November 2012

Environmental agencies must develop cost-effective enforcement programs to meet goals within tighter budgets. One idea is to provide incentives for facilities to self-audit, voluntarily report any violations, and self-correct to return to compliance. Since finding and correcting violations are how most agencies are judged, self audits are a good fit.

Federal Self-Audit Program

The USEPA has had a self-auditing policy for over 25 years. Some relevant publications may be found here: http://cfpub.epa.gov/compliance/resources/policies/incentives/auditing/. The main incentive that the USEPA offers to encourage self-auditing and reporting is penalty reduction. The USEPA fine policy takes two factors into consideration: gravity of the violation and the economic benefit of violating. The USEPA has stated that it can reduce the penalty’s gravity portion fully or by 75% if certain self-reporting conditions are met. The USEPA will not reduce the economic benefit portion. In addition, the USEPA will not normally recommend an entity for criminal prosecution if it self-reports.

According to USEPA policy, a facility has to make the discovery voluntarily (not because of a legally-mandated audit or monitoring) and report a violation within 21 days of its discovery in writing to the USEPA. A violation is discovered when any officer, director, employee or agent of the facility has an objectively reasonable basis for believing that a violation has, or may have occurred. “Objectively reasonable” is difficult to define as a facility can find a potential violation but then take time (by necessity) to examine it thoroughly through legal counsel to determine whether it is a true violation or not. The disclosure must be made to the facility’s appropriate USEPA Regional Office and should, at a minimum, identify the means of discovery and type of violation. Correction of the violation is expected to be made within 60 days of the discovery date, although an extension can be granted. A system to reasonably prevent recurrence must be developed. The USEPA Audit Policy does not cover repeat violations, those that could cause serious harm, nor violations of a judicial, administrative, or consent order.

On the State Level

Roughly 30 states have enacted environmental audit privilege and/or penalty immunity laws. New York State is in the process of updating its self-audit rule. The NYSDEC is expected to post its draft self-audit policy for public comment beginning later this month. A final policy is expected to be posted and implemented in the spring of 2013.

The draft New York State Audit Policy applies to any facility within the state subject to environmental rules. It will not apply to repeat offenders (even for different but similar violations elsewhere in a facility) nor to “uncooperative” entities. It will not apply to violations made during department inspections or those that may cause serious harm.

Disclosure must occur within 30 days of discovery, although, like in the USEPA policy, discovery is not well defined. The draft policy emphasizes communication and written agreement. The self-reporting entity is encouraged to meet with regulators in person to coordinate future steps. An Audit Agreement must be agreed to describing the violation, the steps to remediate it, and reduction in fines. The violation must be corrected within 60 days of disclosure; although that can be changed in the Audit Agreement.

The New York State draft policy gives the NYSDEC the right to waive the gravity portion of a fine. In addition, it can also reduce the economic benefit portion to a de minimis value and/or allow credit for pollution prevention costs that the entity will spend to prevent recurrence. The draft policy offers additional incentives, such as 50/50 cost sharing for energy upgrades, priority for Small Business Program and other assistance, and being placed as a “Low Priority” as a NYSDEC inspection candidate.

Wisconsin has a program called “Green Tier” which provides incentives to entities that voluntarily improve their environmental performance, irrespective of having a violation or not. The program has two tiers. Tier One participants are entitled to deferred civil enforcement as well as statutorily capped or stipulated fines for violations. The WIDNR promises not to seek penalties for those entities that self-disclose violations and take corrective action. Tier Two participants generally contract for a limited form of immunity from any civil action for self-disclosed violations.

What Should You Do?

The descriptions here demonstrate the many advantages for self-disclosing/correcting environmental violations. Environmental rules applicable to your facility are generally listed in your permits (Title V, etc.). Most environmental rules are science-based (i.e., measurements of certain parameters). Make time to make appropriate measurements to ensure that you are still in compliance with all applicable rules. If you find a violation (for example, excessive quantity of a waste or a composition of a paint), then measure it again and even a third time to make sure the measurements are correct. Even use a second lab, if necessary. Then discuss the potential violation with legal counsel to determine whether this is truly a violation of an applicable rule. Then work with Legal and management on how to approach the USEPA or your state agency to self-disclose the violation to take advantage of the incentives. Finally, take the time to review your monitoring systems that are supposed to indicate your compliance status. Are they functioning properly? Can they be upgraded if a more reliable technology is available?

This article is a technical overview of self-auditing policies. Be sure to consult your legal advisor before making decisions on how to approach these issues. CCES has the experts and experience to assist you in performing a 3rd party environmental audit to determine early on any potential violations for self-reporting. We can design and manage your compliance program and work with you to provide technical (not legal) advice when you deal with the regulatory agency to maximize your approval in the self-auditing rule. We can also help you design a new or upgrade an existing compliance monitoring system to enable you to determine compliance early in the future. Contact us for more information.

October 2012

The Federal Trade Commission issued the final version of its Guides for the Use of Environmental Marketing Claims (http://www.ftc.gov/bcp/grnrule/guides980427.htm) (http://business.ftc.gov/advertising-and-marketing/environmental-marketing) on October 1, 2012 after a 4 year effort. The FTC website has over a dozen different documents summarizing and discussing the impacts of “Green Guides” on business. This document was designed to protect consumers and give marketers the proper guidelines necessary to ensure that claims made about the environmental attributes of products are truthful and do not cause consumer deception. Although called “Guides”, they will have the force of law for those who sharply violate them.
The final version addresses issues that did not even exist when the Green Guides were last issued (1998), such as seals of approval, carbon offsets, and “free-of” and made with renewable energy and materials claims. Ironically, the new Green Guides do not define terms such as “green”, “sustainable,” and “natural.” The Green Guides go into effect immediately.

Some highlights of the Green Guides:

• Companies should only make environmental benefit statements that can be backed up with tested data. Broad claims, like “green” or “eco-friendly”, are discouraged because they are impossible to substantiate;

• Companies that provide claims of environmental benefits must ensure that such claims are clear to the (nonprofessional) public and specific;

• Companies should use approved accounting methods to substantiate that any carbon offsets bought or sold are based on actual measured GHG emission reductions and ensure that the offsets derived from a voluntary reduction, not one required by law;

• Companies that list an environmental certification or seal must clearly reveal its specific basis, not that it is given to a product for general environmental benefit. Companies must also disclose any relationship with the certifying organization;

• Companies claiming a product is “compostable” need scientific proof that all product materials – including packaging – will break down into compost. A claim that a product is “degradable” can only be made if there is scientific data that the entire product and package will completely break down and return to nature within one year of typical disposal (in other words, not for a product whose waste is normally destined for a landfill or incinerator);

• Companies claiming a product to be “recyclable” in areas where recycling of those types of products is unavailable must disclose this limitation if recycling facilities are unavailable to at least 60% of the consumers where the product is sold;

• Companies that claim that a product is “non-toxic” need to have available, reliable scientific data that the product is safe for both people and the environment;

• Companies can make a claim that a product is “free of” a certain compound only if that substance is not associated with that product type. A company can claim that the product is “free of” the compound even if it contains some amount of it only if:

o the product does not have more than trace amounts or background levels of the substance in question and is not intentionally added to the product,

o the trace amount of substance present does not cause the harm that may be expected of the substance, and

o the substance has not been replaced with another one that poses a similar or greater level of risk.

In short, the FTC is cautioning companies not to make broad, unqualified claims, particularly of a concept that does not have a specific definition, such as “eco-friendly” or “green”. Studies indicate that such claims do cause consumers to believe that the product truly has significant environmental benefits, which may not be true. Instead, more specific claims should be made, and then only if backed up by scientific data.

Although the Green Guides are not federal regulations, they do set the guidelines for the types of environmental claims that the FTC may find to be deceptive under Section 5 of the FTC Act, which can be the basis of enforcement action by the FTC of deceiving the public in advertisement.

The initial reaction to the issuance of the Green Guides by industry, consumer, and environmental groups appears to be positive. At least there is less confusion as actual guidelines exist that companies and marketers can use when promoting green products. You as an EHS or sustainability professional may be brought in to help your Marketing Group decide on what claims for your products may be made. Your scientific knowledge should help square claims away with the guidelines in the Green Guides.

The one area of confusion that has come out since the issuance of the Green Guides earlier this month is what constitutes a qualified scientific claim and what is an unqualified claim. What level of scientific evidence is sufficient to make a claim? Must it be a study published in a major, refereed, professional scientific journal? Could one in a less rigorous journal (consumer magazine) be acceptable as qualified? Or could an internal, unpublished study made available to anybody who inquires be acceptable? The FTC may need to clarify what it means by qualified scientific study.

CCES has the experts and experience to assist you in developing a dependable “green” and sustainability program and to assess potential green and environmental claims for your products. We can design and manage such a program to maximize your cost benefits and to coordinate with your Marketing and Product Development groups to properly highlight your environmental benefits. Contact us for more information.

December 2013

Gasoline prices have dropped recently, but they have been over $4.00/gallon and could easily return “north” of there if several geopolitical situations occur. As upheavals in the Middle East, Russia, and Latin America show, even matters far away and outside the government’s control can reverse long-held trends and cause oil to be more expensive.

For many companies, but perhaps more important, departments, divisions, and offices, energy is a significant portion of expenses; cutting fuel costs is an important way to help the bottom line and preserve your budget. While using natural gas for boilers and renewable energy for electricity can be feasible, transportation is a major problem, as there are few reliable substitutes for gasoline and diesel fuel, particularly for large vehicles, such as trucks. It is imperative to implement a conservation program to control costs. And if you have a sustainability or energy plan, this will fit in and contribute significantly. What follows are 5 tips to reduce fuel usage in your transportation sector.

• Manage your fleet size and usage. When fuel and space were cheaper, it was feasible to purchase extra trucks or cars for your fleet. You never want to be caught short! But now, given the extra fuel needed sitting in an idle truck (not to mention the payments on the vehicle), this could be a good time to re-evaluate the size of your fleet. Can you reasonably downsize the number of vehicles? Are they the right size or contain the right features for their exact needs (transporting materials or salespeople)? For example, several major companies give their sales staff incentives to order fuel-efficient cars rather than big, flashy gas guzzlers, which ultimately has saved them money in avoided fuel purchases. With the US CAFÉ standard recently raised for passenger cars to 54.5 miles per gallon by 2025, opportunities exist for a smart fleet program for fuel cost savings.

• Programs to drive more effectively. It may seem impractical, even silly, to set driving standards for your employees or professional truck drivers who have many years of experience, but re-educating based on recent studies can result in stretching out a fleet’s fuel usage. For example, excess braking reduces fuel economy by as much as 33% at highway speeds. Idling also decreases average fuel efficiency. While turning a car off and then back on a minute later made no sense years ago, new fuel injection technology reduces the fuel necessary to turn on a car. If a car is stopped for more than 10 seconds, tests have shown that it makes sense to turn your car off, then back on. OK, it may be impractical to do this at a traffic light, but other opportunities exist to turn off a vehicle for fuel savings. Also, be aware that more and more municipalities ban idling.

• Trip management. Plan out all trips ahead of time to minimize time lost and fuel used in being lost. As was well publicized, a few years ago UPS invested in software to develop routes for all deliveries that took the least amount of time and amount of fuel. In the first year, they reported to have saved over 3 million gallons of diesel fuel. One policy UPS added was to minimize left turns. It was more cost-effective to drive a longer distance and make multiple right turns than to make a left turn. In addition, combining stops and avoiding frequent short trips will improve your overall fuel economy. One more thing that affects fuel economy is the terrain. Hilly terrain and unpaved roads adversely affect fuel economy, so planning out routes that minimize these will conserve fuel use.

• Maintain your fleet. Your fleet should have a regular maintenance performed thoroughly and on schedule. A poorly maintained automobile or truck not only burns more fuel, but also requires more repairs and more frequent replacement, costing more money. Maintenance is necessary for the entire vehicle, from engines, radiators, and fuel injectors to brakes, filters, and tires. They all can affect fuel economy. Your cost to maintain your vehicles are easily made up in avoided replacement costs and fuel combustion.

• Alternative fuels. Research whether alternative fuels can successfully be implemented in your fleet and what the potential savings and costs are. For example, can your trucks be converted to burn used vegetable oil, which certainly has a combustion capability? If so, what are the costs of such a conversion and what is the availability and cost of such oil? Waste vegetable oil is available in greater quantities than ever and, in some areas, can be obtained for free. If your processes result in waste vegetable oil, not only would you be avoiding significant waste disposal costs, but it can substitute for diesel fuel in your trucks, extra savings!

Finally, when implementing a transportation energy conservation program, it is important to catalog progress. Therefore, recordkeeping is important and will lead important information. How many miles are your vehicles being driven? How much (less) are you buying fuel? Is your overall fuel economy changing? While this may seem daunting and “just another thing that has to be done”, it is not as difficult as you may think because this can be combined with your recording of fuel purchases in Accounts Payable. For all recorded fuel purchases, include the code for the particular vehicle and the odometer readings and now you can easily get a feel for your progress in not only fuel cost savings, but also can compute relative fuel economy for individual or groups of vehicles in your fleet. You can see changes over time and correlate them to functions (more or fewer sales calls in different seasons), the weather, locations, etc.

CCES has experience and can assist you in developing a dependable transportation energy conservation program or an energy conservation program for all of your organization’s functions. In either case, we can design and manage such a program to maximize your cost benefits and to dovetail it to your greenhouse gas reduction or sustainability program. Contact us for more information.

We are currently dealing with a real conundrum. It is in the nation’s interest to reduce our energy use, reduce GHG and other emissions, reduce our need for more power plants and energy infrastructure, and be more energy independent. But people fear new regulations and standards to force this. So, how can we reduce energy usage without “government intrusion”? One idea is to mandate disclosure of a building’s energy use, but not require they meet a standard. Diverse new rules have been passed in cities from Seattle to Washington, DC and New York City (plus several states) mandating energy reporting. The thinking is that if comparative energy data is available for potential buyers or tenants, then building owners may be motivated to reduce, but not feel they have to.

Different Approaches in Different Areas

These rules differ between jurisdictions, but have the same approach: gather sufficient building-specific energy usage information to develop a score (usually through the USEPA’s Portfolio Manager) to rate the building. Some rules apply only to commercial buildings, some also apply to residences. Some jurisdictions require all subject buildings greater than a certain square footage to report (i.e., New York City, >50,000 sq. ft. – in some cities, the threshold is lower); others require disclosure of a subject building only when it is undergoing a transaction (i.e., California’s new rule, to go into effect in 2013, is only for a perspective buyer or new major tenant). The New York City rule (Local Law 84) exempts a commercial building which utilizes at least 10% of its floor space for energy-intensive operations, such as film studios, trading floors, and data centers. They still must submit data, but their scores will not be compared to standard office buildings.

How Public Will the Data Be

In many cities, data and ratings will be published in full. New York City just published a summary report of the first energy submittals in 2011 for 2010 energy usage (http://www.nyc.gov/html/gbee/downloads/pdf/nyc_ll84_benchmarking_report_2012.pdf). It plans to post building-specific data of tens of thousands of subject buildings in stages starting this fall, including energy intensity (kBtu/sq. ft), Energy Star score, and GHG emissions. It is unclear whether NYC will post “all” data or just summaries. In areas only for buildings in a transactional situation, data will be shared only with affected parties. But in this era of open information it is unclear how to keep such data private (FOIA or the buyer posting data). In this era of Facebook, Linkedin, and other social media, posted energy data and success can, in a short time, be shared with the general public or a specific segment, such as real estate brokers or potential renters and buyers.

How Will Energy Data Be Used and Perceived?

For most of the rules, use of USEPA’s Portfolio Manager is required. It is a respected, free program that allows entry of basic building and energy data (i.e., type, location, conditioned square footage, electricity and fuel usages, etc.) to develop an Energy Star “score”. It is a percentile from 0 to 100. A score of 50 means that the building fits in the median for similar building types and size. A score of 75 or greater enables the building to earn the Energy Star label from the USEPA.

Some are concerned that a simple score cannot accurately describe a building. Each building may have unique features holding it back from a better score. The USEPA is currently revising Portfolio Manager, and will release a new version in early 2013.

Data gathering also depends on tenant cooperation. In some places, such as California, the owner cannot “force” a tenant to share its utility bills, even for mandatory energy disclosure. Thus, agencies must address data quality issues (when values must be estimated) and readers (stakeholders) must understand not to take scores too literally.

In addition, another concern is the changing modes of business. Business must be flexible. How it operates now can change fairly quickly to respond to customer needs. This includes the need for equipment or changes in operation that may change energy usage. This may not be reflected in an energy intensity or Energy Star score released.

What Are The Future Benefits of Energy Disclosure?

There are likely to be many. As discussed above, it gives the consumer (potential renter or buyer) more valid information about the energy achievements of a building and for budgeting and bidding purposes. This could also give the owner/manager motivation to improve energy performance, reducing costs. Disclosure of actual energy performance emphasizes feats, rather than actions, which in some ways is a step up from programs like LEED, which, awards points for implementing practices even if results are unclear.

Energy disclosure will also likely impact real estate appraisals. Appraisers have historically not considered energy strongly when evaluating a building, mainly because of little comparative industry-wide data and appraisers’ lack of knowledge. Now with Energy Star scores and energy intensity better understood, energy performance will now likely influence building value, and those interested to be more efficient.

In summary, government agencies see energy disclosure as a way to plan for and improve the usage of energy resources, while not spending huge resources on enforcing energy standards. There is growing interest in this by many jurisdictions.

CCES experts can help you assess your site-specific energy usage, using Portfolio Manager and other tools. We can manage your compliance with an energy disclosure rule or just for you to have the information. We can perform simple or more complex energy evaluations in which we can also to develop reasonable strategies for you to reduce your energy usage and save you much costs with reasonable return on investment. Call or e-mail for a free, no-obligation discussion or more information now.

Many articles have been written in this blog and newsletter about the many financial benefits of energy upgrades. Not just the direct cost savings of energy efficiency and conservation, but items like employee productivity, satisfying customers, and reducing risk. Energy efficiency improvements depend on the effectiveness of the equipment being purchased, whether they be lights, appliances, or HVAC equipment. The great news is that for many technologies, both improvement in efficiency and reduction in price have been occurring simultaneously on a regular basis. Historically, new energy technologies become both more efficient and cheaper over time.
This leaves corporate and building managers with a dilemma. If energy-efficient strategies will improve and be cheaper in the future, is it better to wait to upgrade? Then when next year comes, should one wait another year for even greater savings?

Here is an example. A building uses 500 75-watt T12 fluorescent bulbs. Assuming the owner pays $0.15/kilowatt-hour and operates the bulbs 12 hours/day every day, the T12s cost the building owner $2,228 per month in electricity to light the areas (assume an extra 10% usage for the ballasts). This does not include the extra cost to air condition areas for the excess heat during the cooling season (including demand charges, too).

What if the bulbs are replaced with LEDs which produce the same amount of light, but use only 20 watts. Electricity costs for the lighting will decline to just under $600/month, a savings of over $1,600/month. The real savings will be a little greater as LEDs will reduce summer AC needs. Assume an installed cost of $85/LED, the upfront investment is $42,500, for a simple payback of just over two years. There is additional cost savings through reduced maintenance efforts because LED lights last much longer than T12s.

Let’s assume that in one year, the installed price of LEDs drop to $75/LED and the wattage drops to 15 watts. Electricity costs will decline to about $450/month, a savings of an added $125/month or $1,500/year. The upfront cost drops to $37,500. However, the building had one extra year of using the T12s, paying out over $1,600/month extra. So while waiting an additional year saves the building an extra $1,500/year in electricity costs and $5,000 in upfront costs, the wait also cost the building about $20,000 in extra electricity costs. The incremental improvement of one year does not pay for the use of inefficient technology during that year awaiting potential efficiency and cost upgrades.

Yes, the great improvements in energy technologies that have occurred over the past decade or two alone justifies the move to perform an energy analysis and smartly upgrade your energy systems now and not wait for possible added future advances.

CCES has energy experts to perform smart energy analyses and audits to show how the latest strategies will both save you significant money and improve the comfort and productivity of your staff. Contact us at 914-584-6720 or karell@CCESworld.com.

The City of New York promulgated Local Law 87 in 2009, with amendments in 2012, a radical approach for energy conservation. Local Law 84, already in effect, requires subject buildings to compile and enter energy data into Portfolio Manager for the public to see. But LL 87 requires a more active policy of energy conservation. LL 87 is now in effect, with the first reports due for selected buildings this December 31, 2013. See: http://www.nyc.gov/html/gbee/html/plan/ll87.shtml

Applicability

With some exceptions (not presented here), any building in New York City with a gross area of 50,000 sq. ft. or greater is subject to LL 87. Applicable large buildings must conduct an energy audit and a retro-commissioning study every 10 years. The reports for these two requirements are due to the NYC Dept of Buildings on Dec. 31 of the year ending with the last digit of the building’s tax block ID number (2013, if that digit is a 3 until 2022, if that digit is a 2). Based on the DOB’s reaction to LL 84 non-action, there may be an initial warning, but expect to be fined if LL 87 is ignored. A building may elect to submit LL 87 reports up to four years ahead of its due date.

First step: check your DOB-listed gross square footage to determine whether it is greater than or equal to 50,000 sq. ft. If so, check the last digit of your tax block # to determine when your reports are due.

Required Actions

A subject building must perform an energy audit, equivalent to a Level II ASHRAE audit. It must be performed or supervised by a professional, as listed in the rule. A Certified Energy Manager (CEM) is one qualified professional. The audit includes collecting at least one continuous recent year of energy use data (i.e., electricity and gas bills, oil invoices) and performing a building site visit. The auditor will focus on three items: the building “envelope” (i.e., windows, roof, insulation), lighting, and HVAC equipment. It is critical that during the site visit the person who knows the building the best (typically a facility manager or superintendent) be made available to answer the auditor’s questions. In addition, it is important to give the auditor access to all manuals about equipment and a history of building changes.

The DOB issued its preferred energy audit report format, an Excel spreadsheet. The key to the energy audit report is a list of energy conservation measures (ECMs) that the building can implement to reduce energy use. Many ECMs require purchase of updated systems or equipment, and are capital intensive. ECMs include an estimated cost to implement, the amount of energy and cost expected to be saved, and simple payback period. It is important to note that LL 87 does not require implementation of any ECM; any ECM that is implemented may be scheduled based on building management preference.

The other part of the LL 87 requirements is a retro-commissioning (RCx) study, a review of existing energy systems and equipment and a determination of whether they are operating properly. Like the energy audit, the RCx must be performed or supervised by a listed professional in the field; four certifications are acceptable. An Existing Building Commissioning Professional (EBCP) is one example. The RCx must make a detailed site visit to examine energy-related equipment, pipes, and systems. It is common for such a visit to last several days to observe all relevant systems. RCx studies often take place over several seasons. If the site visit is performed during the winter, it may be difficult to turn on and measure the effectiveness of a cooling system. I performed such a site visit on a 90 degree summer day, and turned on (with the site’s permission) the heating system (at lunch time, when many workers left the building).

The 2012 amended LL 87 contains 25 different areas that must be examined as part of the RCx study, including whether there are leaks in any air or water system, pipes are insulated, filters are present and clean, thermostats are properly calibrated (i.e., the temperature noted is what it actually is), equipment manuals accessible to staff, lighting is proper for the need, lighting fixtures are broken, etc. Any deficiencies found are generally no/low cost to remedy and are intended to ensure that your equipment is operating as they are supposed to.

The RCx professional must develop a report listing specific deficiencies (i.e., rooftop unit #2 has a clogged filter, several fluorescent lights are out in section X of the 3rd floor, the condensate line of unit #4 is leaking, etc.) and present it to building management (not the DOB). The RCx professional must return to the building to determine whether the deficiencies have been addressed, and develop a report which must list the project team, building information, testing protocol, a master list of findings, and a catalogue of deficiencies corrected. This report must be submitted to the DOB by Dec. 31 of the subject year. It is believed that most remediation of deficiencies are inexpensive to perform and can be done by building maintenance staff and/or contractors who service HVAC equipment.

Please note that this is a basic summary of LL 87. For the sake of space, some details of applicability and requirements are not provided. Please be sure to read the original and amended rule to fully understand applicability and requirements.

CCES has the professional technical staff (licensed professional engineers, CEMs, EBCPs, etc.) to help assess your LL 87-applicability and help you comply with the complex rule. Contact us at 914-584-6720 or at karell@CCESworld.com.

October 15, 2013

The USEPA proposed to amend the recordkeeping and reporting requirements of the Greenhouse Gas (GHG) reporting rule (40 CFR Part 98), for certain categories of reporters. The USEPA saw the need to address what types of data inputs in GHG emission calculations are confidential business information (CBI).

In the Clean Air Act, “emission data” cannot be kept confidential. Therefore, the USEPA proposed in 2010 that emission equations used by a facility for its GHG emission reporting meet the definition of “emission data” and could not be protected as CBI. Many facilities that must perform and submit to the USEPA these emission calculations are heavy manufacturing and chemical facilities, who became concerned that such unique, critical data about their processes, such as listing all raw materials used and their volumes and overall production data, may not be protected as CBI and become public knowledge. In response to strong public comments, USEPA deferred reporting requirements until 2013 for some data, and 2015 for others, to allow a full evaluation.

In last month’s proposed rule, the USEPA suggested that facilities use an agency-developed input verification tool that would verify detailed data used in calculations, yet not have this tool and its inputs available for publishing because of CBI.

Entities affected by this proposal are facilities that are direct emitters of GHGs and tend to be in the heavy manufacturing and chemical manufacturing industries. The USEPA has proposed that facilities subject to this proposed rule change that use information that is potentially CBI to calculate and report GHG emissions, use the electronic inputs verification tool being developed by the USEPA, which would calculate and also verify GHG emissions. The USEPA provided an Internet link to a “pilot” for its inputs verification tool within the USEPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT). Of course, with the government shutdown, the “pilot” is not available.

The USEPA is seeking comments from the business community about the rule and the pilot modified e-GRRT system as to its functionality. Public comments on the proposal are presently due on November 12, 2013, but will undoubtedly be delayed by the shutdown. While this proposal is focused on the GHG Reporting Rule (40 CFR Part 98), this approach to CBI will undoubtedly affect other environmental programs, as well. Therefore, it is important to keep abreast of the final rule change on this issue.

CCES has the technical experts and experience to calculate emissions of GHGs or any other regulated air pollutant from a variety of processes and sources using approved, published methodologies. Contact us today at 914-584-6720 or karell@CCESworld.com.

Natural daylighting and views to the outdoors provides an economic form of lighting and at the same time improve the indoor environmental quality in the workplace. The lack of natural daylight affects people in the workplace. Natural daylight has been proven to reduce stress levels and increase employee performance.

We are naturally drawn to the outdoors and feel more comfortable when we are connected in some way with nature. Even though natural daylight can sometimes be a source of glare and uncontrolled or variable illumination, it is still a strong desired feature in the workplace environment.

The following are benefits of natural daylight in the workplace:

Decreased Use of Energy. Making use of natural daylight with lots of window access results in less of a need for artificial lighting, which means less energy consumption and lower energy bills. When artificial lights are left on when no one is around it is a waste of energy and money, but when natural daylight is used there is not any waste.

Many offices that are making an effort to reduce their carbon footprint are seeing a large reduction in their annual electricity costs by cutting down on artificial light and maximizing natural daylighting. For an added increase in energy efficiency, they are also installing daylight monitoring sensors, which automatically adjust the light levels indoors according to the light outdoors.

Better Health. Research has proven that headaches and eyestrain are among the leading health problems in the workplace, and these issues are related to the spectrum of light experienced. The Color Rendering Index (CRI) rates how lamps render color. The best CRI is natural daylight because it has the full spectrum of colors.

Eyestrain can be significantly reduced when people have a window with a view. Landscape views, either short-range or long-range force the eye constantly to refocus, benefiting the eyes. Natural daylight helps to increase attentiveness, causes fewer headaches and improves productivity.

Improved Productivity. Besides natural daylight affecting the eyes, it can also have physical effects on the body that influence a person’s mood and motivation levels. Studies have proven that employees prefer to have their workstations near a window because the natural daylight and views of the outdoors provides stimulation and variety throughout the workday.

Bright and open working environments with plenty of windows reduce stress leading to increased concentration and productivity. When companies try to save money on lighting, studies have revealed that the quality of work and productivity decreases.

To improve the amount natural daylight in an existing building, full pane or floor to ceiling windows can be installed to maximize the amount of lighting entering a building. On the top floors, skylights or light tubes can be installed to funnel light into the spaces below. Also, the use of glass walls and low partitions add more visual access to windows helping to create a more efficient workplace.

Employees with convenient access to natural daylight have instant access to time and weather, and a connection to the outside world. When they have a view of the outdoors, they tend to show less stress from their work, less illnesses, and more work satisfaction. They also recover from stressful situations quicker and do not tend to become stressed out as easily.

Employees do not want to feel trapped in a space while working. They need to feel a connection to the outside and want to be able be to enjoy nature while sitting at their desk. A bright, uplifting working environment elevates everyone’s mood.

Lynn Hoffman may be reached at 203-984-4695 or at lynn@lynnhoffmandesign.com.

I have written much in this blog about energy conservation and easy, inexpensive ways to save energy costs with a good payback. For most buildings and situations, lighting is on top of the list. While economics is an important reason to upgrade lighting, growing research indicates that using the right type of lighting will also improve your and your workers’ health and productivity, also improving the bottom line. Most buildings now use fluorescent lights, even compact fluorescents. While they use less energy per unit of light than incandescents, fluorescent lighting may contribute to a number of problems.

Why? Human eyesight and our brain developed from signals from our retinas based on sunlight during our evolution. The Sun shines the full spectrum of visible wavelengths, in addition to those higher and lower than the visible spectrum. We evolved as outside beings using sunlight to work and survive. Even as we moved to indoor living, domiciles were built with openings or (later) windows to let in sunlight. Artificial lights give off a limited spectrum of wavelengths and being much more recent, we have yet to evolve to handle these patterns. In addition, fluorescent lights flicker due to electricity flow pulses. While we generally do not consciously detect such flickering, our retinas and brains do. A third problem with fluorescents is its color rendering, a rating of a light’s color compared to natural sources. A color rendering index (CRI) of 100 means a range of colors equal to sunlight. Ironically, energy inefficient incandescent lights usually have a CRI in the upper 90’s. Many standard fluorescents are in the 50’s and 60’s; although modern, energy-efficient ones, such as T-8s and CFLs, have CRIs in the 80’s. High and low pressure sodium lamps, commonly used in outdoor lighting, have CRIs in the 20’s to 40’s. LEDs vary in their CRI; however, most recent brands are at least in the 80’s.

Research indicates at least some linkage between long-term exposure to fluorescent lights with migraine headaches, eye strain, sleep deprivation, anxiety, depression, hormonal disruptions, certain cancers, and obesity.

What can you do to lessen these effects in your office and home?

• Bring in sunlight. That is, encourage workers to get outdoors in the sun a few times a day. Also, try to move workers to spaces away from the interior of the building and by a window. Skylights can bring sunlight into your office, as well.

• Look to purchase and install energy efficient lights with the highest CRI available. If your office continues to use fluorescent lights, then consider electronic ballasts over magnetic ones (less flicker) and “full spectrum” lights that have a better CRI than others or filters over lamps to aid in full spectrum wavelengths.

CCES has the experts to help you evaluate your lighting to save energy costs, while creating a positive working environment. Contact us today at 914-584-6720 or at karell@CCESworld.com.

When one considers an energy audit, one “rounds up the usual suspects”, as they said in the movie Casablanca: lighting, envelope, HVAC. However, there are other major users of energy not always considered during an audit. One that can result in significant electricity savings is replacing a constant speed fan or drive with a variable speed unit.

A study has found that upgrading fans to include fan speed controls in an intense area of electricity usage, such as a data center, can reduce both the facility’s electricity usage and average and peak electric power demand by 40 to 70%. Since many buildings’ electricity costs are due to both total and peak usage, this is important. A joint study of a 135,000 square foot data center in California by Digital Realty Trust (the owner), Vigilent Corporation, and Lawrence Berkeley National Laboratory focused on replacing constant speed scroll fans with electronically commutated motor variable speed fans of a more efficient design and deploying an energy management system to control fan speeds and computer room air handler output.

Variable speed fans using energy management software led to a 66% reduction in electricity usage for cooling compared to using a constant speed fan, on at all times. Additional energy savings were also achieved by improved temperature distribution. In all, power usage effectiveness (PUE) was improved by 8% and 2.9 million kWh were saved annually.

Variable frequency drives (VFDs) for motors can also reduce wasted electricity. In starting a motor, a VFD initially applies a low frequency and voltage, thus avoiding high inrush current. After the start, the VFD can increase frequency and voltage at a controlled rate. A motor using a VFD can develop 150% of its rated torque while the VFD is drawing in less than half of its rated current. The stopping sequence is just the opposite of the starting one. The frequency and voltage applied to the motor are ramped down at a controlled rate. When the frequency approaches zero, the motor is shut off.

According to the IEEE, there are over 40 million motors operated in the U.S., using up to 60% of total national electricity. IEEE believes that VFDs can cumulatively reduce electricity consumption by about 18% for all such motors.

Another cost-saving approach to consider is an energy management system to provide a graphical view of the heat profile in a room, such as a data center, allowing operation of an HVAC to be more efficient while ensuring equitable cooling to protect equipment.

CCES has the experts to assess whether and by how much your facility can benefit by switching to VFDs and variable speed fans, can provide you with other ways to reduce your energy usage, and maximize your financial return. Contact us today at karell@CCESworld.com or at 914-584-6720.