Nov. 29, 2011

With all the bad press from the federal bailout of Solyndra, one fact was forgotten. Sales of Solyndra’s alternative design dropped, leading to its bankruptcy, because of a glut of polysilicon, the semiconductor used in the most common type of solar panel. In fact, polysilicon’s price plunged by 93% since 2009. Standard designs are now less costly.

So what does this mean for the solar industry and does that make getting electricity from solar a more viable alternative for a facility? According to Bloomberg, because the cost has dropped so greatly, the top five producers of polysilicon have doubled output and will likely produce more polysilicon than needed to meet global demand for solar panels in the foreseeable future. While this may lead to a shakeout in the industry and some shutdowns, all prognostications are for a settling of the market price around or slightly higher than its current value, leading to a period of cost stability for polysilicon.

Given the dropping and likely stable prices for solar panels, is this the time for a facility to “go solar”? Some recent published articles indicate some key concerns remain. First, price. While polysilicon prices have dropped markedly, it represents only 25% of the total cost of solar PV. Last summer, the price for solar was about $0.20/kwh, not competitive with fossil fuel-based electricity from a utility. A drop of 25% may still not make it competitive. In addition, the upfront cost to install solar panels on a roof or in a parking lot is still relatively high compared to wind turbines and, of course, compared to little cost for existing utility electricity lines. So while prices for a system will drop, it is unlikely to be a sure fire alternative to traditional electricity sources cost-wise.

Another concern is government subsidies. A decline in the price for solar PV may signal the government to no longer subsidize potential solar purchasers. Such purchasers may be concerned about long-term planning of changes in such subsidies.

A final thought concerns the public. Besides having “free” electricity from the sun (and possibly selling excess electricity generated back to the grid), how will a company’s stakeholders and the public view this? While the customer base (both retailers and the public) would be pleased to see publicity photos of new solar PV cells providing clean energy, companies know that the bottom line is holding the line on prices. Since a company by nature must pass on all costs on to the products it sells, companies are concerned that solar PV may still put them in a non-competitive position compared to relatively cheaper electricity from the established grid. Executives are still concerned about the issues that have been holding up solar PV growth in the first place.

CCES experts can help your firm evaluate whether alternative energy is right for you.

November 22, 2011

Thanksgiving and the year-end holidays are a time for big meals, family, etc. But we should always keep the thanks in Thanksgiving. Here are some statistics to drive home the importance of sustainability and for Thanksgiving. You probably heard the news story about a month ago that the Earth’s population has just reached the 7 billion mark. But there is another statistic that did not make the news even more sobering. According to the IPCC, of the 7 billion people a little over 1 billion live “like us”. That is, we eat 3 full meals a day, own our own car (and maybe more than 1 and a boat, too), have a roof over our heads where we can easily burn fuel or use electricity with a click of a button to control the temperature, go on vacation, and use many “things” to make life easier (i.e., TVs, smartphones, laptops, etc., etc.). And even if some of these billion plus people do not physically have all of these, it is only by choice. Yes, we in the U.S., Canada, Western and Central Europe, Japan, Australia, and parts of other countries are all high resource and energy users. This is not a guilt trip. We have been given this opportunity to have access to these. They are affordable, so we consume and use.

But this statistic leads to two important points. According to several demographers, the expected world population in 2050 – less than 40 years from now – is expected to be 9 billion. OK, what’s a couple of billion more mouths to feed, particularly if most will live on subsistence diets, will not own cars or climate-controlled homes, take vacations, etc.? But the kicker is that it is believed that by 2050 the number of people who will be “like us” will increase from a little over one billion to 3 billion! 2 billion additional people will live in bigger homes, drive cars, use laptops, refrigerators, clothes washers, TVs, smartphones, etc. This will occur mainly in the “BRIC” countries as they grow and people move to the middle class. We are already seeing many people in China giving up their bicycles and buying their first automobiles, where both the infrastructure (the roads) and the environment (the air) are not ready for this big increase in automobile usage. Therefore, sustainability is a must for us. How can we refuse these additional 2 billion people having seen how “we” live to live “like us”, too? But how can we provide the extra energy, water, and resources for all of these new items for these additional 2 billion people? We must redouble our efforts to be sustainable or our natural resources will be so scarce as to put us in another recession (or worse) or lead to war or protests.

And, how does that initial statistic relate to Thanksgiving? If you are reading this article, you are most likely in the one billion out of 7 who live a high energy lifestyle. No matter what may be troubling you (and I am sure that it’s legit), always be thankful that you have access to 3 full meals a day, a comfortable home, means of transportation, access to the Internet, TV, and gadgets galore, etc. Be thankful that you are not part of the 85% of the world’s population that do not have access or cannot afford all of these pleasures.

Happy Holidays to you and your family from CCES.

November 2011

According to the USEPA, energy use in commercial and industrial buildings costs U.S. companies about $200 billion per year. And for many businesses, energy costs (with unit prices rising every year) are among their largest expenses. Therefore, the direct financial benefits of reducing energy use should drive all companies – even non-“smoke stack” facilities – to establish a program. So what is holding up many U.S. organizations from devoting themselves to reduce energy? For many, it is the lack of standards. What constitutes a proper, effective effort to reduce energy use? How can my company achieve reductions and yet not overspend upfront? What are my competitors doing?

Earlier this year, the ISO organization published final energy management certification standards: ISO 50001 (http://www.iso.org/iso/energy_management_system_standard). This follows other ISO standards (ISO 9001, 140001), and applies to energy management.

ISO 50001 takes a holistic approach to energy management and not mearly to “check off” the boxes or on one-time achievements. ISO 50001 requires the facility to establish an energy baseline and from this develop realistic energy goals and strategies (i.e., improve energy efficiency and conservation). Once energy strategies are implemented, ISO 50001 requires monitoring and recordkeeping to ensure that selected technologies and strategies continue to work toward intended energy goals and that management oversight of energy is part of the corporate or facility “culture”.

ISO 50001 focuses on long-term improvement in energy management, not just meeting some short-term goals and stopping there. One of the criticisms of the LEED green building program is that it is perceived to focus on meeting a goal (LEED certification at some level), implementing strategies to meet the goal, and potentially stopping there and not necessarily ensuring that the strategies work optimally long term. ISO’s continuous improvement emphasis ensures the best return on investment for the facility, as well as long-term reduction in energy usage, expenses, and greenhouse gas emissions.

One unique feature of ISO 50001 is the requirement for 3rd party review of energy management systems. This is intended to raise the pressure on those that pursue ISO 50001 certification to do it properly and to do so to prosper in the long terms.

Energy savings, as discussed in earlier Environmental News for YouTM, is the most successful strategy for those looking to be more sustainable and achieve economic gains in the quickest timeframe given its measureable metrics (reduced kwh electricity or gallons of oil or cf of natural gas) and the fact that unit energy prices (cost per kwh electricity or per gallon of oil) are at record levels and in the long-term will likely continue to grow as there are only finite sources of fossil fuels.

Those companies looking to garner financial gains in 2012 should look into energy savings. Planned, site-specific energy audits followed by implementation of reasonable findings are virtually guaranteed to pay for themselves and more. According to the US Dept of Energy, 40-50% reductions in energy use (and concurrent reduction in energy expenses) within 5 years of beginning the process were shown to be typical and fairly consistent across type (office building, retail, etc.) and U.S. region (arid vs. wet, cold vs. warm). Remember the power of energy savings from a business point of view. Saving energy expenditures is money “in the bank”, directly raising profits. The alternative way to make a profit, increasing sales or revenues, takes a large investment (sales staff, ads, etc.), is not guaranteed, and can change from year to year. Energy savings continue with no additional changes and grow (as unit costs grow) in the future.

Now that there are new respected energy standards from ISO (as so many companies have met ISO 9001, ISO 14001 and other ISO standards), any hesitation based on not being sure how to implement an energy program should disappear.

What is the future for ISO 50001? As a voluntary standard, will it have much impact? It is possible that major companies that already collect information or set standards for their supply chain, such as Walmart and IBM, will request their suppliers to address and potentially certify under ISO 50001 in order to continue to do business. When Walmart began requesting greenhouse gas life cycle information, suppliers rigorously began to determine their carbon footprint. A similar request from Walmart on the energy side will likely cause a similar reaction. Besides pleasing customers and investors, significant cost savings should merit a systematic upgrade in the energy usage area. ISO 50001 now provides a valid roadmap and standard to validate pursuit by all types of companies and gives security that an internationally-accepted standard is being met.

Get more useful information in our blog:

www.CCESworld.com/blog
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This Environmental News for You is meant to provide background on the new ISO energy standards. CCES experts can assist you in implementing these standards and showing how you can improve efficiency and financially benefit from this and other sustainability programs.

November 8, 2011

This seems a bit of an oxymoron. After all, how much can banks contribute to environmental sustainability? Banks do not require a lot of water to operate or release toxic pollutants into the air. To my knowledge the printing of money does not have a large carbon footprint. While banks and all office-based enterprises can be made more energy and paper-efficient, saving significant expense, it won’t save the world.

But in reality the financial industry can have a major impact on global climate change and energy issues by how it finances new projects. Banks provide the capital that every new project or business needs to start and grow. To maximize its payback for money lent or invested and to reduce risk of loss, “green” is being recognized as very important. Several major banks and investment houses are beginning to recognize that investment in green buildings and clean and smarter infrastructure is needed in the U.S. and can result in good returns and low risk of failure. They recognize this as good economics and not being “cool” in any way. A study by AT Kearney showed that between 2008 and 2009 (during the economic crisis), companies that had a sustainability focus (i.e., listed on the Dow Jones Sustainability Index or Goldman Sachs SUSTAIN list) outperformed equivalent companies across the board by 10 to over 25%. That certainly would be preferable companies for financial firms to invest in.

And then there is growing concern about climate change. The banking community is now taking the cue from the overwhelming majority of the scientific community that now believes climate change is real and could potentially do extreme damage to manmade structures and projects. The risks and liability are real. The United Nations Environmental Programme estimated that lost value of buildings and structures because of climate change could total $1 trillion every year by 2040. This is forcing the insurance and banking industries to look into more investments in projects that are less vulnerable to storms, etc. and/or represent positive steps for climate change mitigation.

Finally, many investment houses are beginning to recognize that companies or projects with potential environmental issues represent a major investment repayment risk. Incidents like last year’s BP Deepwater Horizon resulted in reputational issues for the firm, as well as the billions of dollars spent to clean up natural areas and places where people live, work, and play. Companies now realize that the government and the public will expect nothing less than complete restoration of a site to its pre-accident condition, money not withstanding. While BP was flush with cash, most others would have had to declare bankruptcy and not pay back investors. Financial institutions are now including “what if” environmental risk in their calculation of whether to invest or not.

CCES can help your firm develop a viable and recognized sustainability program and can help determine whether projects have potential high climate change risk or not.

November 1, 2011
More and more corporate upper management understands the picture that in these tough financial times, going “green” or being more sustainable is not an idealistic statement of millionaires or old hippies, but is smart business and engineering management. While technology can help reduce one’s energy use, water use, and waste generation, etc., ultimately for such a program to sustain long-term benefits for the company, its employees have to cooperate and make it a part of their everyday lives to work with these technologies. How can companies get employees and other stake-holders to keep their interest up in a sustainability program in the long term? There is no one answer to this question, but here are 3 possible strategies to engender cooperation.
1. Keep it Simple. The biggest source of opposition to such a program even among people sympathetic to its goals for the company and the Earth is that it involves more work. People feel overwhelmed at work more and more, that they are doing more with less support. And, of course, there is more and more involvement in home duties, as well. A company begins a well-intentioned “green” program and workers think that there will be more things they have to do (and paperwork to fill out) as part of their duties. So make it easy. At least start up with items that involve no work at all, such as installing motion sensors to turn off their lights or easily programmable thermostats (through a Smart Phone) for individual comfort. Minimize paperwork to prove compliance.
2. Make It Fulfilling. People, in general, get excited at the start of a new, interesting program like a “green” or energy-saving program, but lose that fresh feel for it in time. How can one maintain enthusiasm for (and compliance with) such a program? A good way is to develop a regular internal “newsletter” of some type to chart the progress of your program. Let employees know just how the company is benefiting from the “green” program – how much lower the carbon footprint is, how much less waste has to be disposed, etc. And, most important, how much money the company has saved by these initiatives. Perhaps the company can put back some portion of the money saved and return it to the employees in terms of a party or in a gift (i.e., provide each a free CFL or a free energy saving tips) to take home. Another idea is to set up on an Intranet site a forum for employees to ask questions, receive answers, and share experiences.
3. Reward and Punishment. Professionals say it works for mice and for children, so why not for adults, too. Some companies have included individual behavior as a goal on employee’s annual review and will get increased bonuses and other benefits from meeting these goals. It is critical, of course, to be very clear on what the goals are to be met and give the employees full direction on how to achieve these goals.
CCES can help your company prepare a smart, sustainability program with maximum financial benefits and engenders cooperation from your employees and stakeholders.

October 25, 2011

The International Code Council (ICC) is in the process of rolling out final standards for Green Construction, called International Green Construction Codes (IgCC), in March 2012 (www.iccsafe.org/cs/IGCC). The IgCC is intended to be an enforceable code for municipalities to seamlessly adopt and enforce for future building construction. It is intended to reduce the negative impacts of the built environment on the natural environment for the purposes of reducing the costs of potential adverse effects on a municipality, such as flooding. The IgCC is not intended to be a rating system or replace LEED. Points will not be accumulated. It is meant as minimum requirements for future design and construction and to drive the industry toward more green construction. It is intended to be focused and enforceable by municipal Dept of Buildings officers.

The IgCC will contain a “model” code which municipalities can adopt or modify. There are also unique regional requirements. There will likely be two levels of standards, a “green” building standard and a higher “high performing” standard. IgCC contains ANSI/ASHRAE 189.1 as a compliance option. Minimum standards in IgCC include:

• Energy use conservation and efficiency (zEPI for large buildings, sub-metering)

• Water use conservation and efficiency (rain harvesting, plumbing, irrigation stds.)

• Indoor environmental quality (indoor air quality, HVAC stds., materials use)

• Materials and resource conservation (waste management planning, recycling)

• Site development and land use (protection of parklands, agriculture, floodplains)

• Operations & maintenance (building maintenance stds., building user education).

IgCC will contain separate standards for new and for refurbishing existing buildings. Commissioning will be required for most projects.

The ICC will present the draft standards at their annual conference in November in Phoenix for the public to make final comments. They are expecting to publish them final in March 2012. They plan on upgrading them every 4-5 years, but will do the first upgrade earlier, based on the early results of adoption of these standards in municipalities. Will this become the norm for all or many states or municipalities? This is hard to say, but diverse places, such as the States of Maryland, Rhode Island, and Oregon and Cities of Phoenix and Boynton Beach, FL have already passed resolutions stating it will adopt the IgCC standards as mandatory. Plus others are “on the fence” waiting for the final standards to be published to decide. Therefore, building owners and builders should prepare to understand and potentially comply with these standards.

CCES can help your facility prepare an analysis of the impacts of IgCC on your future buildings and strategize cost-effective options to comply with such codes in your area.

Oct. 17, 2011

More and more U.S. organizations see the financial advantages of setting and attempting to meet sustainability goals. However, many others are still waiting for the “right time” to start such a project. Some consider sustainability a risk, a venture into the unknown, which, of course, fosters avoidance. However, a solid body of U.S. and global companies has developed successful sustainability programs, setting and meeting strategic goals. Information about such programs are now posted in various registries, and, therefore, lessons can begin to be learned about how to overcome potential program barriers and what the most cost-effective successes were. This article summarizes a recent detailed survey of executives involved in sustainability programs.

A White Paper published by Tririga in July 2011 (http://www.tririga.com/information-center/whitepaper-view/sustainability-chasm-strategies/index.html) summarizes a survey of 130 executives from large companies and public service organizations, most of which have at least initiated a formal sustainability program. The survey found that the following activities were the focus of organizations that have achieved their sustainability goals:
• 91% improved facility energy efficiency
• 77% improved equipment and operations servicing and maintenance, and
• 75% improved space utilization (i.e. space optimization)

Energy savings, as discussed in earlier Environmental News for YouTM, is the most successful strategy given unit energy prices at record levels (cost per kwh electricity or per gallon of oil). Planned, site-specific energy audits followed by implementation of reasonable findings are virtually guaranteed to pay for themselves and more. Plus it’s an effective way of reducing greenhouse gas (GHG) emissions, the most common (but not the only) measurement for sustainability. 40-50% reductions in energy use (and the concurrent reduction in energy expenses) within 5 years of beginning the process was shown to be typical and fairly consistent across type (office building, retail, etc.) and U.S. region (arid vs. wet, cold vs. warm). Remember the power of energy savings from a business point of view. Saving energy expenditures is money “in the bank”, directly raising profits. The alternative way to raise profits, increasing sales or revenues, takes quite an investment (sales staff, ads, etc.), is not guaranteed, and can change from year to year. Energy savings stay consistent and grow (as unit costs grow) in the future.

As the numbers above show, many companies have found success and benefits from improved facility maintenance planning and implementation of improved processes. This includes preventative maintenance. A previous Tririga study determined that a well-maintained preventive maintenance program pays for itself and more resulting in a ROI of 545% compared to performing no preventive maintenance. Executives cited that such a program reduces: the number of expensive “emergency” repairs; the number of expensive capital purchases; and both energy consumption and maintenance labor staff needed. For some companies, part of this investment in improved facility maintenance is continuous commissioning. Although not required, many large, new processes and buildings undergo commissioning by a specialized firm to ensure that it has been built to spec and that the equipment and operations are functioning optimally and as designed. Deviations affecting performance sometimes happen during construction. There is also a segment of commissioning which focuses on maintenance of equipment and operations, including continuous commissioning and review after operation begins. The survey showed that those that implemented continuous commissioning had it pay for itself and more. Besides these direct savings, improved facility maintenance lowers risk and better ensures that production and other goals are more likely to be met, pleasing those in the C Suite.

The other area in the survey which many executives reported success in and benefits for implementing is space optimization. Space reduction offers an opportunity for organizations to reduce expenses, such as rent, energy, water and maintenance labor, as well as reducing environmental impact. Especially with downsizing, more facilities have an excess of space for its needs. Companies that implemented optimization strategies for space, such as combining functions, putting related operations and groups near each other, and encouragement of staff to work from home, all were shown to result in direct cost savings. This either frees up space for other, new functions and ventures or to no longer lease. Freeing up space also means not heating or lighting it, reducing energy, resources usage (and expenses) even compared to “green” space.

Get more useful information in our blog: www.CCESworld.com/blog
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This Environmental News for You is meant to provide background on sustainability programs performed by other organizations. CCES experts can help you in the technical aspects of how you can benefit and how to get started with and see benefits from your sustainability program.

October 12, 2011

Virtually all states that have nonattainment areas for ozone have passed a rule called nitrogen oxide (NOx) Reasonably Achievable Control Technology (RACT). With many regions not in attainment for ozone approaching 4 decades, several states have or are considering toughening this rule to reduce NOx emissions, a precursor for ozone. In New York, the NOx RACT rule, found in 6NYCRR Part 227-2, was amended in 2010. All large combustion sources must meet these “reasonable” standards, defined as standards that are technologically achievable and not overly expensive.

The revised rule in New York (which may be adopted by other states) contains new NOx emission limits for different fuels for different-sized boilers, any boiler with a maximum heat input of 25 mmBtu/hr or greater. Any boiler below that level must undergo a formal annual tune-up. The revised NOx RACT rule contains more stringent NOx emission limits, which will go into effect on July 1, 2014, for combustion of coal and of No. 6 fuel oil are particularly stringent. A number of boiler and burner vendors have told me that their equipment simply cannot meet the new limits. This is particularly telling as equipment vendors are usually optimistic that their units can meet stringent standards. If they admit their equipment cannot, then it really is believable that the limits cannot be met. Therefore, New York State may be using NOx RACT as a means of virtually eliminating the use of coal and No. 6 fuel oil altogether in the state.

What is a facility to do? First, one must recognize that this rule must be addressed promptly. Even a deadline date several years down the road gives little time to waste because of the time necessary to strategize, design, and order new equipment. In New York, the time is now. If a facility operates boilers combusting coal and/or No. 6 oil, it needs to review any old stack tests to determine how the units have performed in the past. It is likely that emissions measured would not meet the future limits. Simply saying that you will “clean the tubes” or otherwise tune-up your units will probably not achieve compliance. And as you saw above, even installing more modern burners will likely not achieve compliance either. So what are your choices? De-rating boilers such that they would be exempt from emission limits could work – if this gives you the proper operating flexibility. Proof of de-rating by some type of physical fuel flow restriction, such as a plate or nozzle, may be necessary. Another possibility is fuel switching to a different fuel and burner upgrades to attain the emission standard. Fuel switching will also cause decreases in emissions of other pollutants and CO2, a greenhouse gas.

CCES can help your facility in any state assess the NOx emissions of your boilers and strategize cost-effective options to lower them to comply with future regulations.

October 3, 2011

Sustainability is all the rage as many significantly-sized companies are evaluating it and seeing how it can fit into company plans and maximize economic benefits. We in the environmental community believe that sustainability programs almost always deliver a good return on investment (ROI) because of the economic benefits of reducing waste, water, energy use, etc. However, some C-Suite executives claim that sustainability projects do not have an acceptable ROI. Why the disconnect over the same numbers? How can the CFO’s ROI calculations be more severe than those of the EH&S Director?

Remember that ROI is a ratio of returns of a project over its total invested cost. An ROI may not appear good because the project’s total cost is made early, while the benefits, the time it takes to recover the money before the return is made, may be years in the future. Some companies’ ROI calculations take timing (such as different worths of current and future money) more strongly into consideration. This can be countered by emphasizing the long-term gains that will continue well into the future, once the effort or technology is in place, it will not be pulled out and savings will continue. In fact, in the energy and water realms, savings should increase as unit costs are expected to rise sharply for these commodities in the farer future.

Another disconnect is that sustainable projects produce indirect monetary returns, such as fewer compliance fines, enhanced consumer feelings toward the company, improved employee health and productivity, and reduced employee turnover. How do these real factors get quantified in a traditional ROI calculation? In confronting a “cold” calculation from a CFO, these hard-to-estimate, but real benefits should be brought up.

Some companies take risk into consideration when calculating ROI. If the strategies and technologies necessary for a sustainability project are considered unproven, then this may be factored into the calculations negatively. You can point out that sustainability is really “smart” projects and usage of resources which at various times have been scarce and expensive. Let the C-Suiters know that the company has likely already done many “smart” projects in the past to optimize resource usage. This is nothing new.

The same thing goes with the benefits of a sustainability program. Sustainability projects that reduce business risk (i.e., improve access to diversified sources of energy and water, reduce impacts of climate change-related actions, such as severe storms, etc.) should be recognized and credited for raising the potential ROI.

CCES experts can help your company develop smart strategies for a sustainability program and for projects that maximize your company’s financial benefits and acceptance.

September 26, 2011

The Greenhouse Gas (GHG) Reporting Rule (GHGRR), found in 40 CFR Part 98, has a major deadline in front of us. The first reports of GHG emissions for 2010 are required to be submitted to the USEPA electronically by this Friday, Sept. 30. The USEPA set up an electronic data submission system called e-GRRT, which stumbled upon its unveiling, but was finally up and operating last month. So the Sept. 30 deadline for 2010 data is still in force for those industries affected by Part 98 in 2009. The submission deadline is expected to return to April 30 in 2012 and beyond for the prior calendar year.

The GHGRR has gone through a number of amendments just in the last couple of months. For example, GHG emission calculation methodologies underwent technical changes for natural gas and petroleum processes (Subpart W) and for semi-conductor manufacturing facilities (Subpart I). The GHGRR allows usage of alternative methods to collect data and calculate GHG emissions, the Best Available Monitoring Methods (BAMM). The USEPA extended the timeframe that affected facilities in several industries to use BAMM without receiving prior permission from the USEPA.

One of the controversial portions of this rule is the treatment of data in terms of confidential business data. The USEPA wishes a balance between receiving plant data that can substantiate the calculation of accurate GHG emissions with the desire to not reveal publicly confidential business secrets. In April of this year, the USEPA tentatively ruled on the issue, stating that all input data would be held by the Agency in confidence at least until 2013. Final confidentiality policy is found in this USEPA memorandum: http://www.epa.gov/climatechange/emissions/downloads11/documents/CBI-final-data-category.pdf.

Well, if you are a facility that must submit your first GHG emissions report to the USEPA this week, there is little more you can do at this time. You certainly deserve hearty congratulations and a respite from the pressure you have been under to ensure the data can even be submitted to e-GRRT I know; I’ve been there. But at some point, it’s critical to evaluate where you stand and see how you can improve your system to serve you and your company in the future. Emphasis on system. Hopefully, you have developed a systematic approach to data gathering so that you gather the right data, reliably and accurately from people who understand the process and the need. Hopefully, your system is also reliable in terms of compiling the potentially large quantities of diverse data and can properly store data properly, and calculate GHG emissions per the rule requirements, and integrate not only with e-GRRT, but with your other environmental and even business software. If your system cannot do all of that yet, then it certainly can be optimized and that is a worthy and cost-saving effort for you to work on before the next year’s data is due on April 30, 2012.

CCES has helped others and can help you develop a robust Part 98 data system.