, a bit overweight), and friends and family try to convince me to stop.

But I love it so much. The competition, the intensity, the camaraderie. At the end of an evening of basketball, when I walk to my car and into the night and even the next morning – even when I’m very sore – I feel absolutely great. Why does it make me feel so good? I don’t know. The physicians out there may say that the intense activities on the court and all causes me to produce endorphins that lift my mood, presumably to counter the pain. Maybe some who are very religious may say that doing such a physical activity prolongs life (of paramount importance) and God is participating in a positive feedback loop. I happen to subscribe to another theory (and it’s just a theory) that one of the worst things a person can do is be in a rut. Do the same thing day after day, week after week, year after year. From an evolutionary point of view, it is hard for a species to survive if it does the same things all the time. So I think the good feelings from my brain is an evolutionary reward to encourage change. Again, just my guess.

As if this were not enough, I also participate in another activity that is a bit unconventional for someone like me, dancing, specifically Israeli dancing, on a regular basis. 60-year old men generally do not go out dancing; we sit by the TV and watch ball games and movies and talking heads. But again, I find it fun and uplifting, too.

So, as we enter a new year which is often a time when we self-evaluate and think about our lives, I want to urge each and every one of you to pledge to do something a little unconventional this year. No, it doesn’t have to be playing basketball or doing Israeli dancing (they’re certainly not for everyone). Perhaps it’s saying one or two evenings a week you will not sit on the couch and watch TV, but instead read classic old books or study new philosophies or take a course in a new subject or spend more time with your kids or do a volunteer activity with other kids or groups or be involved in local (or national) politics, or pick up that musical instrument you always liked or have not played since high school. Do any of these as a different, regular activity in 2017.

And the same for your careers. Declare in 2017 you will do something a little different; study something you normally do not get too deep into, or expand your comfort zone in your workload and go down a different “route” to benefit your company, or look into doing something new in the office.

Whether personal or professional or both, doing things unconventionally in 2017 should get your endorphins flowing, make you a little more nimble, and make yourself happier and more productive.

Thank you very much for allowing this indulgence. Have a happy, productive, unconventional 2017.

Despite Election, Six Reasons Why Clean Energy Will Still Do Well In The Future

With a new presidential administration and team at Energy and the USEPA soon to be sworn in, it is assumed that the US will repeal many current environmental rules, attempt to develop more of its own fossil fuels, and walk away from Paris climate change commitments. However, there are strong economic, global, and non-political factors that will move the US away from these actions or prove that they are actually harmful for the companies that the new Administration wishes to benefit the most.

Here are six reasons:

1. Economic forces are stronger than repealing a few rules. Right now, there is a glut of oil relative to demand, as many nations are only slowly recovering from the Great Recession or are entering a new slowdown themselves (i.e., China). Should the US succeed in greater exploration of coal or crude oil or invest in improving pipelines to move the oil, this will be a “dump” in the market, pushing down prices more and reducing profit margins of coal and oil companies. This would be true even if this growth were to take a few years, as futures markets will react.

Further, if the Trump Administration gets its wish to relax or repeal many environmental rules, which they believe is “holding back” energy companies, economic forces will make coal, oil, etc. more inexpensive. Other oil and coal producers (Russia, Iran, Venezuela, Middle East, etc.) are all desperate for revenue to keep their regimes going and populations happy, and are likely to dump as much energy supply on the market as possible. The US will just add to that. Despite OPEC agreements to hold back putting oil on the market, countries will want to maximize needed revenue. Economic forces are greater than loosening some environmental rules.

2. The effort to get fossil fuel supplies. Even with a “green light” from Energy or the Interior, as time goes on, it will get harder for companies to drill for or mine oil, natural gas, or coal. Companies naturally look for the easiest and cheapest sources. In the future, companies will need to dig deeper or in further away places than years ago, raising the baseline cost. Because of oversupply the price of a gallon of crude oil or coal may not be worth the cost to produce it – even if environmental regulations were to be relaxed (if this is even allowed).

3. Improved technology favors clean sources of energy. Another economic force that even the Trump Administration cannot stop is technology. Improved technologies are being invented and successfully implemented all the time to make renewable energy more effective, practical, and affordable. New wind farms in west Texas can be built for as little as $22/MW, and solar farms in the desert for about $40/MW. In contrast, the cost to build a new natural gas-burning power plant is estimated to be about $52/MW and for coal about $65/MW. Even if environmental controls do not need to be included, there will still be a gap and that gap will climb as renewable technology improves more. There is also the crucial issue of time. Renewable power plants can be up and running in a matter of months; for a fossil fuel plant to begin operation, it’s years.

While causing GHG emissions, natural gas will also be favored because it is lower in GHG emissions compared to oil or coal and can be shipped overseas as LNG much more conveniently and cheaper than oil or coal.

There is also forecasted progress in battery storage capabilities. Thus, it is likely that eventually, all forms of transportation will be able to operate using electric power, lessening the need for gasoline or diesel oil combustion, resulting in lower GHG emissions and saving money, too. It is not an accident that major oil & gas companies are all investing in energy storage, LNG, and renewable energy.

4. Growing understanding of the impacts of “dirty” fuels. Another factor favoring clean energy is the strength of the problems and growing understanding about the impacts of “dirty” energy. There is much worldwide publicity about the air pollution issues in China with pictures shown worldwide of filthy vistas and people walking around in masks. Asthma and other lung diseases have risen dramatically, and the Chinese now realize that environmental issues are high impact economic issues, too, affecting future growth. Many other locations worldwide are learning this, too. So even if the Trump Administration tries to repeal many environmental and public health rules, it will not succeed because of the risk of such scenes becoming common in the US and that world markets, with the biggest component, China, in the lead, will move away from dirty fuels and toward renewables over the next few decades.

5. The power of the States. While those picked to run national environmental and energy policies have historically fought to repeal many regulations, the States have considerable sway in their energy mix. More than half of US states have laws requiring utilities to incorporate a minimum percentage of renewable energy into their generation mix. Some such rules are in force in states considered conservative politically. Some states have very aggressive goals. These will force utilities to contract for or build plants for renewable power in the near future, independent of who is President.

In addition, some states administer GHG emission rules that have been determined to be effective in getting utilities to move away from coal toward renewable power. The Regional Greenhouse Gas Initiative (RGGI) is a cap and trade system for GHG emissions from large power plants in 9 Northeastern states, and is considered a success as it met GHG reduction goals ahead of schedule at a relatively low cost to the regulated utilities. California has aggressive rules it is enforcing. Other states are considering similar rules to encourage renewable power in their states.

6. The power of the private sector. In addition to the States, some major corporations have thrown in their lot to move toward a heavy reliance for renewable power, including Wal-Mart, Microsoft, and Google. It is in their long-term plans to maximize renewable power as their source of electricity for a variety of reasons, including reliability of supply (the sun will always shine, while there could be an embargo or shortage of oil or coal). For the most part, these companies have succeeded and saved energy costs, as well. Other companies are likely to see the success and authorize their own programs to catch up and obtain the benefits.

While there is much to worry about in terms of our future work in the environmental and energy sectors, these factors, beyond the control of the upcoming Administration, should ensure that there is much progress in the future for clean energy, environmental safeguards, and renewable powers.

CCES has the experts to help your company assess impacts of future environmental or energy rules. We can provide you technical advice to help you determine your current status and determine strategies in the future to put yourself in a better place. Contact us today at 914-584-6720 or at karell@CCESworld.com.

USEPA Proposes Revisions To PSD And Title V GHG Permitting Rules

On October 3, 2016, the USEPA published a proposed rule to revise the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Rules in reaction to a US Supreme Court ruling in 2014 (https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0355-0001).

The most critical change is that the proposed rule would provide a Significant Emissions Rate (“SER”) for GHGs, 75,000 tpy CO2e SER. An applicant that is subject to PSD because proposes to build and operate a new facility or to an expand an existing one that would cause emissions of an existing PSD pollutant to rise by more than its significant level (an “anyway” source) and also GHGs by at least this amount would need to have performed a Best Available Control Technology (“BACT”) analysis for both the subject PSD pollutant and GHGs, as well. Previously addressing GHGs as part of a PSD Permit was limited to “anyway” sources (not sources that exceed a de minimis for GHGs). The proposed revision would prevent the USEPA from exempting from GHG BACT requirements “anyway” sources if it proposes to emit GHGs above the SER guideline.

The proposed rule would also revise several definitions, including a definition of GHGs itself and of CO2 equivalents (CO2e). GHGs is any of a group of 6 compounds, including CO2, N2O, CH4, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. CO2e is calculated by taking the tons per year emission totals of each compound (or set of compounds) and multiplying this by its “global warming potential” published in the rule, and summing them. The proposed rule also provides for the exclusion of GHG emissions from “major source” and “major modification” determinations.

The comment period of the proposed rule is over. Of course, with the new administration taking over in January, it is unknown whether the new USEPA administrator will drop these proposed changes and not have any action about GHG emissions and permitting under the Clean Air Act.

CCES has the experts to allow your facility to make the technical decisions concerning air emissions and compliance with GHG and Clean Air Act rules. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Climate Change News and Notes: November 2016

The Paris Climate Change Agreement Goes Into Effect This Month

On November 4, 2016, the Paris Agreement went into effect. What is next? The signatories must implement its terms and help meet their own goals and perhaps do better. The central aim of the Agreement is to strengthen the global response to the threat of climate change by holding the increase in the global average temperature to below 2°C, recognizing that this would significantly reduce the risks and impacts of climate change. The Paris Agreement is also meant to strengthen the abilities of countries to adapt to deleterious impacts of climate change by helping one another out both technologically and financially.

Before The Paris Agreement each country prepared its own plan to reduce GHG emissions or Nationally Determined Contributions (NDCs), an implementation plan. Now the nations must implement their plans. Of course, adding complexity to this problem is the election of Donald Trump as President of the US, the second largest emitter of GHGs, who has said he will have the US repeal its portion and obligations of this Agreement, as well as its economic contribution. This led to much criticism. It will be interesting to see what he does when he comes to office on January 20, 2017.

President Obama Directs Agencies To Consider National Security Impacts Of Climate Change

On September 21, 2016, President Obama issued a Memorandum titled Climate Change and National Security. (https://www.whitehouse.gov/the-press-office/2016/09/21/presidential-memorandum-climate-change-and-national-security). The purpose of the Memorandum is to ensure that in the development of national security doctrine, policies, and plans climate change-related impacts are fully considered. The Memorandum establishes the Climate and National Security Working Group, to be made up of representatives from various federal agencies, including the USEPA, the Council on Environmental Quality, and the USDOE. The Working Group will ultimately develop recommendations for agencies such as the Departments of State, Defense, and Homeland Security. The Memorandum is expected to be revoked by the next administration. The Working Group is expected to issue its Action Plan, outlining specific objectives and milestones for carrying out the policies identified in the Memorandum.

CCES can help your company evaluate how Climate Change affects your operations and the various physical and regulatory risks associated with it. We can work with you to reduce your GHG emissions and realize the maximum financial benefits that go with smart strategies. Contact us today at karell@CCESworld.com or at 914-584-6720.

The Future Of Energy And Environmental Policies In A Trump Administration

November 10, 2016

Last month I wrote an article about the potential course of events for environmental and energy policies if either presidential candidate was elected. Now we know there will be a Donald Trump administration. So first I will repeat the thoughts about what a Trump administration might look like when it comes to energy/environmental policy, and I’ll present some early policy areas being considered. Nothing here is written in favor or against any policy, but future issues facing the energy/environmental professional.

Energy: Donald Trump has been severely critical of current energy and environmental policy and has stated he will reverse many of President Obama’s initiatives. During a May 26 speech, Trump reflected a desire to achieve US energy independence by reducing federal regulations on the energy industry, increase investments in fossil fuel development and infrastructure to bring it to market (such as supporting the Keystone Pipeline), and reduce federal investment in renewable energy, as he has criticized both solar and wind power. Trump also supports increased use of nuclear power.

Environment: Trump has stated he would rescind a number of President Obama’s environmental rules, such as the Clean Power Plan. As a real estate developer, Trump has a particular aversion to environmental rules which he felt has cost him unnecessary money and delayed his projects. He has also specifically pointed to the Clean Water Act as another regulation he would greatly weaken. Reversing or weakening these and other EPA rules would require EPA rulemaking, requiring a public notice process. A Trump Justice Department may just not defend these and other environmental rules when challenged in court by industry. Neither approach would ensure success, as environmental and other groups would surely marshal forces in defense of the rules. Furthermore, courts could rule that these regulations are valid, legal, and necessary.

Climate Change: Trump stated on the campaign trail several times that climate change has not been proven. However, closer to the election, he was more neutral about the topic. He certainly feels it is not a high priority. He has expressed his intention to withdraw the US from the Paris Climate Agreement, which may be difficult to do. Trump could do as little as possible to implement it, which has weak enforcement mechanisms. He has also stated he would stop all US payments toward UN climate change initiatives.

Early Steps

One of Trump’s main advisors on environmental issues is Myron Ebell, a known climate change denier. There is speculation that he may be put in charge of the EPA. Mr. Ebell has been very critical of not only climate change, but also of recent Obama environmental rules. There is speculation that he may even call for the repeal of signature environmental rules, such as the Clean Air Act and Clean Water Act, and the dismantling of the EPA. This would likely require passage by Congress. Both houses of Congress are controlled by Republican majorities, but slim ones. There are many Republicans who believe in climate change and environmental rules or live in districts with constituents who would be bothered by radical change like this.

Published reports have stated that Mike McKenna has been a major advisor for the transition team on energy issues. He is a former DOE employee, and has been a lobbyist for several oil & gas and chemical companies. It is believed that a Trump-led DOE and Republican Congress would open up more federal land for oil exploration and encourage more coal production by repealing rules discouraging it. This would lead to greater energy supply, lowering prices for consumers, but also potentially raising risks of costly environmental damage. Many have argued that with other countries willing to supply much oil, gas, and coal to the global market and with rising exploration costs, the market may convince many oil & gas and coal firms to restrain anyway. With fracking and a large natural gas supply, coal and oil may yet be too expensive to invest in even with reduced regulations. But it appears that’s the direction of the new administration.

While this is happening on the federal level, it is certainly conceivable that states or groups of states will re-double their efforts to enforce meaningful environmental rules. However, with weak federal rules, one state’s lax rules could attract new businesses in place of a state with stricter rules to protect its public’s health.

And finally, there is the market. Many people were shocked by Trump’s electoral victory, but the sun still came out the next day, and with it solar and other renewable energy. While Trump has been critical of its implementation, the market has certainly favored this and being more energy efficient, as renewable power and energy efficiency programs have grown tremendously in the last few years. Renewable power is generally cheaper, growing in reliability, and reduced in cost compared to many fossil fuel applications. While dis-incentivizing these programs may set them back, positive results in the market should still attract business.

CCES can help you evaluate your company’s energy use and environmental impacts and can perform the technical aspects to determine compliance with current rules and develop opportunities to reduce your energy usage and diversifying sources, saving you money and decreasing business risk. Contact us today at 914-584-6720 or at karell@CCESworld.com.