Category Archives: Energy Management

The Future Of Energy And Environment Policies Under The Next Administration

October 17, 2016

While most of the analysts predict a Clinton victory and Democratic administration, here are some thoughts about what a Trump administration might look like when it comes to energy/environmental policy and what may change in a Clinton Administration. As I have written in other blog articles, nothing here represents writing in favor or against a candidate or policies, but instead addresses future issues facing the energy/environmental professional.

Should There Be a Trump Administration.

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 cornerstone environmental and energy achievements, such as the Clean Power Plan. Trump has also specifically pointed to the Clean Water Act as another regulation he would greatly weaken if he were elected. Reversing or weakening these and other EPA rules would require EPA rulemaking, requiring a public notice process. A Trump Justice Department could just not defend these and other environmental rules as they are 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 has stated on the campaign trail that climate change has not been proven. In a recent speech, he was more neutral about the topic, but has expressed the feeling that this is not a high priority. He has expressed his intention to withdraw the US from the recent Paris Climate Agreement. With the Paris Agreement officially ratified, it would be difficult to withdraw, although Trump could likely do as little as possible to implement the Agreement, which has flexible objectives and no enforcement mechanism.

Should There Be a Clinton Administration.

Energy: To enable energy independence, Hillary Clinton has outlined a wide ranging list of investments by the federal government, such as clean energy, upgrading energy infrastructure, promoting responsible domestic drilling for oil and natural gas, and building on many of the core energy and environmental programs of the Obama Administration, such as the Clean Power Plan and Paris Climate Agreement. Clinton has spoken out in favor of natural gas development, citing it as a bridge fuel in the transition away from coal, including supports for fracking, although she has stated that deference should be given to localities who wish to ban it in their communities. Despite the “all of the above” approach in energy development, Clinton has stated policies that would discourage coal as an energy source, unless acceptable environmental levels are met. Clinton issued an infrastructure plan, prioritizing the development and repair of large-scale energy infrastructure across the country. Clinton would likely seek to continue the current Administration’s strong support for renewable energy development, call the US a future clean energy “superpower.” Clinton’s specific plan increases the percentage of renewable generation to 25% of total national energy mix by 2025.

Environment: Clinton supports the Clean Power Plan and wants to expand it in other industries in order to implement “smart” pollution and efficiency standards. Clinton has given no specifics, but states she supports additional policies to reduce US greenhouse gas emissions.

Climate Change: A Clinton Administration has committed to continue to abide by the Paris Climate Agreement. The Democratic Party platform stated: “Democrats believe that carbon dioxide, methane, and other greenhouse gases should be priced to reflect their negative externalities, and to accelerate the transition to a clean energy economy.”

Control of Congress.

Remember that while the President wields considerable power through the EPA and DOE, control of Congress is certainly important, too, in “setting the tone”, promulgating new rules and funding existing agencies. Republican control of the Senate and perhaps the House is in play in the upcoming election. A Democratic control could dramatically change the policies of several related committees in the Senate and House.

Senator Lisa Murkowski, the current chair of the Senate Energy and Natural Resources Committee, has been a strong advocate of the “all of the above” approach to energy. She supports energy exploration on federal land, such as in her home state of Alaska. Senator Maria Cantwell is the ranking Democrat on this committee and would likely chair it if the Democrats take control of the Senate. She has billed herself as a champion of “smarter” energy policies to diversify energy sources and lower costs for consumers. Senator James Inhofe, the current chair of the Senate Environment and Public Works Committee, is a noted climate change skeptic and strongly supports scaling back environmental regulations and promoting greater domestic energy production. If the Senate flips to Democratic control, Senator Tom Carper is expected to chair this committee.

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.

Trend Toward Healthier Buildings

A new report issued by the US Green Building Council and Dodge Data & Analytics finds growing understanding and acceptance by building owners that buildings built or redesigned to improve the health of the occupants drives major business benefits.

“The Drive Toward Healthier Buildings 2016” (https://analyticsstore.construction.com/smartmarket-reports/HealthierBuildings16SMR.html) finds that the design and construction industry in the US is moving toward wider adoption of building practices that prioritize the physical and mental well-being of tenants and occupants. The report found that 75% of US building owners surveyed want to invest in healthier buildings as a way to improve employee or tenant satisfaction.
Constructing healthier buildings for occupants was of interest to about two-thirds of US building owners, although, not surprisingly, this paled in comparison to the percentage of owners who were interested in cost savings (85%).

Asked what design options would result in a healthier building, the only option that a majority of US building owners recognized as effective is improved ventilation. A majority of building owners were not aware that the following are also effective options:

• proper site selection,

• improved daylighting,

• layout that encourages physical activity,

• usage of healthier product usage (such as cleaning solutions), and

• improved thermal and acoustical comfort.

This is at odds with the design community, who are aware of the effectiveness of these features. This indicates that more education of the real estate community is important.

Building owners, according to the survey, do recognize that such buildings will lead to improved employee satisfaction (79%), will result in the owners’ ability to increase leasing rates (73%), and achieve higher asset values (62%). However, about half of all building owners are unaware of whether any benefits to improve health have been achieved. Those that perform actions (measure light levels or air quality or perform employee/occupant surveys) are overwhelmingly satisfied that the upgrades have been successful in making tenants healthier, more satisfied, and more productive.

CCES has the experts to perform technical evaluations of how to upgrade your buildings to be healthier and to gain all the benefits that come with it (more desirable, greater asset value, etc). Contact us today at karell@CCESworld.com or 914-584-6720.

Cross-State Air Pollution Rule Affecting Power Plants Finalized

On September 7, 2016, the USEPA finalized an update to the Cross-State Air Pollution Rule (CSAPR) for the 2008 ozone National Ambient Air Quality Standard (NAAQS) by issuing a final CSAPR Update. See https://www.epa.gov/airmarkets/final-cross-state-air-pollution-rule-update. The final rule has not yet been published in the Federal Register.

CSAPR was designed to address facilities that cause significant pollution that travels long distances impacting people in other states. States in which these facilities operate have not been motivated to regulate their emissions as it does not affect the health of their citizens. This federal rule achieves this. USEPA estimates that the rule will reduce summer (May – September) emissions of nitrogen oxides (NOx) from power plants in 22 states, result in benefits totaling up to $880 million, and reduce ground-level ozone exposure for millions so people, reducing rates of asthma, cancer, and other diseases.

Beginning in May 2017, the new rule will affect 2,875 electric generating units at 886 coal, gas and oil power plants. The USEPA says affected power plants can achieve the required NOx emissions reductions using existing, cost-effective technology.

Under CSAPR, each of the 22 states hosting an affected electric generating unit must develop state implementation plans meeting minimum NOx emission requirements under the supervision of the USEPA which could issue a federal implementation plan for each state that fails to submit an approvable plan.

The power industry has come out against CSAPR since its inception, suing the USEPA. The US Supreme Court upheld the CSAPR in 2014. However, the US Court of Appeals, DC Circuit in July 2015 remanded parts of CSAPR to the USEPA for updating, and this is the final update. This update is based on downwind areas meeting the 2008 ozone NAAQS of 75 parts per billion, and not the subsequently updated standard of 70 ppb. The power industry is still not happy with the updated version and a legal challenge to CSAPR is likely.

CCES has the technical experts to help your company implement the technical requirements to comply with a variety of environmental and air quality rules. Our engineers can perform an emissions inventory and determine from a technical point of view how to maintain compliance or get in compliance with federal and state air rules. Contact us today at 914-584-6720 or at karell@CCESworld.com.

USEPA Proposes Clean Energy Incentive Program

On June 30, 2016, the USEPA published a proposed rule laying out its Clean Energy Incentive Program (CEIP), found in the Federal Register, Vol. 81, No. 126. CEIP is a voluntary early action program within the federal Clean Power Plan of 2015 (CPP), regulating CO2 emissions from existing power plants. To provide greater compliance flexibility, including having a pool of allowances for subject power plants to buy to comply, the USEPA would like to have this available when CPP goes into effect in 2022.

Implementation of CPP has been hobbled by a stay put on it by the US Supreme Court in February 2016. While some have argued that all compliance deadlines must be postponed because of the stay, the USEPA is continuing efforts for full implementation of all aspects of the Plan, including the proposed CEIP program.

The publication contains proposed guidelines for states that wish to participate in CEIP, including procedures for states to distribute allowances or to issue emission reduction credits (ERCs) for approved energy efficiency (in low-income communities) and zero-emitting renewable energy projects (in all communities). The proposed rule lists solar, geothermal, hydro, and wind as eligible renewable projects; it does call for comments on whether it should expand the definition to include CHP and nuclear. An entity which has successfully implemented an approved project by 2020 may get matching ERCs from the USEPA and can sell or transfer the ERCs or allowances to subject power plants to comply with their CO2 emission reduction goals from CPP. The USEPA is limiting the pool to 300 million short tons of CO2 emission allowances to distribute, based on its estimation that this will be the level that subject power plants will reduce CO2 emissions as part of CPP. These allowances will be distributed to states based on its share of the estimated reduction.

The proposed rule contains administrative requirements for states that choose to participate in the CEIP and the requirements for energy projects to meet CEIP eligibility. In general, a renewable energy project will receive 2 ERCs for every 2 MWh of renewable power generated. This ratio doubles for projects in low-income communities. For a project to be eligible to obtain ERCs, it must be implemented in a state that is participating in CEIP, and has demonstrated that it is replacing electricity production from a subject power plant in 2020 and 2021.

CCES has the technical experts to help you plan, design, select, and fully implement an energy efficiency or renewable energy project and help you obtain ERCs under this program, when it comes into force. We can maximize not only the revenue you can make selling ERCs under this program, but also maximize the financial benefits of your projects for your bottom line, as well. Contact us today for a free, no-obligation discussion at karell@CCESworld.com or at 914-584-6720.

Insulation: Another Way to Save Energy Costs

Pipe and building insulation are proven strategies to reduce energy usage and, therefore, costs. Don’t try this at home or at work, but imagine how hot a metal pipe in steam or hot water service is and then imagine the reduction in heat loss when it is properly insulated. That heat loss stays inside the pipe with the steam or hot water, making it more effective and necessitating less energy usage (fuel combustion) to produce that steam or hot water. Properly and completely insulating a bare surface in steam or hot water service can easily reduce heat losses by over 90% and therefore, reduce your need to produce steam or hot water significantly, saving you fuel costs, improving safety (workers not touching the hot pipes), and reducing emissions of greenhouse gases and of toxics that may impact your plant and neighbors.

To illustrate the cost-effectiveness of insulating pipes in steam or hot water service, see this example. A facility produces and pumps steam at 350°F from an oil-fired boiler operating at an average efficiency of 80%. Oil is purchased at $2.50 per gallon. The 4-inch steam header is insulated with 2 inches of fiberglass pipe insulation. The North American Insulation Manufacturers Association (NAIMA) has software to estimate the energy savings. Let us say that the insulation reduced heat loss from that bare pipe by 95%. Assuming the boiler is used only during the heating season, this can easily save the building $100-$150 per foot per year, for the avoided cost of oil not combusted to replace the lost heat. This figure can be much higher if the cost of oil rises or if the boiler is used for other purposes and is used all year. This also reduces greenhouse gas emissions significantly, too.

Savings can also occur for cold piping, too. Cold water – from electric chillers – transported through pipes can be insulated to save the use of these chillers, reducing electricity usage. While oil prices are relatively low these days, electricity prices are at all-time highs and projected to rise even more. Anything that can be done to reduce electric usage, will save you money.

August is the time of year many buildings – residences, offices, and industry – check their boilers and chillers to make sure they are maintained so they run reliably in the upcoming months. Part of your evaluation should be whether there are pipes that are uninsulated or with insulation that is cracking and damaged. Of course, look out for asbestos and, if present, make sure its removal is managed professionally and via the law. If you see such areas that are uninsulated, underinsulated, or insulated with damaged or cracked insulation, now is the time to re-insulate it properly. That extra time and cost for insulation will be paid for in savings this winter.

CCES has the experts to perform an energy audit of your building, and examine this and many other energy issues to help you save energy and other costs reliably and effectively. Contact us today at 914-584-6720 or at karell@CCESworld.com.

USEPA Releases New Final Landfill Emissions Rules

August 2, 2016

On July 15, 2016, the USEPA released a new final amended rule limiting emissions of greenhouse gases (GHGs) and other compounds from both existing and newly-constructed municipal solid waste landfills. This is the first modification to the federal landfill emission rule in 20 years and, for the first time, addresses GHG emissions. There has been the realization lately that any approach to successfully reduce GHG emissions nationally mist include reduction of methane emissions, a major component of landfill gas, because it is 21 times more potent on a mass basis than the main GHG, CO2, which had been the focus of most GHG reduction strategies. Therefore, came this focus on amending the main federal municipal landfill air quality rule.

Newly-constructed or modified landfills after July 17, 2014 will have emission limits found in New Source Performance Standards (NSPS) or Sect. 111(b) of CAA. See https://www3.epa.gov/ttn/atw/landfill/landfills-nsps-2060-am08-final-signature.pdf For existing landfills built before this date, emission guidelines have been published to be implemented by each state in their specific plans. See https://www3.epa.gov/ttn/atw/landfill/landfills-eg-2060-as23-final-signature.pdf. The USEPA estimates that the new standards will cover over 1,100 new and existing landfills at a combined compliance cost of approximately $60 million by 2025.

The new standards apply to landfills that have design capacities of 2.5 million metric tons and 2.5 million cubic meters or more of waste, no change in the current rules promulgated in 1996. Under both the rule and the guidelines, facilities that meet the design thresholds and emit over 34 metric tons of non-methane organic compounds (NMOC) per year will be required to install a gas collection control system (GCCS), such as flares, an enclosed combustion system for energy generation, or gas treatment system for its sale or beneficial use. A landfill may be exempt from GCCS requirements even if it meets this applicability threshold if it can demonstrate that the surface NMOC concentration is below 500 ppm for consecutive quarters.

The rule and guidelines will take effect 60 days after publication in the Federal Register (which has not occurred yet as this article is posted). Any facility that exceed the design capacity and NMOC emissions thresholds will have 30 months to install GCCS. The USEPA estimated that > 100 newly-built or modified landfills will install GCCS by 2025.

Capturing landfill gas can be beneficial as it is combustible and can be useful in generating electricity, heat, or hot water. So while being mandated to capture landfill gas can be costly, it is a “free” source of energy that can be converted to useful energy to reduce your energy costs.

CCES can provide for you the technical portion of the advice to determine which federal and state air quality rules are applicable to you and the most cost-effective strategies to maintain compliance. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Applying Green Building To Manufacturing Plants

July 2016

The “green” building movement as thought of by LEED standards has progressed well as applied to residences and commercial buildings, such as office buildings. But what about manufacturing? When we think of “factories”, we imagine large “clunky” buildings built for the necessities of 100 or more years ago, when energy and water were cheap and room was needed (and available) for assembly lines. With the decline in manufacturing in the U.S. over the last few decades, few have thought it worthwhile to invest in green features in old manufacturing buildings.

However, the U.S. Green Building Council recently released a short report “LEED in Motion: Industrial Facilities,” there are more than 1,775 LEED-certified industrial facilities, covering nearly 500 million square feet of space, with high future growth likely.

Many former industrial hubs have seen an increase in available, empty industrial buildings that are primed to be refurbished or repurposed. Meeting LEED certification standards by demonstrating excellent energy, water, resources, waste, etc. performance makes such efforts worthwhile. Pittsburgh is considered the leader in this effort, as its municipal government has encouraged repurposing and refurbishing its large stock of former factories through LEED.

Why is the “greening” of factories necessary and beneficial? First of all, the economics of operating a manufacturing plant has changed compared to decades ago. Energy, water, waste management were easily available and cheap; not so anymore. Space is more of a premium, too. Factories have to be more efficient in resource management to meet the new realities of the market. In addition, US industry is competing in global markets where labor costs, which are often much greater then resource costs, are cheaper. As “LEED in Motion: Industrial Facilities” states, U.S. manufacturing buildings must be more efficient when it comes to not only energy, water, and waste, but also labor productivity. LEED buildings of all types result in high-performing buildings where the health of the labor force is enhanced.

The first packaged-goods manufacturer to achieve a LEED Platinum rating is Method Product’s cleaning products factory in Chicago. Method heavily invested in renewable energy and the world’s largest rooftop farm, expected to produce 500 tons of food annually. Method estimated that the plant cost them about $30 million, about 33% higher had it aimed for a lower LEED rating, but that they would make the extra money back quickly in increased productivity, reduced costs, and reduced transportation costs.

CCES can assess your current or prospective industrial facilities and determine whether they are candidates for upgrades to become more “green” and to estimate the necessary investment, payback, and profit of different green strategies. We can assist whether you wish to do a complete green upgrade or want to address one issue at a time. Contact us today at 914-584-6720 or at karell@CCESworld.com.

This Is The Time To Fix Inefficient Boilers

May 2016

It has taken longer than usual, but warmer weather is finally headed to the US Northeast and Midwest, and boilers to provide heat and comfort can be shut down for awhile. While it may be “out of mind”, this is exactly the time to perform upgrades to save you money in the next heating season. We have seen recently fuel prices rising (fuel oil and natural gas), so savings will be even greater next heating season.

Heating and hot water supply can account for over one-third of a building’s energy consumption, justifying the investment in improved efficiency. Heating costs can be cut by up to 30% by implementing simple measures such as insulation, maintenance, optimized on/off controls (improved modulation), and energy monitoring.

The simplest upgrade with a good payback is insulating or repairing the existing insulation on boilers, condensate tanks, pipes and valves in steam or hot water service. Putting your hand on such areas (very briefly) will illustrate the loss of heat which must be made up by combusting more fuel. Insulating such areas can save up to 10% of fuel consumption.

It is important to find a reliable company to review, test, and upgrade maintenance of your boilers. Not just go through the motions, but spend extra time inspecting boiler tubes, brickwork, fuel lines, etc. to determine whether they are operating optimally. Have combustion testing done to determine efficiency, O2, CO, and CO2 levels at both high and low loads, etc. Given that you have invested so much in capital costs for your boilers, it would be a shame to have you have to buy new units prematurely because warning signs have not been even observed, not to mention addressed. Quality summertime maintenance of boilers pays for itself in the long term.

If you have not installed this, you should consider installing monitors and software to determine whether all areas of your building are receiving adequate heat and feeding back either to adjust the rate of steam or hot water travel or the fuel feed rate. While the monitors and software may be initially expensive, the detailed determination of your heating success not only will save you energy costs, but also provides proof that you are providing adequate heat to all tenants.

CCES has the technical experts to help you identify potential upgrades for your boiler, domestic hot water, and other heating systems, and can manage upgrade or replacement projects for you to maximize the cost savings and other benefits. Contact us today at 914-584-6720 or at karell@CCESworld.com.

The Key Is Not Less Lighting, But Right Lighting

Energy conservation is on more and more people’s minds – particularly building owners and managers and corporate officers. Energy is a growing cost for any business and with recent discoveries in technology that saves energy use, more and more businesses are turning to energy savings to gain many diverse economic benefits.

Among the best ways to save energy is through lighting upgrades. Changing to more energy efficient lights is one of the best “low hanging fruits” for energy savings. But, it is critical that you do not just run to the hardware store and buy new lights labeled “energy efficient”. Changing to the wrong lights may save you some energy costs now, but actually cost your company much more money when it comes to worker productivity.

Work and, Therefore, Lighting Needs Have Changed

For example, in commercial spaces, the way that offices are operated has changed in recent years. Most offices used to be a collection of private rooms for each employee, based upon size (larger ones for senior management), with little common space and hallways. Now, more and more offices are “open” with one or a few large rooms for many employees. Fewer lights are needed because there are fewer walls and separations. Put another way, lighting for one person in one office can now adequately provide proper lighting for several people’s work spaces.

The nature of work has changed, too. Office work used to be based on reading or writing on paper. But now much more work is done on personal computers, tablets, and other devices. Less artificial light is needed because these devices give off light.

Too Much Lighting Is Not Good Either

Therefore, you do not need to provide your employees with as much light as you used to. De-lamping, the strategic removal of light fixtures, effectively reduces wattage and energy costs. If done right, it will not adversely affect, but will improve worker productivity. Excess light, studies show, is actually not a good thing, potentially causing headaches, fatigue, stress, and even disrupting circadian rhythms.

The Illumination Engineering Society (IES) used to recommend a lighting level of 750 to 1,000 lux (lumens per square meter) in offices. However, IES now recommends a lighting level for open offices of about half of this: 300 to 500 lux. While a manager may be tempted to keep lighting levels as they are “to be sure” that everyone has sufficient light, this may not be a good idea for the reasons mentioned above.

Another matter to consider is the use of natural light. While allowing sunlight to enter an office as a replacement for artificial lights (whether by switching off lights or with a daylight control) is an effective energy saver, it can cause glare and solar heat gain, affecting worker productivity and adding to your air conditioner’s load and raising energy costs that way. Installing “low-e” film on the windows that allow sunlight will reduce glare and solar heat gain, providing the office the natural light with less of the downside.

Reducing lighting is a positive way to reduce energy costs and be more sustainable. However, your company will benefit more by doing this coupled with the right lighting.

CCES has the experts to help your company evaluate your current lighting and determine whether there are opportunities to not only replace your current lights with more energy efficient ones, but to also install the “right” lighting to improve productivity. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Energy Conservation: A Great Financial Investment

Don’t think of energy reduction as a burden, but as a great financial investment. A robust program will effectively help your bottom line by reducing operating costs.
What is the other way to increase profits? Increase revenue. Fine, but how easy is that to achieve? Let’s say a building saves $100,000/year in operating costs through energy savings (not hard to imagine: less than $10,000/month). If your average “widget” results in a 10% profit, then you’ll have to increase sales by $1,000,000/year to get the same increase in profits as reducing energy. That means investing in more advertising, sales people, etc., and then there is no guarantee that you’ll reach that $1,000,000 annual increase in sales. It is more likely you will meet an energy savings goal than a sales goal. More important, even if you succeed in increasing sales accordingly, the next year you have to do it all over again. Keep the advertisements, salespeople, etc. going. How easy is that? But the energy conservation measures automatically keep saving you energy costs. In fact, savings will increase in future years as the unit cost of energy will only rise (will your utility keep the cost per kWh, per therm, etc. the same?). So the savings likely will be $103,000 in year 2, $107,000 in year 3, etc. for some time. But each future year, you have to invest and hope to get that million-dollar increase in sales.
Yes, think of energy savings as an investment to get the best return with your business’ hard-earned money. The basics of any financial investment is to get the highest return for the lowest risk. Energy efficiency achieves this as rates of return on many projects are conservatively in the teens percent per year, and often 25%, 30% or more per year. What bank or Wall St. investment pays this, with no risk (a light bulb is lower wattage, you will save; equipment is designed to use a certain amount of energy, etc.)?
Why is energy management such a good investment?
• Rate of return exceeds most financial investments (often >25%/year), with low risk. Technologies are well understood and perform well in “real life” conditions.
• Energy costs are a growing segment. Reducing these directly increases Net Operating Income for any business.
• These technologies last longer, meaning you need to have fewer in reserve, liberating space. Reliability is improved and maintenance costs are lower, freeing up O&M staff for other projects.
• Prices for these technologies are coming down as more get into the business. Plus, utilities and governments give incentives to pay part of the cost. But don’t wait for prices to come down further. Future capital cost savings will likely be lower than the lost opportunity to save energy costs in your buildings.
• The financial community knows energy efficiency projects have a high rate of return and are reliable. So they will compete to loan you upfront money for these projects. Financing can be arranged to produce a positive cash flow at all times.
Again, think of energy savings – if done right – as an opportunity to get a great financial return with little risk. CCES has the experts to help your company maximize the benefits of energy upgrades. We handle it all from assessment to planning to execution to benefit you the most. Contact us today at 914-584-6720 or at karell@CCESworld.com.