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.

May 24, 2011

Last month, the USEPA issued its periodic update report on where the US stands in terms of our overall greenhouse gas (GHG) emissions inventory, and trends since statistics began to be kept in 1990. It is important to step back and see where our GHG emissions derive and trends in recent years to be able to determine best steps forward.

http://www.epa.gov/climatechange/emissions/usinventoryreport.html.

This covers GHG emissions through 2009.

Total U.S. GHG emissions in 2009 were 5,618 million metric tons (mmMT) of CO2e. In the baseline year of 1990, US emissions were 5,328 mmMT, topped off at 6,203 mmMT in 2007. The decline since 2007 is mainly recession related. Still, this represents a 5.5% rise above baseline. The scientific community is looking for a 70-80% decrease in GHG emissions from baseline by 2050 to avoid the worst physical impacts of climate change.

Where do our GHG emissions derive? The largest segment is fossil fuel combustion (5,209 mmMt in 2009). 41% of this total comes from electricity production. While CO2-free, renewable sources and natural gas combustion have grown in the last decade, coal-fired electricity generation has grown only slightly in that time. Coal still accounts for over half our electricity generation nationwide. Therefore, growth in CO2 emissions from electricity generation is due mainly to increased demand of a growing population for more gadgets. As for CO2 emissions from fossil fuel sources, the largest segment is transportation, 33% of the total, nearly all of it gasoline and diesel fuel combustion. Transportation emissions rose about 16% since 1990, due mainly to more vehicle miles driven and no improvement in overall vehicles’ miles per gallon. The next largest segment of is from industrial sources, about 26% of the total. But this represents a 12% decline from 2008 and a greater decline since 1990, mainly because of the recession, the decline in manufacturing in the U.S., and efficiency improvements. Finally, the residential and commercial sectors came in at 22% and 19% of the total, with the vast majority being electricity usage. This represents a 25% rise in total emissions since 1990, due to increased demand for appliances, air conditioning, lighting, etc.

While the focus of many climate change studies is CO2 emissions, one must not forget emissions of other GHGs, such as methane (CH4). Remember that CH4 is 21 times more potent than CO2 as a GHG. The inventory details that the largest source of CH4 emissions is natural gas systems (CH4 leaks). Methane emissions in this sector rose by about 17% since 1990 and 4% from last year alone, probably because of the increase in production (number of wells). CH4 emissions from landfilling, the 3rd largest source, decreased by 20% since 1990, mainly due to greater efforts to capture and use CH4. Finally, CH4 emissions from manure management, while relatively small, has increased by 55% since 1990, mainly due to the proliferation of larger farms which tend to use liquid systems to manage manure, which causes greater CH4 emissions.

April 26, 2011

Earlier this year the World Resources Institute and other organizations issued a report providing ways for the federal government to implement a cap and trade program to reduce greenhouse gas (GHG) emissions independent of Congress, through Section 111 of the Clean Air Act (§111), New Source Performance Standards. This report states that cap and trade regulations are legally-defensible and allow states to implement carbon reductions in a more efficient manner than standard USEPA rules.

While the Clean Air Act generally focuses on geographical areas and maintaining attainment with the National Ambient Air Quality Standards (NAAQS), §111 grants the USEPA the authority to regulate emissions by the type of source, rather than the location or attainment status of pollutants. §111 applies to any compound that has been determined to endanger public health and welfare, but for whom no NAAQS has been issued; a situation that pertains to GHGs. The section provides the states the right to be flexible in how they design these rules, whether they be traditional “command and control” limits or more flexible mechanisms.

Parts of the U.S., of course, are already on the path to cap and trade to reduce GHG emissions, namely RGGI in the Northeast and AB-32 in California. Can these be models to apply §111?

The Tailoring Rule currently tailors PSD and Title V Permitting to GHG emissions. The USEPA may extend this to NSPS by issuing draft performance standards for GHG and other emissions for new and modified power plants and for refineries later this year. At the same time, the USEPA may mandate states develop plans for existing facilities. Final performance standards for these industrial categories under §111 are expected in 2012. With the purported success of RGGI in the Northeast (reduced GHG emissions and revenue for the money-tight affected states), cap and trade may be considered a viable option, although in some areas it may be politically untenable. Many believe that §111 would allow the USEPA to permit states to implement such programs.

Although politics and court challenges are a reality, look at more states to take a more serious evaluation of cap and trade for GHG reductions in the future.
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CCES technical experts can help your facilities prepare for the Tailoring Rule and how they currently impact future facility expansions and your Title V Permit.

Environmental News for You(TM) February 2011

The USEPA has begun to apply Clean Air Act (CAA) regulations to greenhouse gases (GHGs), as of Jan. 1, 2011. The USEPA was forced to as the CAA requires the agency to develop and enforce rules for any compound designated a pollutant, and GHGs were so stated. But how does one apply rules designed for a pollutant that has a toxicity and distinct local ambient concentration to those that have little localized effects and is not toxic? Last year, the USEPA published draft rules called The Tailoring Rule to tailor the CAA to GHGs. While there will likely be litigation against the implementation of the rule, no stay has been put on the rule. Here is a summary based on recent USEPA outreach and a document published by the USEPA on Nov. 11, 2010, and available on their website.

The USEPA is applying two established rules, Prevention of Significant Deterioration or PSD (40 CFR Part 52.21) and Title V Operating Permits (40 CFR Part 70), to GHG emissions. PSD is a pre-construction permitting program for major new projects or modifications applicable to emissions of compounds in regions that are already in attainment with their National Ambient Air Quality Standards (NAAQS). Title V is an operating permit required for “major” sources (facilities).

For PSD, the 1st phase of implementation, between Jan. 1 and June 30, 2011, affects active PSD permit applications (PSD permits applied for during that time or those initially applied for earlier, but not yet issued final). PSD applies to GHG emissions of a source only if it is subject to PSD “anyway” because of another PSD-regulated compound and if GHG emissions, measured in CO2 equivalents (CO2e), exceeds 75,000 metric tons/yr (mtpy) and any mass emissions. The USEPA has actually defined an “anyway” facility. After June 30, 2011, “anyway” and other sources that have GHG emissions ≥100,000 mtpy and propose to increase it by ≥75,000 mtpy and new sources with a proposed modification to increase GHG emissions by ≥100,000 mtpy are subject to PSD for GHGs.

Once a proposed project is in the PSD program for GHGs, how would it be regulated? Traditionally, a subject facility must install Best Available Control Technology (BACT) to minimize emissions and perform dispersion modeling to estimate off-site ground level concentrations (impacts). As for the latter, no dispersion modeling or estimate of impacts is necessary for GHGs in general or CO2 in particular. It is understood that even for a facility combusting large amounts of fossil fuels, the concentration of CO2 downwind will not change. However, BACT will still be applicable and a Top-Down approach preferred. Usually a BACT Analysis assesses different control equipment to reduce emissions. Controls for CO2, such as carbon capture & sequestration (CCS), although experimental, needs to be at least listed (although likely would be not technically feasible). Instead, BACT would consider strategies to improve energy efficiency, reducing the quantity of fuels combusted forming CO2. Proposed design and O&M activities are fair game to be reviewed by the USEPA as BACT to determine if they can be improved. The USEPA will allow energy efficiency to be assessed by reduced normalized GHG emissions (say, lbs CO2e / MW) even if the proposed project causes an increase in total emissions. The applicant may follow the PSD strategy of eliminating from BACT a strategy if it causes emissions of other regulated compounds to rise. The USEPA stated that it will not require a facility to operate a brand new boiler or furnace to replace a “poor” one to meet BACT.

As for Title V Permits, the timeline is similar to PSD. During the initial Jan. 1 to June 30, 2011 period, GHGs need to be addressed only for sources getting new or renewed Permits during this period anyway (“anyway” sources) if CO2e emissions ≥100,000 mtpy. No reduction is required. After June 30, 2011, all existing and new Title V Permit sources must address GHG emissions if CO2 equivalent emissions ≥100,000 mtpy. For those affected this would represent a modification of an existing Title V Permit. The modification must pertain to that state’s rules on the matter. For many, the Title V Permit would not need to be modified to include the GHG emission rate until it comes up for its next renewal.

How to Address These New Rules

Here are some potential strategies to prepare for CAA-GHG regulations affecting your facilities:

• Keep up with The Tailoring Rule. The USEPA is beginning outreach to explain its interpretations of the Tailoring Rule, starting with state agencies. Attend a session if open to the public or meet with your local agency if it will enforce it. Keep track of court proceedings.

• Know the status of your Air Permits and expansion plans. Which of your facilities will expand in the future and may be subject to PSD? Which may be modifying or renewing their Title V Permits? Be proactive. As an example, I am working with a facility renewing its Title V Permit. While the process was begun in 2010, the renewal was just issued last week, and as an “anyway” source could be considered subject if CO2e emissions exceed the threshold. To be proactive, I calculated worst case CO2e emissions from all combustion sources, showed that it was below the threshold, and transmitted this to the agency. I did not want this to hold up issuance of the Title V Permit renewal; by doing this, I removed a potential barrier. Now is the time to study impacts of these new rules on your facilities and planned modifications.

• Determine GHG emissions. Take time to determine worst case CO2e emissions of your sources and see whether any may be near an applicability threshold that will affect it in the future. Perhaps there are strategies to consider implementing now to improve energy efficiency to further reduce the risk of exceeding the threshold should there be change or growth later.

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 Tailoring Rule. Be sure to obtain professional, source-specific technical and legal advice before implementing a strategy. CCES experts have the experience to assist you in the strategic and technical tasks necessary to address the Tailoring Rule.

January 25, 2011

Last week in my blog, I discussed the growing issue of energy risk. It is almost a certainty that we will have future energy price volatility and overall cost increases, as we see this winter with gasoline prices and news reports of more accidents (i.e., Deepwater Horizon) and potential impacts on the environment of obtaining fuels (i.e., Marcellus Shales). Last week’s blog discussed the issue of what happens if energy is unavailable or at a great cost. Nothing is more important for a company than reliability in making a product and getting it to market. Keeping funds or credit in reserve to address lack of reliability or cost volatility is a costly endeavor. Companies highly dependent on energy (i.e., airlines, steel) already understand, quantify, and implement energy risk strategies. But other companies, less dependent on energy, will need to do the same in the future.

Besides following the energy market and hedging one’s bets with long-term contracts, there are ways to design and plan your plants and operations to lessen your energy dependency and have greater energy diversification to lessen risk.

The first approach is to lessen your overall energy dependence. Improving your energy efficiency means less energy needed to pay for, to store, to use, saving you money (and reducing your carbon footprint). Initially, your total corporate BTU energy demand will decrease. If total BTU eventually rises in the future, it is only because your company is making and selling more “widgets”, allowing increased revenue to pay for the energy increase. Thus, upgrading process equipment, reducing losses, and following green building principles will not only lessen your energy costs, but reduce energy risk, too.

A second approach is energy diversification. Your company needs to take a look at your fuel sources and attempt to increase your flexibility. A boiler that can burn several different fuels can save your company money by allowing you to purchase the fuel that becomes less expensive. Often a relatively inexpensive upgrade, such as a new burner and onsite storage equipment, can allow such diversification.

An example is a project I worked on several years ago for a company looking to build two new industrial plants in Thailand. Both needed to produce a steady and large quantity of steam for their manufacturing process. I was on a team evaluating a number of potential fuel sources to eventually design the boilers. Which fuels were both highly available in Thailand and likely to be most plentiful in the foreseeable future and, therefore, have the least potential future volatility? Reviewing publicly-available models and other documents, we determined that coal, fuel oil and wood waste (biofuel) were most available and stable. However, a concern for coal was the potential future need to procure large amounts of carbon credits, resulting in some monetary risk of future coal dependence. The boilers were ultimately designed to be able to combust all three fuels.

CCES experts can help your company lessen your energy dependence, saving you money, lessening your risk, and reducing your carbon footprint. Contact me at Karell@CCESworld.com or at 914-584-6720 for more information.

Dec. 28, 2010

2011 is coming and many people have made their new year’s resolutions and wish lists. My wish for 2011 (besides a healthy, happy, and prosperous New Year for all) is simple. I would like to return to a time in the U.S. when things were done at a high quality level. It seems like in the last couple of decades, quality is less important and showing you have done something is everything. I think the culprit is the checklist. Everything seems to be organized in checklists, including many office functions and everyone seems to have “To Do” lists. Hey, I use checklists, too. It is a great way to organize, make sure you have completed what you said you would do, and to know what needs to be done. Of course, we check off items as we complete them. But have we – as a society – become so stuck on checklists that all we care about is just checking items off? Of completing items even if the accuracy of what was done may not be so great? We only care that we did the task and can show it? I think this has become a bigger problem in our society and I see it both in my personal and professional lives, both in terms of serving clients and company expectations for themselves and their projects.

I have thought about this problem a lot, but it really hit home a couple of months ago when reading a major news story, the home foreclosure scandal. Remember, how banks rushed to prepare many foreclosure documents to formally take over and re-sell properties whose owners could not pay their mortgages to show shareholders progress? They prepared these documents hastily and made numerous errors. They included incorrect facts in many documents, including the wrong owner name, wrong addresses, etc. When reviewed by the authorities, these errors came out and stays were put on many foreclosures. In some cases, foreclosures happened – of the wrong properties! Wrong premises were entered of properties that were fully owned quite legally by others and banks forced their way into people’s bedrooms!! Upon further review, it came out that many of these banks – to save money – did not use attorneys to prepare or review these foreclosure documents, as was the norm, but hired clerks who were not qualified to prepare these documents and did not know how to prevent potential errors. Again, checklists! Forget the accuracy and the quality, but just get the foreclosure documents prepared and out the door and check off the list that it is done!

2011 promises to be a big year, environmentally. New regulations such as the federal Mandatory GHG Reporting Rule are fully in fruition now, with the first reports due on March 31. The Tailoring Rule goes into effect on January 1, changing the way PSD and Title V will be implemented at many applicable facilities. Let’s hope that all of us in the environmental fraternity do not treat these and other obligations merely as items to check off a list, but prepare the reports and applications – not just the forms, but the underlying data and science – in a professional, high quality manner that serves our companies and clients well, is meaningful, and that we can be proud of. Let’s not just do it, as Nike would say, but let’s do it thoroughly, accurately, and right!

Once again, CCES wishes you and your families a happy, healthy, prosperous 2011!