April 24, 2012

The USEPA recently released its 17th annual U.S. GHG emissions inventory, The Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2010 (http://epa.gov/climatechange/emissions/usinventoryreport.html). The report shows overall GHG emissions in 2010 increased by 213 million metric tons or 3.2% from the previous year, despite a recession. About 77% of all GHG emissions derive from fossil fuel combustion. From an industry sector, about 34% of total net GHG emissions (taking GHG emission sinks into consideration) derive from electricity generation, about 27% of the net total from transportation, and about 20% of the net total from industrial. Energy demand reportedly rose in 2010 due to growth attempts by companies and increased electricity demand for air conditioning due to a relatively warm summer in 2010.

Total emissions of the six main GHGs in 2010 were equivalent to 6,822 million metric tons of carbon dioxide equivalents, representing an increase by over 10% from 1990. In the Kyoto Protocol (not enforced because it was never approved by the US Senate), the US was supposed to reduce GHG emissions by 7% from the 1990 baseline by 2012. Although the Kyoto Protocol does not apply to the US, as a member of the UN, it must report net GHG emissions to the UN Framework Convention on Climate Change.

Other significant contributors to the inventory included methane emissions from natural gas systems, fermentation, and landfills; N2O emissions from agricultural practices; and SF6 emissions from electrical transmission. Remember that these GHGs have Global Warming Potentials significantly greater than CO2’s. The inventory also tracks “sinks” that remove CO2 emissions from the atmosphere. In fact, the amount of CO2 estimated to have been removed from the atmosphere by renewed forests rose by under 2% in 2010 compared to 2009. The success of cropland in the US as a sink declined in 2010.

The USEPA will undoubtedly use this information to develop future policy and focus attention on those segments most responsible for GHG emissions when developing new rules.

The Executive Summary of the GHG emissions inventory: http://epa.gov/climatechange/emissions/downloads12/US-GHG-Inventory-2012-ES.pdf

CCES and our technical experts can help you develop a real, successful GHG emission reduction program for your company, building or institution. Most such strategies have economic benefits and have a healthy return on investment. Call CCES now for help.

On March 27, 2012, the USEPA announced a new draft rule regulating GHG emissions from new electric utility generating units (EGUs) under New Source Performance Standards (NSPS), Section 111 of the Clean Air Act. This is a first, as previous new rules regulating GHG emissions have been issued under the New Source Review and Title V Permitting programs. This proposed rule indicates that the USEPA will be strongly targeting power plants, particularly given data from the initial reports of GHG emissions under the Mandatory GHG Reporting Rule which shows that EGUs are the largest category of GHG emitters nationally. However, this may certainly be an indication of the USEPA’s approach across all segments. The proposed NSPS rule was just published in the Federal Register on April 13, 2012.

The Proposed Emission Standard

The NSPS’s proposed emission standard for new EGUs with a capacity of at least 25 megawatts (MWe) is 1,000 pounds of CO2 per megawatt-hour (lb/MWh). This standard is based on measured performance of natural gas combined cycle (NGCC) plants, which the USEPA finds to be the system that yields the least GHG emissions. This technology-based standard contains a rigid emission limit for such GHGs from new proposed EGUs, typical of command and control. There is no alternative to meeting this standard, such as procuring credits under a cap and trade system.

While the proposed rule does not ban the use of any other particular fuel, the USEPA clearly shows it favors natural gas, as its analysis shows that it is “cleaner”, highly available, and relatively cheaper in price. NGCC, the USEPA feels, will be the standard design for new EGUs for the next decade or two for economic reasons, such as it is a less expensive technology to install and the fuel’s wide availability.

High Level of Flexibility

However, this proposed rule certainly contains a wide amount of flexibility, given its rigid emission limits. A new EGU that burns coal can meet this standard and operate, but only if it successfully installs carbon capture and sequestration (CCS) and implements it to capture at least half of the CO2 in the exhaust. While CCS is currently under development (there is no successful CCS installation on an operating coal-fired EGU), the rule would still allow a new coal-fired EGU to be built, as long as the applicant promises to operate CCS in the future. How can that be given that the 1,000 lb/MWh standard cannot be met by CCS currently? Because the rule allows an operator to meet the emission standard over a 30-year averaging period. An operator can operate a new coal-fired plant without CCS and install it later. CCS must be planned in the initial pre-construction permit application. The 1,000 lb/MWh may be successfully met over a 30-year period of operation. For example, a coal-fired EGU without CCS can meet a GHG emission standard of 1,800 lb/MWh for the first 10 years, followed by meeting a 600 lb/MWh standard the remaining 20 years with CCS to meet the overall 30-year average limit of 1,000 lb/MWh. The USEPA is doing this to keep options open for the coal industry. There is no apparent discussion of contingencies in case the future development of CCS technology does not succeed in meeting, say, a 600 lb/MWh level in the long-term future.

The proposed NSPS standard does not apply to simple cycle gas plants (typically, “peakers” used only during periods of high electrical demand) or EGUs that burn biomass or co-fire with a fossil fuel. The proposed standard also does not apply to future modifications or major modifications of existing EGUs, even of coal-fired units. This may result in power companies modifying and expanding their existing units as much as possible and not investing in building new plants, even if electricity demand continues to rise.

The USEPA is also allowing additional flexibility in this proposed rule by providing a one year extension of the effective date. Normally, a new NSPS rule would go into effect for all proposed new plants with NSR pre-construction permits issued and construction commenced by the April 13, 2012 date of publication in the Federal Register. Instead, the rule will go into effect 12 months after that date, April 13, 2013. In other words, a new coal-fired EGU with an approved pre-construction permit that has begun construction before April 13, 2013 would not be subject to the new NSPS standard.

Next Steps

With publication in the Federal Register the “clock” for the proposed rule has started. The proposed rule is now open for public comment until June 12, 2012. The USEPA may modify the draft rule as it sees fit based on public comments. The USEPA’s goal is to finalize the rule within one year. However, there is a significant chance of lawsuits by any of a large array of interests against the rule that may slow implementation or even completely block the rule from being implemented.

There is one addition impact of the proposed rule if it becomes finalized as is. With an NSPS standard in place, the 1,000 lb/MWh emission limit becomes the “floor” for any future “Best Available Control Technology” (BACT) analysis for PSD permitting for GHG emissions of a EGU under the Tailoring Rule. Because the NSPS standard only applies to new, and not modified, EGUs, would this also become the BACT floor for existing EGUs undergoing a proposed major modification? Could an EGU undergoing a major modification not be required to meet this standard? This is not clear.

CCES technical experts can help you prepare for this and any other Tailoring Rule that may be applicable, whether future NSPS rule, New Source Review, BACT Analysis, or Title V Permitting. We have and will continue to provide useful, expert technical advice.

Climate Change & Environmental Services (CCES) announces their involvement in the successful conversion of the boilers at East River Housing (ERH), a 2,600-unit apartment complex located in lower Manhattan from burning heavy No. 6 fuel oil to burning cleaner and significantly less expensive natural gas. CCES served as the chief environmental engineer and the construction manager for the project.
ERH completed the conversion of its first boiler to natural gas in late February 2012. During its first full-month of operation, ERH determined that two-thirds or 215,000 fewer gallons No. 6 oil was burned in March of this year as compared to March 2011. While a milder winter accounted for roughly 20 percent of this reduction, the switch to natural gas resulted in an estimated savings of about $400,000 in energy expenses in just one month. New York City is currently requiring buildings to discontinue the use of heavy No. 6 fuel oil. Natural gas is lighter, cleaner, and currently significantly less expensive than heating oils. Many property owners have experienced significant cost savings of 20 percent or more. As part of New York City’s Clean Heat campaign, the City is making it easier for building owners to make the switch.
CCES is proud of its role in helping ERH reduce its energy expenses while at the same time significantly reducing their carbon footprint and emissions of toxic air pollutants in New York City.
About Climate Change & Environmental Services
Established in 2009, Climate Change & Environmental Services, LLC (CCES) is an environmental consulting firm that specializes in servicing the environmental needs of companies, municipalities, and industrial facilities. CCES provides an array of climate-related services including air quality engineering, environmental and sustainability consulting, energy management and green building conversions among others. CCES is dedicated to providing exceptional service that will maximize efficiency and both financial and environmental benefits for our clients. CCES principal Marc Karell has over 25 years of experience in these areas and has successfully consulted with major firms including IBM, ExxonMobil, Alberto-Culver, Abbott Laboratories, the United Nations and Koppers. For more information, visit www.ccesworld or call 914-584-6720.

Over the last few months the USEPA has begun implementing rules to reduce GHG emissions. Not the traditional way by having affected facilities measure and reduce GHG emissions, but by encouraging operational changes to accomplish the same goal. Two rulings that can affect businesses are as follows:

1. Alternative refrigerants. This past December the USEPA announced approval of three alternative refrigerants to replace hydrofluorocarbons (HFCs) in commercial and household freezers which had previously been encouraged because of their negligible effects on stratospheric ozone. HFCs are potent GHGs with global warming potentials in the range of 93 to 12,100 (CO2’s GWP: 1). The use of propane, isobutane, and R-441A (a hydrocarbon blend known as HCR188C) are now suitable replacements for chlorofluorocarbon CFC-12 and hydrochlorofluorocarbon HCFC-22 in household refrigerators, freezers, combination units, and commercial stand-alone units.

See: http://yosemite.epa.gov/opa/admpress.nsf/0/eed8a9f289e19d3f85257966005dbf51?OpenDocument

According to the USEPA, such replacement of refrigerants will reduce GHG emissions by about 600,000 metric tons by 2020.

2. Heavy-duty engines and vehicles. Late last year, the USEPA also announced new GHG emission standards for heavy-duty engines and vehicles, necessary due to a US Supreme Court ruling that required the USEPA to regulate GHG emissions from mobile sources. These standards apply to trucks, buses, heavy-duty pickups and vans, concrete mixers, ambulances, and similar heavy vehicles. Certain small business trucks and typical passenger vehicles are exempt.

As summarized in 40 CFR Part 1037, beginning with model year 2014, heavy duty vehicles must meet fleet average GHG emission standards for CO2, N2O, and CH4, generally in g/mile. Standards will be more stringent in future years. They differ whether the model is spark- or compression-ignition. HFCs, common refrigerant in such vehicles, are regulated by leak rate. Leakage cannot exceed 1.50% per year. The burden of compliance is on the vehicle manufacturer, who must obtain proper certification. The business or vehicle consumer or user is not obligated to report or perform any testing.

Contact CCES to assess your current GHG emissions from all sources. We can recommend technical solutions that pay for themselves in savings.

The USEPA posted on Feb. 24, 2012 minor changes to the Tailoring Rule, tailoring Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs to GHG emissions. The USEPA essentially announced that they would not change many of the parameters in the original draft rule, such as applicability thresholds and gradual scheduling. The USEPA believes that the current approach is working well, and that state permitting authorities are successfully managing PSD and Title V Permit requests. The USEPA did propose steps to streamline the permitting process for facilities covered by the programs, and not to include additional sources in the permitting programs at this time.

The USEPA proposes to follow the same Clean Air Act processes that it has followed for decades. As of Dec. 1, 2011, the USEPA and state permitting authorities have issued 18 PSD permits addressing GHG emissions, covering both new and modified existing facilities. The process addresses six GHGs: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Best Available Control Technology (BACT) has been ruled to be (so far) the implementation of energy efficiency measures to reduce CO2 emissions.

The current PSD approach would be maintained. A new facility with GHG emissions of at least 100,000 tons per year (tpy) expressed as CO2 equivalents (CO2e) or an existing facility emitting at least 100,000 tpy of CO2e and proposing to increase GHG emissions by at least 75,000 tpy CO2e triggers the requirement for a PSD permit. A facility that must obtain a PSD permit because of other regulated pollutants must also address GHG emissions if it proposes to increase emissions by at least 75,000 tpy of CO2e. One change that it is proposing is to develop a “synthetic minor” PSD permit, a relatively simple permit, giving a facility an emission limit above which PSD would be triggered.

The USEPA is keeping the existing Title V Permit thresholds for GHGs. Sources with potential GHG emissions above 100,000 tpy CO2e must obtain a Title V Permit. The agency is proposing one change, allowing a Plantwide Applicability Limit (PAL) for GHGs. This allows facilities to change GHG emissions between sources without having to modify the Title V Permit as long as PAL is met, giving greater operating flexibility.

The proposed changes by the USEPA may be found at:  http://www.epa.gov/NSR/actions.html.  The USEPA will accept comments on this proposal for 45 days after it is published in the Federal Register.

CCES technical experts can help you determine your permitting and PSD needs and help calculate emissions of GHGs and other applicable compounds, and provide cost-effective compliance strategies for you.

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.

Let’s face it: it’s tough to sell a corporate “green” program in-house. You know of the many financial advantages for your company if it develops a robust program. But most companies – especially in these tough times – are conservative and don’t want to spend money on a program with even the slightest risk of not meeting goals. The manager recommending the program may put his/her job on the line should that small chance of something going wrong occurs (even if it’s not his/her fault). The status quo is tempting. Here are some ideas on how to frame a program to get senior management buy-in.

It’s all in a name. It’s not fair, but the phrase “green” has lost its cache, perhaps because of the public debate about climate change. Companies are worried about image. Here’s a suggestion. Implementing energy efficiency, et al. is smart operations. Call it the company’s “Smart” program. You would think everyone would favor that!

Keep it simple (and be smart). Don’t try to change the whole company in one year. Just have modest goals. Repeat them and the solutions often, but keep it simple. And monitor and show off the success. Just concentrate on one or two items only (reduce electricity, fuel, or water), and even then only one small portion of the item (lighting, fleet). Senior management has so much on their plate. They will want to know the progress on the program, but feed it to them gradually and simply.

Make it meaningful, fulfilling, but to the point. Some people are still idealistic and will feel a closeness and loyalty to a company that institutes a “Smart” or “Green” program. Don’t just give the facts about Kwh and boiler upgrades, but frame it in terms people can identify with, such as cars taken off the road, trees planted, and, of course, GHG emissions reduced and money saved (yes, always the bottom line). Getting the company certified “green” in some way, such as LEED certification of a new building, with the nice photo-op can improve the program’s image. And to strengthen your image with your employees, your company can give away an inexpensive gift, such as a compact fluorescent or sensor or arrange a webinar on home energy saving.

Tie the program to other successful ones. Associate your program with other initiatives to help forward it and assure longer-term acceptance. For example, state that the recent gains of the “green” program will reduce expenses so to enable your firm to expand its production or transportation network, etc. or to delve into new markets.

Give the boss what he/she wants. When it comes down to it, your job is to make your bosses and their bosses happy. What’s in it for your bosses? Saving money? A photo opportunity? Keeping up with your competitors? It’s important to know what makes these people tick and the deeper meaning of what they are looking for in the program.

CCES has helped others and can help you develop an organized, responsive, and goal-oriented “Smart” program.

July 2011

You are aware of the business arguments for establishing a sustainability or “green” program (see last month’s newsletter!) and are seriously considering or have begun such a program. It is therefore important to plan the proper metrics of your program in order to demonstrate success so that all stakeholders understand your benefits and achievements, be able to compare your program to others, and avoid any accusation of “greenwashing”. You need to feel sure about standards that certify your success. This article discusses the proper approach to successful metrics and several rating systems.

The first concern is your immediate goals. It is important to focus on one or two matters so you can show early progress. Given its high cost, energy and therefore greenhouse gas (GHG) emission reductions are most popular. Water conservation is critical in certain locations and also a good metric. Waste reduction or recycling is another. In any case, focus on developing a baseline that estimates accurately the parameter in question. One can normalize data using production parameters (tons GHG per square foot of space or per unit of product or per revenue) for better comparisons.

Whatever changes you implement for your program, be sure to correlate these to changes in the metric in question. So if you performed projects that have improved your energy efficiency, be sure to determine the energy parameter reduced (Kwh of electricity or gallons of fuel) and convert that using the proper published emission factor to tons of GHG emissions reduced. Of course, it’s also helpful to correlate this to money savings. Remember that stakeholders often care more about the summary metrics of GHG emissions reduced rather than the details of your energy efficiency strategies.

As your sustainability program grows and successes achieved, develop reports to show how successful your efforts have been and will be in the future. You should develop a written and online Sustainability reports to show progress, often in pie charts or graphs.

As your program matures, you may be asked or want to provide data to an ever growing number of sustainability indices to publicize your achievements There is a huge number of such sustainability rating systems. According to SustainAbility, there are over 100 rating systems, 80% of which started in the last decade. Some are part of mainstream organizations (i.e., Walmart’s Sustainability Index; Newsweek’s “Green Rankings”); others are its own specific entity (i.e., Carbon Disclosure Project (CDP); Climate Counts’s “Company Scorecard”). Some systems are specific to one area (i.e., carbon), while others treat sustainability as a broad issue. Sustainability ratings are being used by a growing number of investors, consumers, the press, etc. to judge companies.

Typically, these rating systems request specific information from target companies. For example, CDP sends an annual questionnaire to all S&P 500 firms. Other rating systems only review publicly-available documents about a company. Some do both. With a company potentially receiving dozens of such requests of different complexities each year, it is easy to not respond. An estimated 2/3 of indices rate non-respondent companies. How does a company choose which to cooperate with and which not?

It is important to research any rating system that may rate your company and you wish to provide information for. Here are 3 major criteria. First, does it have high credibility? Is it well read and respected? As discussed above, many well known organizations with large readerships provide sustainability ratings, such as Newsweek and Bloomberg. This guarantees name recognition and readership. Others, though less known, have strong sponsorship to ensure respect (i.e., CDP). Research into how many people read these indices and how often they are cited in reports can address this first criterion.

A second criterion is credibility. Are the ratings believable based on publicly-available documents which may lack true context? Or are ratings not posted for a company that does not supply data? For example, in the CDP, companies that do not return their questionnaire are not rated, but pointed out as a non-responder. Related to this is the thoroughness of the data sources. Is proper data reviewed before being evaluated? A credible rating system is thorough in its data evaluation.

A third criterion is transparency. Does the rating system publish in detail its evaluation methodology? This is critical to know how different companies are evaluated in terms of sustainability achievements and policy. A rating system without an overt methodology may change from year to year. Also, a transparent methodology saves you time in gathering and submitting data in a knowledgeable and professional manner.

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 ways to maximize your “green” benefits. CCES experts can help you develop the metrics of your sustainability program and a system for collecting data, saving you much time and better ensuring success. We can also assist you in addressing and preparing appropriate questionnaires for sustainability indices.

July 5, 2011

I hate to bring up this issue on Independence Weekend when we should celebrate the many great things about America. But we are falling behind the rest of the world in one area of great importance to us, and that is, clean energy and energy efficiency.

The U.S. has an estimated 120 million homes, but most of them can improve energy-wise. This is not only a great business opportunity, but with proper policy and incentives a great way to effectively reduce greenhouse gas (GHG) emissions without ominous regulations. Yet partisan politics has stopped progress. Much of Europe has already achieved massive home upgrading, thanks to incentives, supported by even right wing parties. Although few Europeans are climate skeptics, even they understand the added value of energy upgrades (reduction in costs, dependence on foreign oil, etc.).

In addition, many European and Asian governments encourage companies to develop new energy efficient, renewable power, and GHG reducing technologies thanks to direct investment, tax breaks, and regulations. And now they have a new market to continue growth: the U.S.! A recent report by the Pew Charitable Trusts found that the clean technology sector was stagnant here because of policy uncertainties in Congress, as the debate over climate change distracts it from setting policies and creating incentives.

Despite some positive measures in the U.S., there is still too much uncertainty, upfront costs, and risk to attract U.S. capital to invest in areas like “smart” technologies, energy-efficient appliances, insulation, or renewable energy, despite the need and large potential market. Not only is this an opportunity to grow a many billion dollar clean energy industry, but also to grow associated work areas, such as banks and legal.

So how should we encourage energy efficiency? There is a healthy debate. Some say we should mimic the European model above. Daniel Esty, the new Commissioner of the Connecticut Dept of Energy & Environmental Protection, recently stated that because government has a bad track record of picking winners, it should stay out of investing in new technologies (lest such picks also be dictated by politics and special interests) and only encourage or mandate demand from the public instead for successful technologies.

On this Independence Day holiday, as we celebrate so much that is good about the U.S., let’s take some time to work toward bettering ourselves. To work toward greater awareness of clean and efficient energy and push to make this country incentivize more basic research in renewable energy and energy efficiency and the public to implement such technologies for our betterment and to grow our economy and produce jobs.

CCES technical professionals can help your company perform an energy evaluation to determine cost-effective energy-saving strategies for your maximum benefit.

June 1, 2011

As you walk down your local supermarket aisle and you compare brands, you generally see only price, price per measure ($ per lb, per fluid ounce, etc.), and maybe calories. Well, several supermarkets and stores are beginning to experiment with labels to provide consumers with the product’s relative carbon emissions. Tesco, the major retailer in the UK, was the first to do so beginning in 2008. Aldi, a major budget retailer in Australia, just introduced their program late last year. Casino, a major supermarket chain in France, inserted a color-coded scheme on its products for carbon comparisons a few years ago. American mega-chains Walmart and Sam’s Club have begun to collect information from suppliers enabling them to develop the same information, although no timetable has been released. Does this work? How has the public reacted to this?

First, some background. This represents a carbon life cycle analysis, as the stores asked the question of what quantity of greenhouse gases (GHGs) are emitted during the life cycle of the product from formation until it reaches the store (from processing of raw materials, manufacturing, and transportation). Making purchasing decisions based on factors other than cost and perceived quality (such as environmental performance and carbon footprint) is believed to be of growing interest to certain consumers.

While standard procedures are used, some of the results have surprised the stores, their consumers, and scientists in the field. For example, at Aldi stores, olive oil imported from Europe has a similar carbon footprint to oil made from homegrown olives. While more energy is needed to ship olive oil to Australia, this is offset by the farming practices in Europe which liberate more GHGs. Studies have shown that food sector GHG emissions are more influenced by activities during farming than by transportation.

When will carbon labels be standard in supermarkets and other stores? Probably a long time. In 2008, when Tesco unveiled its first labels, it committed to label all 70,000 of its products, but without a timetable. In the intervening years, it has introduced about 125 labels per year. At that rate, it may take a century to label them all!

And how has carbon labeling been received by consumers? Initial surveys by the stores appear to indicate that confusion reigns. A survey performed of Tesco consumers in the early days of labeling indicate that only 28% of consumers understood that carbon labels pertained to GHGs and to climate change. For beverages, a large number of people believed that the data on the carbon label was another form of a calorie count!

This has also shaken up some companies. Several who have invested in marketing how “green” their brands are have seen that their actual carbon footprint exceeds that of some non-eco friendly branded competitor products. This has caused much anxiety and research into how to reduce GHG emissions throughout the product life cycle.

CCES can help you perform a carbon life cycle analysis using accepted methodology for you to see where you stand and in what areas energy and GHGs can be reduced.