Companies are under growing pressure from outside advocacy organizations to improve their practices, not only in their products’ image, but even in their supply chain and how products are made. We have been in a globalized economy for some time now, as companies have outsourced manufacturing to or obtain raw materials from farflung countries, which not only do not have environmental, safety, and labor laws nor enforce them like in the US, but actually offer incentives to lure them over, such as tax breaks and very cheap labor. Another lure is that by doing much production work overseas, it would be beyond the ability of watchdog groups to watch.

But some have done just that. One of the first examples 2 decades ago was Nike, who underwent much criticism of the underage and underpaid labor used to produce Air Jordans and other brands, not to mention the unsafe conditions and equipment used. Now more advocacy groups are able to spend more time investigating a wide variety of companies. In addition, the ease in documenting and publicizing supposed misdeeds through social media has resulted in the greater potential for bad publicity for a variety of consumer brands to occur in a short amount of time.

Much of this exposure has moved into the environmental and sustainability areas, as standards for the derivation and use of energy, minerals, water, food, chemicals, and others have been scrutinized and publicized. Environmental and business practices have never been so closely reviewed and publicized by outsiders ever.

What is a company to do? A company’s reputation with its consumers is of extreme importance in this age of almost instant publication of information. A company must know that its upstream suppliers, retailers, investors, and the public all be satisfied that operations, once thought to be private, are not embarrassing in any public way.

Therefore, companies need to take a deeper look into how they manage their water, energy, resources, and environmental impacts, as well as labor and social issues, so they are beyond reproach by an external group and beyond demonization. This can best be achieved by a thorough external review of processes.

Companies must adapt to a new world of being able to research in detail many procedures thought of as beyond review and the ability through social media to publicize any perceived failings in hyperspeed. A thorough review and optimization of processes that are positive for sustainability will only make such companies look better.

CCES has the experts to help your company or entity perform detailed reviews of environmental and sustainable procedures and can make recommendations to make your program more robust and beyond reproach. Contact us at karell@CCESworld.com or at 914-584-6720.

On July 31, 2014, the USEPA published a Request for Information (RFI) to seek comments on potential revisions to its Risk Management Program (RMP) regulations.

See: http://www.epa.gov/emergencies/eo_improving_chem_fac.htm.

Also see Executive Order (EO) 13650: Improving Chemical Facility Safety and Security. The EO is intended to enhance safety and security at chemical facilities and reduce the risks to all potential affected parties (workers, public, etc.) associated with a hazardous chemical release.

RMP (Section 112[r] of the Clean Air Act) was created in the 1990’s in response to deadly accidental chemical releases in Bhopal, India and Institute, WV. The goal of RMP was to prevent major chemical accidents from causing disasters by establishing a prevention and response program. All facilities that store or use a regulated chemical at or above threshold levels are regulated under RMP. Now that over 20 years have passed since its original inception, the Presidential EO asks whether the program needs to be upgraded, particularly to meet new security (9/11) concerns since its origination.

EO 13650 requires the USEPA and OSHA to review the chemical hazards covered by their existing risk management programs and develop options to improve them. OSHA issued an RFI on potential changes to its Process Safety Management (PSM) standard on December 9, 2013. The USEPA’s recent RFI coordinates with the potential changes to OSHA’s PSM program for accident prevention measures.

The USEPA is considering potentially updating the list of RMP-regulated substances, and adjusting their threshold quantities and toxic endpoints based on up-to-date toxicity research. The RFI seeks comment on potentially changing several existing process safety procedures under RMP including compliance audits; equipment maintenance; management of change; emergency response capabilities; and incident investigation. It also seeks comments on potential additional risk requirements, such as mandatory use of safer technologies; process safety metrics; automated monitoring of releases; emergency drills; stop work authority; and siting risks.
Public comments and other submittals for the RFI, EPA–HQ–OEM–2014–0328, are due on October 29, 2014. They may be submitted by mail or online: www.regulations.gov.

CCES can help your facility determine compliance with the current RMP rule, assist in making your compliance program more streamlined and effective, and in assessing the effects of any future changes to the program to your facility for effective planning. In addition, we can help you assess all of your potential air emissions, as well. Contact us today with any questions at 914-584-6720 or at karell@CCESworld.com.

President Obama announced a series of climate change initiatives on July 16, 2014 aimed mainly at improving the nation’s ability to withstand adverse physical effects of climate change (adaptation), such as safeguarding electricity production and transmission, improving flooding, erosion and storm surge planning, and better managing landslide risks. A Fact Sheet describing the initiatives: http://www.whitehouse.gov/the-press-office/2014/07/16/fact-sheet-taking-action-support-state-local-and-tribal-leaders-they-pre.

These actions were among the recommendations of the President’s State, Local and Tribal Leaders Task Force on Climate Preparedness and Resilience, a group of 26 officials who have worked since November to develop the proposals.

One of the recommended projects involves safeguarding the nation’s power supply during climate catastrophes, such as extreme storms damaging power infrastructure and lines and hotter weather resulting in greater surges in demand that the system may not be able to currently meet. The Dept of Agriculture awarded $236.3 million to 8 states to improve electricity infrastructure in rural areas.

Addressing another recommendation, the US Geological Survey and other federal agencies said they would spend $13.1 million to develop advanced 3-dimensional mapping data available to any municipality to provide information to draft strategies in response to weather-related disasters.

The Centers for Disease Control and Prevention released a guide titled “Assessing Health Vulnerability to Climate Change” (http://www.cdc.gov/climateandhealth/pubs/AssessingHealthVulnerabilitytoClimateChange.pdf) to help identify health hazards that might be caused by climate change.

These new initiatives are part of a broader White House strategy to address climate change. Besides these initiatives to prepare for adverse physical climate change effects, the White House wishes to become a leader in reducing GHG emissions to lessen climate change impacts. It issued an Executive Order to support a USEPA plan directing states to submit proposals to reduce GHG emissions from coal-fired power plants. The plan is expected to reduce demand for coal, spur growth in the usage of natural gas for power (which emits much less GHGs than coal per Btu), and foster research into reducing GHG emissions from coal combustion.

CCES has been researching and is qualified to consult in ways for you to adapt to future climate change effects. Lessen the damage and negative business impacts on you of severe storms, drought, and extreme hot weather, and also enable you to bounce back (be resilient) faster. We can help you survive and thrive. Contact us today at 914-584-6720 or at karell@CCESworld.com.

The articles of this blog and newsletter focus mainly on new regulations, Supreme Court rulings, how you can save energy and lessen environmental impacts at your office or industrial area, etc. Good things to help you at your job. One thing I should also provide is good energy/environmental tips for you at home to save you money, too because we all know that energy is a growing portion of our household budget. So here they are. And feel free to use these to put together your own list to provide to your employees so you can have a hand in making their lives better to and engender support at work.

1. Buy Energy StarTM-labeled products. This joint EPA/DOE program lists the most energy efficient products around. Such products are typically a little more expensive upfront than non-Energy Star rated equivalents, but pay back that difference in a short time. This covers household items like TVs, refrigerators, laptops, printers, etc. This is probably the most cost effective way to reduce your energy costs.

2. Convert lighting to LEDs. After some initial problems, LEDs are now reliable and here to stay. LEDs are made for nearly every application in a home (or office), and can be dimmed or similarly controlled. Yes, they are more expensive, but make it up in energy savings and their longevity (fewer replacements and trips up the ladder).

3. Your car. Certainly, a car with a high mpg rating will provide major cost savings and fewer trips to the gas station. But it also means lower emissions from the tailpipe and lower exposure to your family and others. With that in mind, minimize the idling you may do at your children’s school, the supermarket, etc. Carpool with neighbors and encourage them not to idle either. Your town may have a law against it already.

4. Your clothing. Choose a dry cleaner that does not use “PERC”, a toxic compound. PERC can stick to your clothes and be slowly released and build up in the contained space of your closets or on your body, where it can be absorbed into your bloodstream. “Green” cleaners are popping up in a lot of communities.

5. Your indoor air. We all spend more time indoors so the quality of that air we breathe is important. Be careful if you “freshen” a room with scented candles or air freshener. The chemicals contained in air fresheners, while smelling nice, and released from burning candles may be harmful. Consider opening a few windows regularly (if safe) to let in fresh air, such as on a summer night. Also, consider reading labels and buying “green” home cleaning products to minimize volatile toxics in the indoor air.

6. Your food and water. What we should eat or drink is up to us. However, we all can agree that it is best not to re-heat food stored in plastic in the microwave. This can cause leaching of chemicals from the plastic container or wrap onto your food. Be aware of your municipal water. Most meet regulatory standards. If you are concerned, use a filter and store in glass or steel containers and minimize plastic.

CCES has the experts to help you with technical upgrades to help your commercial space use less energy and to reduce the environmental and health impacts on your staff. Contact us today at karell@ccesworld.com or at 914-584-6720.

Last month, this newsletter’s featured article was about how to sell energy or sustainability projects internally, to explain the value of a proposed project to the decision makers and get them to say yes. It got a lot of clicks (Thank you!), and I hope it gave you some good ideas to apply at your organization. With that in mind, I present more approaches and strategies to communicate the value of such projects. Much of this material derives from academic research conducted by Ann Dale and Rob Newell of Royal Roads University in Meeting the Climate Change Challenge (www.mc-3.ca).

Here they provide additional tips (with some interpretation from me) to help anybody communicate the need and benefits of performing energy and sustainability projects.

1. A picture is worth a thousand words

As discussed last month, it is critical to communicate the total value and benefits of a proposed project. While we engineers and scientists like to use numbers to express this, visual images could more effectively show (non-technical) decision makers the benefits of a proposed energy or sustainability project.

Visualization might include showing maps of where a company’s properties or manufacturing centers are located contrasted to nearest energy sources or water availability, etc., potentially demonstrating the future shortage or high cost of obtaining such resources. A map may be able to show vulnerable properties near bodies of water or in flood zones, demonstrating how they may be vulnerable to severe weather. Another example is showing pictures of transportation routes to and from key facilities and how vulnerable they may be to hurricanes, flooding, fires, and other disasters. For a municipality, a map can show vulnerable areas that would potentially need more resources unless preventive infrastructure upgrades can be implemented.

2. Demonstrate that your proposed project will benefit many departments

It is natural to focus the selling of a potential project on the benefits to one’s own group (after all, that’s what we focus our time) and/or the overall organization. However, it is also more effective to list specific benefits for other departments and how it may help them solve their problems. Remember, in the example I gave last month, I cited how efficient lighting will save a municipality significant costs (making the Treasurer happy), free maintenance workers to do other tasks (pleasing Public Works), and make downtown more inviting for people to shop and spend money (make the Mayor happy). Senior managers like to be able to solve multiple problems at once. Who wouldn’t like a project that can assist in addressing multiple problems and facilitate progress?

3. Success requires collaboration, which breeds more innovation

Sustainability and energy conservation are unique in that it takes many different skills for a program to work. No single expert or group has all the solutions for sustainability. Multiple specialties, such as engineering (electrical, mechanical, environmental, energy), legal, financial, product development, marketing, and social, must work as a team to accomplish all of the goals reliably. Sharing of multiple talents across departments and specialists outside the organization spurs innovation and success.

4. Look inward for valuable information

Some of the best sources of information about how a facility operates and how they can benefit are from those that work there. Yes, managers and directors. But also, “blue-collar” staff employees have valuable ideas, working there every day. I have worked on many environmental and energy projects where plant employees and Admins. have given me valuable information about the workings of the plant, office, etc. that was unknown to managers. Explaining to them your ideas to save the organization money or improve flexibility and sustainability will likely motivate them to provide such information to you and can provide additional benefits to work performance to share with managers.

5. Phrase such proposed project as “Win-Win” opportunities and as real

With all of this, there may still be skepticism among decision makers for sustainability and energy projects because they were not taught about this in school and/or have never faced an energy “crisis”. While this project may be proposed to avoid a crisis, the decision maker may not have served during an actual crisis, such as the Oil Embargo of the late 1970’s, to fully appreciate the impacts. Therefore, it is important to point out the implications and the risks involved in either not performing the project or doing so while “cutting corners.” Numerical estimates of potential money, prestige, markets, etc. lost by not performing the project at all or properly should be researched and included.

Decision makers sometimes fear being the “guinea pig.” Therefore, it is a good idea to document similar projects done by other organizations, including competitors, enabling the decision makers to realize this is not theoretical material, but real science that has worked in the “real world” and has benefited others.

CCES can help you or your group prepare proposals and presentations concerning energy, sustainability, and environmental projects for internal review and approval, highlighting the many and specific values that it can give your entity. And, of course, we can manage and implement the projects, too, to achieve those savings and benefits. We are here to help you succeed and meet your goals! Contact us today at karell@CCESworld.com or at 914-584-6720.

On June 23, 2014, the U.S. Supreme Court mostly upheld and partly rejected USEPA’s “Tailoring” rule pertaining to greenhouse gas (GHG) emissions from stationary sources.

The decision concerns two major stationary source permitting programs, PSD and the Title V, being “tailored” to address GHGs. In 2010, the USEPA announced that it was adding GHG emissions to the list of pollutants covered in each program. Various states and industry groups challenged the change, and the Supreme Court gave its ruling.

7 justices held that the USEPA can require sources that are subject to PSD because other pollutants exceeding thresholds (“Anyway Sources”) to also control their GHG emissions. However, a majority of the Court also held that a source’s GHG emissions by itself cannot mandate PSD and Title V permitting, a setback for the USEPA.

By exempting sources of GHGs which are not subject to PSD or Title V due to other pollutants, many large sources of GHGs who emit relatively small quantities of other pollutants would be exempt from such permitting and control, which includes some landfills, pulp and paper producers, electronics plants, and beverage producers. However, the USEPA stated that despite the ruling, about 83% of GHG emissions would still be covered, compared with 86% of emissions had the Court allowed regulation of all sources.

The Supreme Court focused its decision on the application of GHG regulation to the specific programs and not to Section 111(d) of the CAA, which gives the agency latitude to add pollutants to any program if the prevailing scientific research states that the pollutant in question needs regulating to protect public health and the environment. Some complainants said this part of the CAA was unfair and should be struck down. The Supreme Court did not address this in its ruling.

This ruling is also unrelated to the USEPA’s request to set emission standards for GHGs under a separate provision of the Clean Air Act. On June 2, Pres. Obama announced proposed rules calling for a 30% reduction in GHG emissions from existing power plants, including coal-fired facilities.

CCES has the experts to provide you with technical interpretations of Air and other environmental rules applied to your operations and facility. While it is important to retain the proper legal experts, CCES can provide technical explanations to these very technically-written rules and also provide the most cost-effective strategies to reliably comply with the rules. Contact us today at karell@ccesworld.com or at 914-584-6720.

According to a recent GAO report (http://www.gao.gov/assets/670/660558.pdf), US energy infrastructure is increasingly vulnerable to a range of climate change impacts, increasing the risk of disruptions of energy critical for your operations, such as:

• Resource extraction/processing infrastructure. Oil and gas platforms, refineries, and processing plants are often located in areas vulnerable to severe weather/sea level rise.

• Fuel transportation/storage infrastructure. Pipelines, railways and storage tanks are susceptible to damage from severe weather, melting permafrost, and increased rain.

• Electricity generation. Power plants are vulnerable to severe weather/water shortages.

• Electricity transmission and distribution. Power lines and substations are susceptible to severe weather and stressed by rising demand for electricity as temperatures rise.

What can be done to help reduce climate-related risks and adapt energy systems to climate-related impacts? Options generally fall into two broad categories—hardening and resiliency. Hardening measures involve physical changes that improve the durability of specific pieces of infrastructure, such as elevating and sealing water-sensitive equipment. Resiliency measures allow energy systems to continue operating after an event and to recover more quickly, such as, installing back-up generators.

The report states that the most of the changes to adapt to climate change must occur at the local government and private levels, although some federal support can happen. Energy infrastructure adaptation is best accomplished by good planning and design. Some useful approaches by local municipal and private entities include:

• Design more resilient, lower maintenance roadways, bridges, facilities and roads;

• Incorporate materials which will perform well in weather extremes;

• Better control of precipitation runoff including pavement redesign and strengthening its conveyance system to prevent erosion;

• Stronger and lower maintenance bridge design, looking to long-term usefulness;

• Maintain proper wetlands to ensure water uptake during floods/erosion resiliency;

• Larger capacity pumps/pump stations to mitigate key road flooding;

• Improve infrastructure to resist more freeze-thaw, deep frosts and droughts; and

• Encourage residents/businesses/workers to reduce demand on electric grid.

CCES has the experts to help your building, company, or municipality understand potential impacts of extreme weather and help you plan to reduce the risks and increase the speed in which you bounce back from an event. The time to plan and act is now. Contact us today at 914-584-6720 or at karell@CCESworld.com.

As an energy, sustainability, and environmental consultant, I am constantly “selling” appropriate projects to clients who can really benefit. As you readers probably know between this newsletter and my website, I have a short flyer entitled: “The 9 Purely Business Reasons To Save Energy”. Not saving the polar bear or the Amazon Rain Forest, but direct financial benefits. Not hypothetical or “blackboard”, but with real-life case studies. Convincing, overwhelming. I used to think this was a slam dunk to win business helping entities set up such programs. But as I sit down with more and more business or municipal leaders, everyone agreed that these 9 reasons were spot on and appropriate. However, this approach would be a tough sell in-house. What can be done to make it easier for you, the reader, to sell such a program (and increasing your budget to do so) to your corporate or municipal leaders?

The most common problem is that the person making the decision to allocate money to begin or expand an energy or sustainability program is somebody who is not in the field day to day and maybe does not even understand what sustainability is. The answer, it appears, would be to educate that person. The problem is that this takes time, something the executive simply does not have or a desire for. But to further your career, it is helpful to give you some tips to sell such projects internally, and that’s what’s contained in this article.

When your supervisors tell you that a project you are interested in “doesn’t fit into the budget,” it may mean that they don’t understand the true value of the project. There are two options: lower the cost and/or raise the value of the project in their eyes. You can lower your potential project’s cost, but then you increase the risk that the project will have a lower impact or value to the company and/or will fail.

The better solution is to re-position and re-communicate the proposed project in such a way that it shows value to those specific decision makers and what they consider important. This lends itself well to energy, which has many potential, diverse benefits.

Here is an example that I recently experienced. I made a presentation to a municipality focusing on street lights, and upgrading them to LEDs, for better lighting using less electricity. In the room was the mayor, the Treasurer, and the head of the DPW. This is a fairly conservative town that does not like to take what they perceive as “risks” (do anything much different than was done in the past), nor care about environmental or global concerns. In the entire presentation, I did not even mention even once words like carbon footprint, greenhouse gases, or climate change. I knew that if anything this would turn them off. I stuck to financial benefits only. I presented a rough calculation that when all the street lights are switched, they would save at least $250,000 per year in avoided electricity costs (and more as rates increase in the future), money that could be spent elsewhere. I asked whether this was a significant savings and could be useful to their budget as their citizens demand more services. I honestly did not know if this was a significant savings or not. The Treasurer chimed in quickly, yes, they sure can use the money not spent on energy for shortfalls in other areas. (They can’t raise taxes anymore.) She became a fan of the proposed project. I then mentioned that most LED vendors warranty their street lights for 7 years, meaning there would be much less maintenance to replace non-operational street lights. Would that be helpful, I asked? Yes, very much so, said the head of DPW. He said he currently had 2 fellows nearly full-time replacing blown out lights. There were plenty of other tasks his department was behind on that he could use those two staff people. He became a fan of the proposed project. Finally, I prepared a rough conservative financial analysis of the project, demonstrating that the project will likely have a return on investment of 14% per year. I joked and asked what bank offers such a return! But in reality, they should have little problem getting a bond at a lower interest rate seeing this potential return. I also presented a calculation of what are the consequences of not doing the project, keeping the status quo. Over 7 years, the town would spend more money than if they did the project (just spread out) replacing bulbs, not get the quarter million per year saving, and not free up the staff people. Now the Mayor himself saw the contrast and he got on board. Now, the entire group, skeptical about any new project, supported the project because it brought value in areas of importance to each.

The key here is to understand the decision maker(s). What is important to each of them? What does each perceive as “value” to themselves personally or to the company or municipality? Remember that these values vary between people, based on their specific needs. Therefore, before bringing a proposed project to the attention of the decision makers, it is critical to assess each decision maker’s role and what is important to each one. You therefore need to think through what each believes is of value.

Therefore, the key is to focus on the decision makers’ needs or value system. It’s hard, but try to minimize including what you think is of value. Doing so will overload the information and “values” being transmitted to the decision makers. Too much information may be a turnoff and/or dilute the impact of the items of value.

This is how you will increase the value of your proposed product or service in the client’s eyes. Good luck. I hope you succeed in getting your proposed projects approved!

CCES can help you or your group prepare proposals and presentations concerning energy, sustainability, and environmental for internal review and approval, highlighting the many and specific values that it can give your entity. And, of course, we can manage and implement the projects, too, to achieve those savings and values you espouse. We are here to help you succeed and meet your goals! Contact us today at karell@CCESworld.com or at 914-584-6720.

I was fortunate to have been the construction and environmental manager for one of the largest conversions from No. 6 oil to natural gas so far in NYC. 3 large boilers, providing heat and domestic hot water for 8 high-rise apartment buildings and other areas, were upgraded in preparation for the fuel switch. It is now two years since the switch was implemented, and I was asked to estimate cost savings for these two years compared to the last two full years of full No. 6 oil service to determine cost savings. Well, between the improvement in thermal efficiency and the price difference between natural gas and oil, the building owners have saved millions of dollars per year compared to before the switch, despite the fact that the last two winters were colder than the earlier two under No. 6 oil (in terms of heating degree-days)! The payback for this multimillion dollar project will be under 3 years. It is being hailed as a success. The client is happy.

But it turns out that the client has achieved other benefits it did not expect. By switching from No. 6 fuel oil only to natural gas with No. 2 oil as a backup, they have much fewer oil deliveries. Before the project, the boilers were combusting over 2 million gallons of No. 6 oil per year. Trucks used to travel through the narrow neighborhood streets to deliver oil approaching 300 times per year. Every time a truck arrived some workers at the boiler house had to stop their tasks and help the truck driver load the storage tanks. Now, with No. 2 oil as a backup, in the first year of operation there were only 2 truck trips all year! Only twice workers were interrupted from other tasks to help unload. From nearly 300 interruptions to 2. So this has caused stress to go down and productivity up.

Plus, boiler house costs and time devoted to maintenance have decreased. Natural gas is easier to manage compared to thick No. 6 fuel oil, which itself has to be heated just to flow. Pumps, valves, and other equipment had been taken out of service and cleaned and serviced much more than they need to now, improving efficiency among the staff. The new automated control system has also saved staff time.

Finally, the switch to natural gas substantially reduced the risk of a calamity. There was a risk of No. 6 fuel oil leaking from some overburdened piece of equipment, causing preparation for such an event and the potential tremendous cost involved in removing and cleaning this viscous fuel. Now with less No. 2 oil handled and a new modern tank farm, the risk of a spill and the potential cost if one were to occur are both much lower.
This housing complex’s switch to natural gas for its heating needs has been a big financial winner for them, not only in terms of efficiency and direct cost savings, but also in terms of these less visible, but critical additional gains in operational improvements.

CCES has the experts to help you evaluate all of the advantages of a fuel switch or other boiler upgrade to save you money and aggravation, as well as to manage its implementation. Contact us today at karell@CCESworld.com or at 914-584-6720.

The USEPA sent amendments to the Renewable Fuel Standard (RFS) to the White House’s Office of Management and Budget (OMB) that would further incorporate the use of biogas into the RFS. OMB review is the last step before finalizing an agency rule—it is reasonable to expect the final rule to be published some time this summer.

RFS requires gasoline and diesel refiners, blenders and importers to purchase and use an renewable fuel credits (RINs) representing volumes of renewable fuel to offset the annual production of petroleum-based transportation fuel. The final rule, if not modified by OMB, would increase the number of RINs required generated on biogas and therefore, increase the value of those RINs. This is part of the strategy to encourage the profitable production of biogas for heat and for transportation.

Currently, the USEPA allows the generation of “Advanced Biofuel” RINs only for biogas produced at landfills, wastewater treatment plants and manure digesters used as a direct transportation fuel (unmodified). Biogas that is converted to another form, such as electricity, and then used as a transportation fuel (electric vehicles) are not included.

The proposed rule allows biogas from landfills to qualify as a Cellulosic Biofuel, which would generate a RIN. Few RINs are currently from cellulosic sources. The USEPA has also proposed that the entity that can generate and sell the RINs is the “producer” of the renewable fuel, the company that compresses or liquefies the biogas into compressed natural gas or liquefied natural gas that is combusted as the transportation fuel.

The proposed rule would also allow RINs to be awarded for biogas that is subsequently converted to electricity, provided that that electricity is used as a transportation fuel. Given the large amount of room, most of the biogas collected at landfills, wastewater treatment plants and dairy farms is combusted to produce electricity. Some of that electricity is used for energy for the facility’s processes (pumps at wastewater treatment facilities, pasteurization at dairy farms). The proposed rule would require the producer to delineate electricity from landfills used specifically for transportation and all other uses of the electricity. Only the former would qualify the producer for RINs.

How will this affect you and your company? The proposed amendment of the RFS biogas rule will further encourage the production and distribution of biogas for electric and compressed natural gas-fired vehicles. Now that electricity can be an intermediate to qualify for RINs, more electric vehicles will be on the market and, therefore, become more affordable. This should also increase the number of biogas projects around the country, spur research, and make them more ubiquitous and profitable.

CCES has the experts to help you determine your proper energy mix for not just your processes, but for your fleet and other needs, as well. We can help you reduce your risk by expanding your energy sources and save money, too. Contact us today at karell@CCESworld.com or at 914-584-6720.