Category Archives: Sustainability

USEPA Issues Final Rule On Formaldehyde Emission Standards For Composite Wood Products

On July 27, 2016, the USEPA released a prepublication version of its final rule on Formaldehyde Emission Standards for Composite Wood Products. This is important as the USEPA has classified formaldehyde as a probable human carcinogen and many buildings looking to meet green standards take care to minimize indoor formaldehyde emissions. The authority for the rule comes from the TSCA. The USEPA’s rule relies heavily on the formaldehyde emissions rules set by the California Air Resources Board (CARB). The federal standards are identical to those set by CARB.

Formaldehyde emission standards
Hardwood plywood (with a veneer core or composite core) = 0.05 ppm
Particleboard = 0.09 ppm
Medium-density fireboard (MDF) = 0.11 ppm
Thin MDF = 0.13 ppm

When it goes into effect, this rule will affect manufacturers, importers, distributors, and retailers of products containing composite wood as listed above.
The USEPA’s final rule goes into effect one year after its publication in the Federal Register. At that point, fabricators, importers, distributors, and retailers of finished goods containing composite wood must begin to comply with new recordkeeping and labeling requirements. The final rule contains detailed requirements for recordkeeping, labeling, and testing of both composite wood and products containing composite wood.

Record-keeping and labeling. Fabricators, importers, distributors, and retailers of composite wood or products containing it will be required to “take reasonable precautions” to ensure their products comply with the emissions standards, defined as preparing or obtaining appropriate documentation, such as bills of lading or invoices, from suppliers of composite wood products that includes a written statement that the products are either compliant with the emissions standards or were produced prior to the rule taking effect. Companies must retain this documentation for at least 3 years.

In addition, importers must provide records (within 30 days of a request by the USEPA) identifying either the composite wood panel producer and date the composite wood products were produced or the supplier of the composite wood products (if different than the producer), component parts, or finished goods and the date of purchase.

Manufacturers of subject products must label each bundle containing finished goods with manufacturer’s name, date produced, and a statement that the material complies with the emission standard. Importers, distributors, and retailers must keep the label on each bundle and make information available to potential customers if requested.

Importer Certification. 2 years after final rule publication, importers will be required to certify that imported composite wood or products containing it comply with the standard.

Testing requirements. Beginning 7 years after publication of the final rule in the Federal Register, manufacturers of laminated products will be required to comply with third-party testing and certification requirements that apply to manufacturers of hardwood plywood panels. “Laminated products” are defined to include only those products with a wood or woody grass veneer, so testing requirements will not apply to synthetic laminates such as plastic or vinyl. The rule does contain certain exemptions for certain laminated products and for use of ultra-low emitting formaldehyde (“ULEF”) resins.

CCES can provide you with technical assistance to help you assess compliance with this and other environmental rules, and to perform a green building analysis. Contact us today at 914-584-6720 or at karell@CCESworld.com.

White House Issues Final Guidance On Climate Change Analyses in NEPA Reviews

On August 1, 2016, the White House Council on Environmental Quality (CEQ) released final guidance on how federal agencies should consider the direct and indirect impacts of climate change, including from greenhouse gas (GHG) emissions, in environmental reviews conducted under the National Environmental Policy Act (NEPA). See https://www.whitehouse.gov/sites/whitehouse.gov/files/documents/nepa_final_ghg_guidance.pdf. This final guidance is not part of rulemaking and, therefore, is not binding regulation. However, some courts consider CEQ guidance when evaluating NEPA reviews. The guidance is effective immediately, and encourages agencies to use it for all new proposed agency actions for which NEPA review is required.

The final guidance confirms the importance of climate change and its effects and GHG emissions fall under NEPA’s perview. In performing such a review of a proposed project, it is fair to evaluate its GHG emissions and the potential effects of physical climate change impacts. The guidance does not give exact criteria that must be followed in terms of GHG emissions and climate change (a change from the draft guidance), but gives each federal agency the flexibility to use its preferred experts and methods to assess impacts and options. For example, the guidance does not contain a threshold level of GHG emissions that would require review or action, but allows the individual agencies to make that determination.

The guidance calls for a quantitative analysis of potential GHG emissions from a proposed project if appropriate and reliable tools or methodologies are currently available. Stating that GHG emissions are “negligible” or expressions like this are discouraged. A quantitative analysis is also required in discussions of alternatives to a proposed action. However, the guidance does not require the decision maker to select the alternative with the lowest level of GHG emissions. A balanced environmental approach is preferred.

The guidance also calls for agencies to consider how climate change impacts, such as increasing sea level, drought, heavy precipitation, etc. could affect a proposed action. Given that certain aspects of projects, such as development in floodplains or on or near a coastline, could be vulnerable to climate change, agencies should either reject such projects or identify opportunities for adaptation to these effects.

CCES has the technical experts to help your firm perform a quantitative evaluation of GHG emissions and assess potential climate change impacts on a potential project. Contact us today at 914-584-6720 or at karell@CCESworld.com.

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.

Prioritizing Your LED Lighting Upgrade

Most people know now that switching to more efficient lighting, such as LEDs, is one of the most effective strategies for saving energy costs. Facility managers are increasingly turning to LED lights for energy efficiency.

However, “going to Home Depot and picking up LEDs” is not the best way to upgrade buildings. It may be a stretch to change all your lights to LEDs at once (lack of available capital for upfront cost, lack of incentives to make it economically feasible). You may have certain goals and constraints. Thus, what can you do to optimize gains from a lighting upgrade in your facility? How should you prioritize an upgrade?

• Types and age of lights currently used. To best prioritize a partial upgrade, focus your replacement on the lights that are older and less efficient, such as T-12 fluorescents, halogen bulbs, and incandescents. Replacement of certain bulbs, such as newer T-8 fluorescents with new ballasts, represent a smaller efficiency gain. Of course, it is preferable to replace them all with LEDs, but if that is not possible, then replace older and more inefficient lighting types first.

• Your current fixtures’ hours of operation and usage. It is best to install LEDs to replace less efficient lights where high intensity light is needed, such as security lights. Also, determine which of your lights are on the greatest number of hours per year. Only bulbs that are on use electricity, so if lights are used in a situation where they are rarely on, such as a storage room or an electrical room, these could be candidates to be replaced later compared to lights used often. Or to look at it another way, prioritize replacement with LEDs of bulbs normally used often, such as warehouses, parking garages, hallways, elevators and entrances. Of course, for lights with these functions, it is also good to consider occupancy controls which automatically dim or shut off the lights during idle periods.

• Maintenance issues. Prioritize replacement of lights with LEDs in places that are difficult to reach or require significant time. LEDs last considerably longer than most fluorescents and incandescents. Therefore, LEDs will also free up your maintenance staff to perform other duties. It will also reduce rental fees of cherry pickers and result in fewer trips up and down ladders, reducing the risk of a costly accident. Longer lasting LEDs mean fewer bulbs to keep in storage, freeing up some space there, too.

• Prioritize based on operating condition needs. Unlike most other lights, LEDs do not flicker, reducing eyestrain for office workers. A recent study estimated that properly-designed (less glare) lights resulted in the average office worker having one less “coffee” break per day, improving productivity. Therefore, switching to LEDs in an office setting could be a higher priority. LEDs can also be found in any color on the CCT scale (2,000 to 7,000 Kelvin). For areas where precise work by workers is critical, such as lab or work benches and offices, an LED with a high CCT rating (5,500-6,000K) may be best.

Of course, it is preferable to maximize energy cost reductions by replacing all your lights with appropriate LEDs. However, because many large buildings and entities have financial and other constraints it may be necessary to prioritize where one replaces older lights with LEDs. Proper research into the areas of the building that are lit and their function and current lighting status will be helpful in prioritizing properly.

CCES can help you design and implement a lighting upgrade to maximize your financial benefits and improve productivity. Contact us today at 914-584-6720 or at karell@ccesworld.com.

Resolution for 2017: Take Control of Energy – Your Most Controllable Operating Expense

It is August, and things may be slow in your office or company, as many people are taking well-deserved time off. But that also means that September – the start of school, fall is around the corner – which means everyone is back at work. For many companies, September is also the start of budgeting season. Departments and Operations envision and plan for projects in 2017, and request budget for them. I think energy efficiency should be on the top of your wish list for your company, as this is the lowest-hanging fruit for reducing operating costs and also provide other financial benefits. Of course, you need to communicate that energy efficiency provides great return for minimal risk to your Finance Dept in language they understand to get approval for initial upfront funding. Actual case studies demonstrate that smart energy efficiency projects help businesses be more competitive.

Briefly, here are some facts about energy efficiency to present to your bosses and CFO:

• Great financial returns. The rates of return for energy efficiency projects vary, of course, based on technology, the building, and design. But in many cases, they are superior to most financial investments, often over 25%/year. What bank or Wall St. investment pays that?

• Low risk, high reliability. New energy efficiency strategies are not experimental and are proven in the field. While some vendors offer better quality products than others, they will work, bring about energy reductions, and should be warrantied.

In financial investing, we are constantly faced with high risk to get high yields. Or if we are afraid of losing our investment, we sacrifice yield. With energy efficiency, we have low risk (reliable product) and get fine cost savings! See chart comparing energy efficiency with other financial investments found below:

http://www.roienergyservices.com/wp-content/uploads/2014/10/Risk-reward.png

• Long lasting savings. Energy efficiency results in continual savings for many years, actually growing in time with no additional effort, based on energy rates you pay, which will only go up in the future. If you saved $1,000 in one year from an energy efficiency project, that savings will be $1,050 the next year if rates increase 5%. And that is with no additional effort on your part!

• Reduced O&M costs. Most technologies last longer than the ones replaced. This means less time for maintenance staff, for example, changing light bulbs. This frees them up for other, more important projects to benefit employees and customers (tenants). Fewer light bulb changes also means fewer trips up and down the ladder, reducing the risk of a costly accident. Longer lasting items mean fewer need to be procured in reserve and stored, freeing up space for other uses or allowing you to downsize the space you rent.

• Raise the desirability and value of your property. Perhaps I’ve saved the best for last. Studies have shown that buildings and offices that are energy efficient are ones that employees will work more productively in, which may be more valuable than the cost savings. Employees will be happier, too, reducing turnover and reducing HR and productivity costs of finding replacement workers and hoping he/she is as good as the one that left. With solid energy efficiency technologies to show, companies or families will have a greater desire to rent your property, raising rental income, or desire to buy your building, raising its resale value.

Bottom line: the right, smart energy efficiency projects will produce many financial benefits, more than compensating for the cost to implement them, and an overall positive cash flow.

I hope this primer will help you approach your bosses for some smart energy efficiency ideas and projects for 2017! CCES has the experts to help you design and implement energy efficiency projects to maximize the financial benefits and to ensure they are implemented properly and work well. We want you to succeed and get the benefits and credit! Contact us for an initial discussion at karell@ccesworld.com or at 914-584-6720.

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.

The Perfection Trap

“If we’re going to do this project, it’s got to be right!” “There’s a lot riding on this. If it does not come out exactly right, on time, and on budget, then we’re (you’re) in trouble.”

Have you come across expressions like this before? I have, particularly on energy projects. While for other projects, it seems to be OK if it is a little less than perfect in execution or a little late or maybe even a little overbudget. But when it comes to an energy or sustainability project, that all goes out the window. Managers expect major cost savings and they be achieved quickly without any disruptions.

This is a managerial mind-set I have experienced myself with some clients, an obsession with perfection. The demand that a project go perfectly or else we won’t do it is wrong-headed for success and for motivating employees.

Energy and sustainability, like most projects, rely on innovation and adjustment to be successful. There is never a guarantee that a return on investment will hit the mark that was calculated in theory on a spreadsheet. Energy, like most projects, needs flexibility, including an openness for minor failures, and improvement from learning from errors.

I have also come across clients who wonder why we perform analyses of likely success and potential financial gain. Why not just “go to Walmart and buy a few hundred of the darn technology and just install it.” No, that’s not the way a successful project works. Yes, one can overdo pre-project analysis. But every building and company is different and it’s important to plan out the energy upgrade or sustainability study, see how it will likely affect the company’s operation and bottom line, and then design it for the best results, taking data to see if adjustments must be made along the way.

This is the best way to approach an energy or sustainability project and will most likely lead to success for your company. Slow, sure, collect data along the way, and learn from mistakes. With that in mind, it is crucial to communicate the progress of your project, so the managers will know what’s going on, why things may be deviating from original plans, but with the understanding of why this is ultimately beneficial.

“If you are going to achieve excellence in big things, you develop the habit in little matters. Excellence is not an exception, it is a prevailing attitude.”
– Gen. Colin Powell

CCES can help your company organize, design, and develop your sustainability, green, or energy program to maximize financial benefits for your individual operations and buildings. We can help you learn from others and communicate progress effectively. Contact us today at 914-584-6720 or at karell@CCESworld.com.

EHS Programs Have Great Financial Benefits

Effective environmental, health and safety (EHS) programs traditionally are viewed as “backoffice” operations, existing only to prevent fines and reduce risk of accidents. But a proactive EHS program that also addresses sustainability issues also helps firms make and save money, according to an Ernst & Young report. http://www.ey.com/Publication/vwLUAssets/Make-money-save-money-and-manage-risk/$FILE/Make-money-save-money-and-manage-risk.pdf

BP paid $25.4 billion in EHS cases brought by federal regulatory agencies since 2010, according to a database called Violations Tracker. While this is the most in the US, several other major firms have paid over $1 billion because of federal EHS violations in the past few years that could have been reduced had they had robust EHS programs.

The report says that in addition to decreasing the number of enforcement actions, fines, and injury costs, a robust EHS and sustainability program also helps companies reduce raw materials used and cut waste and energy and water costs used in operations, which all lead to major cost savings. These cost savings include not only smaller outlays to utilities and suppliers, but reduced O&M and other labor expenses, too, and attendant reduced insurance costs and risks.

But well-organized EHS programs can also lead to:

• increased revenues by enhancing reputation with the public,

• improved employee morale (thus improving productivity and reducing inefficiencies of training so many replacement workers),

• improving relations with leaders and politicians which may allow the company to move forward on a project that some may oppose, and

• putting their products in a more favorable position in the marketplace.

Robust EHS programs also have a balloon effect, improving the technology and providers of such services. Greater programs incentivize better technologies and applications of existing technologies to environmental and safety applications. Robust EHS programs leads to increased spending on the right technology, EHS consulting, and software.

In an era where some Presidential candidates disparage EHS and its importance, these studies demonstrate the many-pronged value of a strong EHS program to companies, municipalities, and the public.

CCES has the experience and expertise to help you organize a robust EHS program for your firm to provide options to realize these advantages and to maximize financial benefits. Contact us today at 914-584-6720 or at karell@CCESworld.com

Our Crumbling Infrastructure and Climate Change

After several harsh winters, several major railroad disasters, and a greater frequency of severe storms, more and more people realize that we have ignored our infrastructure for way too long. Perhaps the tragedy with drinking water infrastructure in Flint, MI put us over the edge. While the focus there has been on who knew what when, this would not have been an issue if the Michigan government had not kept cutting their appropriations for all infrastructure. Even the Michigan Legislature began to support tax increases to support road and bridge repairs two years ago and even Chambers of Commerce, who have been major proponents of tax reductions and smaller government, now realize that potholes, sinkholes, improper water and energy delivery, and bridge failures are not good for the businesses they represent. The Federal government is discussing increasing appropriations for infrastructure upgrades, as well.

Let’s hope that any surge in infrastructure upgrade projects takes potential future effects of Climate Change into account. What is the use of re-paving a road, re-piping water mains, etc., if flooding due to sea level rise and strong storms may wipe out upgraded infrastructure? Therefore, the key concept is resiliency, how the structure will stand up to more rain, snow, longer periods of weather extremes, etc. Some key concepts:

o design, construct roadways, bridges, facilities, railroads, and piping to withstand weather extremes beyond the current norm and to require less maintenance, using materials which will perform more consistently in weather extremes.

o new designs of water runoff including permeable pavement and robust drain and river banks and ditches to handle large quantities of stormwater and less erosion.

o more, not less, roadside vegetation to ensure water uptake during severe storms, plus drought and erosion resiliency.

o larger capacity pumps/pump stations to prevent flooding in key areas.

o better sewer and cleaner water lines to adapt to greater and more frequent freeze-thaw, deeper frosts and drought and flood conditions.

A 2014 US GAO study, “Climate Change Energy Infrastructure Risks and Adaptation Efforts” reviewed likely impacts of climate change on US energy infrastructure, such as

o increased demands for electricity (cooling, pumps, etc.).

o physical risk of damage to the grid.

o risk of power plants’ reliability due to water shortages.

There appears to be momentum for politicians to approve more infrastructure upgrade projects, as the growing incidents are embarrassing politicians. Let’s hope that the engineering community gets more involved with design of projects and takes potential climate change impacts into consideration for long-term benefits, such as LEED.

CCES can help your firm assess its climate change risk, both physical and financial, from extreme storms, sea level rise, flooding, etc. We can help you design and manage solutions to improve your resiliency and benefit your bottom line. Contact us today at 914-584-6720 or at karell@CCESworld.com.

3 Ways To Get Building Owners To Say Yes To Energy Upgrades

March 2016

The CCES blog has returned. It was nice to take a break, but great to be back!!

A lot has been written about getting building owners and managers to invest in smart energy upgrades. We in the profession know they are beneficial in many ways. But how do you get somebody who may be scared by the technical aspects of upgrades to not stick with the status quo, even when presented with positive reasons? A recent article summarizes 3 barriers to overcome to get most such people to agree to move forward: http://www.slate.com/articles/business/the_juice/2016/03/ge_sells_1_4_million_leds_to_jpmorgan_it_s_the_most_important_light_bulb.html.

The three barriers are:

1. Does the technology work? Not only does it save significant energy, but does it do so without sacrificing any of the features of the technology it replaces or causes the user to sacrifice its lifestyle or workstyle to enable it to be used?

2. The finances. Is the simple payback reasonable and/or is the rate of return outstanding? As for the latter, we are looking at the energy cost savings plus other indirect benefits (reduced O&M, increased asset value, improved worker productivity) vs. the length of time the technology is used for.

3. See the project through and ensure that the technology works as designed. If the buyer just receives the technology and has to install something so new and different, it will get scared off.

If these concerns are suitably addressed for a given technology, whether it be solar PV or LED lights or anything else, then there is a good chance that even an unknowledgeable potential buyer will go forward.

CCES is an energy consulting firm helping buildings, companies, and municipalities to determine the best strategies and technologies to reduce their energy usage and demand, to reap maximum financial benefits from the upgrades, and to ensure that any chosen strategy is incorporated in the best way for your operations. Contact us today at 914-584-6720 or at karell@CCESworld.com.