Cross-State Air Pollution Rule Affecting Power Plants Finalized

On September 7, 2016, the USEPA finalized an update to the Cross-State Air Pollution Rule (CSAPR) for the 2008 ozone National Ambient Air Quality Standard (NAAQS) by issuing a final CSAPR Update. See The final rule has not yet been published in the Federal Register.

CSAPR was designed to address facilities that cause significant pollution that travels long distances impacting people in other states. States in which these facilities operate have not been motivated to regulate their emissions as it does not affect the health of their citizens. This federal rule achieves this. USEPA estimates that the rule will reduce summer (May – September) emissions of nitrogen oxides (NOx) from power plants in 22 states, result in benefits totaling up to $880 million, and reduce ground-level ozone exposure for millions so people, reducing rates of asthma, cancer, and other diseases.

Beginning in May 2017, the new rule will affect 2,875 electric generating units at 886 coal, gas and oil power plants. The USEPA says affected power plants can achieve the required NOx emissions reductions using existing, cost-effective technology.

Under CSAPR, each of the 22 states hosting an affected electric generating unit must develop state implementation plans meeting minimum NOx emission requirements under the supervision of the USEPA which could issue a federal implementation plan for each state that fails to submit an approvable plan.

The power industry has come out against CSAPR since its inception, suing the USEPA. The US Supreme Court upheld the CSAPR in 2014. However, the US Court of Appeals, DC Circuit in July 2015 remanded parts of CSAPR to the USEPA for updating, and this is the final update. This update is based on downwind areas meeting the 2008 ozone NAAQS of 75 parts per billion, and not the subsequently updated standard of 70 ppb. The power industry is still not happy with the updated version and a legal challenge to CSAPR is likely.

CCES has the technical experts to help your company implement the technical requirements to comply with a variety of environmental and air quality rules. Our engineers can perform an emissions inventory and determine from a technical point of view how to maintain compliance or get in compliance with federal and state air rules. Contact us today at 914-584-6720 or at

Fuel Economy Standards Tightened For Heavy, Medium-Duty Trucks – Phase 2

The USEPA and National Highway Traffic Safety Administration jointly issued a final rule with new fuel economy standards for heavy to medium trucks which had kept its fuel economy standards virtually unchanged for many years. While the USEPA had made more rigorous fuel economy standards for passenger cars (Corporate Average Fuel Economy or CAFÉ) and light-duty trucks, medium- and heavy-duty trucks have escaped such tightening of standards for a few decades. Phase 1 standards were issued beginning with model year 2014 heavy-duty trucks. The new Phase 2 standards ( will be phased in through 2027. The final rule’s impact is estimated to reduce greenhouse gas (GHG) emissions from such trucks by about 10% or about 1 billion tons over the lives of the regulated vehicles, as well as save about 75 billion gallons of (mainly) diesel oil and 25% more fuel efficient.

The new rule covers vehicles, such as big rigs, passenger vans, truck trailers, school and passenger buses, and dump trucks. Medium- and heavy-duty vehicles currently account for approximately 25% of GHG emissions in the US transportation sector.

Phase 2 will provide significant GHG emission reductions and save fuel by:

• Accounting for ongoing technological advancements. Truck owners will be required to procure trucks containing certain fuel and emission reduction technology. While more expensive, the payback is estimated at about 2 years for tractors and trailers and about 3 years for heavy-duty pickups and vans.

• Containing first-time standards for trailers. Phase 2 standards include fuel efficiency and GHG emission standards for trailers used in combination with tractors. Although standards will not be finalized for all trailer types, the majority will be covered.

• Encouraging innovation while providing flexibility for manufacturers. For each category of trucks, performance targets will be set that allow manufacturers to achieve reductions through a mix of different technologies (such as any combination of advanced aerodynamics, engine improvements, waste heat recovery, etc.). Manufacturers will be free to choose any means of compliance.

CCES has the air quality experts to help your firm understand and provide the technical expertise to comply with a variety of air regulations. We can perform a complete emissions inventory of your facility and technical evaluation of compliance with federal and state air rules. Contact us today at 914-584-6720 or at

USEPA Proposes Clean Energy Incentive Program

On June 30, 2016, the USEPA published a proposed rule laying out its Clean Energy Incentive Program (CEIP), found in the Federal Register, Vol. 81, No. 126. CEIP is a voluntary early action program within the federal Clean Power Plan of 2015 (CPP), regulating CO2 emissions from existing power plants. To provide greater compliance flexibility, including having a pool of allowances for subject power plants to buy to comply, the USEPA would like to have this available when CPP goes into effect in 2022.

Implementation of CPP has been hobbled by a stay put on it by the US Supreme Court in February 2016. While some have argued that all compliance deadlines must be postponed because of the stay, the USEPA is continuing efforts for full implementation of all aspects of the Plan, including the proposed CEIP program.

The publication contains proposed guidelines for states that wish to participate in CEIP, including procedures for states to distribute allowances or to issue emission reduction credits (ERCs) for approved energy efficiency (in low-income communities) and zero-emitting renewable energy projects (in all communities). The proposed rule lists solar, geothermal, hydro, and wind as eligible renewable projects; it does call for comments on whether it should expand the definition to include CHP and nuclear. An entity which has successfully implemented an approved project by 2020 may get matching ERCs from the USEPA and can sell or transfer the ERCs or allowances to subject power plants to comply with their CO2 emission reduction goals from CPP. The USEPA is limiting the pool to 300 million short tons of CO2 emission allowances to distribute, based on its estimation that this will be the level that subject power plants will reduce CO2 emissions as part of CPP. These allowances will be distributed to states based on its share of the estimated reduction.

The proposed rule contains administrative requirements for states that choose to participate in the CEIP and the requirements for energy projects to meet CEIP eligibility. In general, a renewable energy project will receive 2 ERCs for every 2 MWh of renewable power generated. This ratio doubles for projects in low-income communities. For a project to be eligible to obtain ERCs, it must be implemented in a state that is participating in CEIP, and has demonstrated that it is replacing electricity production from a subject power plant in 2020 and 2021.

CCES has the technical experts to help you plan, design, select, and fully implement an energy efficiency or renewable energy project and help you obtain ERCs under this program, when it comes into force. We can maximize not only the revenue you can make selling ERCs under this program, but also maximize the financial benefits of your projects for your bottom line, as well. Contact us today for a free, no-obligation discussion at or at 914-584-6720.

USEPA Issues Final Rule On Formaldehyde Emission Standards For Composite Wood Products

On July 27, 2016, the USEPA released a prepublication version of its final rule on Formaldehyde Emission Standards for Composite Wood Products. This is important as the USEPA has classified formaldehyde as a probable human carcinogen and many buildings looking to meet green standards take care to minimize indoor formaldehyde emissions. The authority for the rule comes from the TSCA. The USEPA’s rule relies heavily on the formaldehyde emissions rules set by the California Air Resources Board (CARB). The federal standards are identical to those set by CARB.

Formaldehyde emission standards
Hardwood plywood (with a veneer core or composite core) = 0.05 ppm
Particleboard = 0.09 ppm
Medium-density fireboard (MDF) = 0.11 ppm
Thin MDF = 0.13 ppm

When it goes into effect, this rule will affect manufacturers, importers, distributors, and retailers of products containing composite wood as listed above.
The USEPA’s final rule goes into effect one year after its publication in the Federal Register. At that point, fabricators, importers, distributors, and retailers of finished goods containing composite wood must begin to comply with new recordkeeping and labeling requirements. The final rule contains detailed requirements for recordkeeping, labeling, and testing of both composite wood and products containing composite wood.

Record-keeping and labeling. Fabricators, importers, distributors, and retailers of composite wood or products containing it will be required to “take reasonable precautions” to ensure their products comply with the emissions standards, defined as preparing or obtaining appropriate documentation, such as bills of lading or invoices, from suppliers of composite wood products that includes a written statement that the products are either compliant with the emissions standards or were produced prior to the rule taking effect. Companies must retain this documentation for at least 3 years.

In addition, importers must provide records (within 30 days of a request by the USEPA) identifying either the composite wood panel producer and date the composite wood products were produced or the supplier of the composite wood products (if different than the producer), component parts, or finished goods and the date of purchase.

Manufacturers of subject products must label each bundle containing finished goods with manufacturer’s name, date produced, and a statement that the material complies with the emission standard. Importers, distributors, and retailers must keep the label on each bundle and make information available to potential customers if requested.

Importer Certification. 2 years after final rule publication, importers will be required to certify that imported composite wood or products containing it comply with the standard.

Testing requirements. Beginning 7 years after publication of the final rule in the Federal Register, manufacturers of laminated products will be required to comply with third-party testing and certification requirements that apply to manufacturers of hardwood plywood panels. “Laminated products” are defined to include only those products with a wood or woody grass veneer, so testing requirements will not apply to synthetic laminates such as plastic or vinyl. The rule does contain certain exemptions for certain laminated products and for use of ultra-low emitting formaldehyde (“ULEF”) resins.

CCES can provide you with technical assistance to help you assess compliance with this and other environmental rules, and to perform a green building analysis. Contact us today at 914-584-6720 or at

White House Issues Final Guidance On Climate Change Analyses in NEPA Reviews

On August 1, 2016, the White House Council on Environmental Quality (CEQ) released final guidance on how federal agencies should consider the direct and indirect impacts of climate change, including from greenhouse gas (GHG) emissions, in environmental reviews conducted under the National Environmental Policy Act (NEPA). See This final guidance is not part of rulemaking and, therefore, is not binding regulation. However, some courts consider CEQ guidance when evaluating NEPA reviews. The guidance is effective immediately, and encourages agencies to use it for all new proposed agency actions for which NEPA review is required.

The final guidance confirms the importance of climate change and its effects and GHG emissions fall under NEPA’s perview. In performing such a review of a proposed project, it is fair to evaluate its GHG emissions and the potential effects of physical climate change impacts. The guidance does not give exact criteria that must be followed in terms of GHG emissions and climate change (a change from the draft guidance), but gives each federal agency the flexibility to use its preferred experts and methods to assess impacts and options. For example, the guidance does not contain a threshold level of GHG emissions that would require review or action, but allows the individual agencies to make that determination.

The guidance calls for a quantitative analysis of potential GHG emissions from a proposed project if appropriate and reliable tools or methodologies are currently available. Stating that GHG emissions are “negligible” or expressions like this are discouraged. A quantitative analysis is also required in discussions of alternatives to a proposed action. However, the guidance does not require the decision maker to select the alternative with the lowest level of GHG emissions. A balanced environmental approach is preferred.

The guidance also calls for agencies to consider how climate change impacts, such as increasing sea level, drought, heavy precipitation, etc. could affect a proposed action. Given that certain aspects of projects, such as development in floodplains or on or near a coastline, could be vulnerable to climate change, agencies should either reject such projects or identify opportunities for adaptation to these effects.

CCES has the technical experts to help your firm perform a quantitative evaluation of GHG emissions and assess potential climate change impacts on a potential project. Contact us today at 914-584-6720 or at

Insulation: Another Way to Save Energy Costs

Pipe and building insulation are proven strategies to reduce energy usage and, therefore, costs. Don’t try this at home or at work, but imagine how hot a metal pipe in steam or hot water service is and then imagine the reduction in heat loss when it is properly insulated. That heat loss stays inside the pipe with the steam or hot water, making it more effective and necessitating less energy usage (fuel combustion) to produce that steam or hot water. Properly and completely insulating a bare surface in steam or hot water service can easily reduce heat losses by over 90% and therefore, reduce your need to produce steam or hot water significantly, saving you fuel costs, improving safety (workers not touching the hot pipes), and reducing emissions of greenhouse gases and of toxics that may impact your plant and neighbors.

To illustrate the cost-effectiveness of insulating pipes in steam or hot water service, see this example. A facility produces and pumps steam at 350°F from an oil-fired boiler operating at an average efficiency of 80%. Oil is purchased at $2.50 per gallon. The 4-inch steam header is insulated with 2 inches of fiberglass pipe insulation. The North American Insulation Manufacturers Association (NAIMA) has software to estimate the energy savings. Let us say that the insulation reduced heat loss from that bare pipe by 95%. Assuming the boiler is used only during the heating season, this can easily save the building $100-$150 per foot per year, for the avoided cost of oil not combusted to replace the lost heat. This figure can be much higher if the cost of oil rises or if the boiler is used for other purposes and is used all year. This also reduces greenhouse gas emissions significantly, too.

Savings can also occur for cold piping, too. Cold water – from electric chillers – transported through pipes can be insulated to save the use of these chillers, reducing electricity usage. While oil prices are relatively low these days, electricity prices are at all-time highs and projected to rise even more. Anything that can be done to reduce electric usage, will save you money.

August is the time of year many buildings – residences, offices, and industry – check their boilers and chillers to make sure they are maintained so they run reliably in the upcoming months. Part of your evaluation should be whether there are pipes that are uninsulated or with insulation that is cracking and damaged. Of course, look out for asbestos and, if present, make sure its removal is managed professionally and via the law. If you see such areas that are uninsulated, underinsulated, or insulated with damaged or cracked insulation, now is the time to re-insulate it properly. That extra time and cost for insulation will be paid for in savings this winter.

CCES has the experts to perform an energy audit of your building, and examine this and many other energy issues to help you save energy and other costs reliably and effectively. Contact us today at 914-584-6720 or at

Prioritizing Your LED Lighting Upgrade

Most people know now that switching to more efficient lighting, such as LEDs, is one of the most effective strategies for saving energy costs. Facility managers are increasingly turning to LED lights for energy efficiency.

However, “going to Home Depot and picking up LEDs” is not the best way to upgrade buildings. It may be a stretch to change all your lights to LEDs at once (lack of available capital for upfront cost, lack of incentives to make it economically feasible). You may have certain goals and constraints. Thus, what can you do to optimize gains from a lighting upgrade in your facility? How should you prioritize an upgrade?

Types and age of lights currently used. To best prioritize a partial upgrade, focus your replacement on the lights that are older and less efficient, such as T-12 fluorescents, halogen bulbs, and incandescents. Replacement of certain bulbs, such as newer T-8 fluorescents with new ballasts, represent a smaller efficiency gain. Of course, it is preferable to replace them all with LEDs, but if that is not possible, then replace older and more inefficient lighting types first.

Your current fixtures’ hours of operation and usage. It is best to install LEDs to replace less efficient lights where high intensity light is needed, such as security lights. Also, determine which of your lights are on the greatest number of hours per year. Only bulbs that are on use electricity, so if lights are used in a situation where they are rarely on, such as a storage room or an electrical room, these could be candidates to be replaced later compared to lights used often. Or to look at it another way, prioritize replacement with LEDs of bulbs normally used often, such as warehouses, parking garages, hallways, elevators and entrances. Of course, for lights with these functions, it is also good to consider occupancy controls which automatically dim or shut off the lights during idle periods.

Maintenance issues. Prioritize replacement of lights with LEDs in places that are difficult to reach or require significant time. LEDs last considerably longer than most fluorescents and incandescents. Therefore, LEDs will also free up your maintenance staff to perform other duties. It will also reduce rental fees of cherry pickers and result in fewer trips up and down ladders, reducing the risk of a costly accident. Longer lasting LEDs mean fewer bulbs to keep in storage, freeing up some space there, too.

Prioritize based on operating condition needs. Unlike most other lights, LEDs do not flicker, reducing eyestrain for office workers. A recent study estimated that properly-designed (less glare) lights resulted in the average office worker having one less “coffee” break per day, improving productivity. Therefore, switching to LEDs in an office setting could be a higher priority. LEDs can also be found in any color on the CCT scale (2,000 to 7,000 Kelvin). For areas where precise work by workers is critical, such as lab or work benches and offices, an LED with a high CCT rating (5,500-6,000K) may be best.

Of course, it is preferable to maximize energy cost reductions by replacing all your lights with appropriate LEDs. However, because many large buildings and entities have financial and other constraints it may be necessary to prioritize where one replaces older lights with LEDs. Proper research into the areas of the building that are lit and their function and current lighting status will be helpful in prioritizing properly.

CCES can help you design and implement a lighting upgrade to maximize your financial benefits and improve productivity. Contact us today at 914-584-6720 or at

Resolution for 2017: Take Control of Energy – Your Most Controllable Operating Expense

It is August, and things may be slow in your office or company, as many people are taking well-deserved time off. But that also means that September – the start of school, fall is around the corner – which means everyone is back at work. For many companies, September is also the start of budgeting season. Departments and Operations envision and plan for projects in 2017, and request budget for them. I think energy efficiency should be on the top of your wish list for your company, as this is the lowest-hanging fruit for reducing operating costs and also provide other financial benefits. Of course, you need to communicate that energy efficiency provides great return for minimal risk to your Finance Dept in language they understand to get approval for initial upfront funding. Actual case studies demonstrate that smart energy efficiency projects help businesses be more competitive.

Briefly, here are some facts about energy efficiency to present to your bosses and CFO:

• Great financial returns. The rates of return for energy efficiency projects vary, of course, based on technology, the building, and design. But in many cases, they are superior to most financial investments, often over 25%/year. What bank or Wall St. investment pays that?

• Low risk, high reliability. New energy efficiency strategies are not experimental and are proven in the field. While some vendors offer better quality products than others, they will work, bring about energy reductions, and should be warrantied.

In financial investing, we are constantly faced with high risk to get high yields. Or if we are afraid of losing our investment, we sacrifice yield. With energy efficiency, we have low risk (reliable product) and get fine cost savings! See chart comparing energy efficiency with other financial investments found below:

• Long lasting savings. Energy efficiency results in continual savings for many years, actually growing in time with no additional effort, based on energy rates you pay, which will only go up in the future. If you saved $1,000 in one year from an energy efficiency project, that savings will be $1,050 the next year if rates increase 5%. And that is with no additional effort on your part!

• Reduced O&M costs. Most technologies last longer than the ones replaced. This means less time for maintenance staff, for example, changing light bulbs. This frees them up for other, more important projects to benefit employees and customers (tenants). Fewer light bulb changes also means fewer trips up and down the ladder, reducing the risk of a costly accident. Longer lasting items mean fewer need to be procured in reserve and stored, freeing up space for other uses or allowing you to downsize the space you rent.

• Raise the desirability and value of your property. Perhaps I’ve saved the best for last. Studies have shown that buildings and offices that are energy efficient are ones that employees will work more productively in, which may be more valuable than the cost savings. Employees will be happier, too, reducing turnover and reducing HR and productivity costs of finding replacement workers and hoping he/she is as good as the one that left. With solid energy efficiency technologies to show, companies or families will have a greater desire to rent your property, raising rental income, or desire to buy your building, raising its resale value.

Bottom line: the right, smart energy efficiency projects will produce many financial benefits, more than compensating for the cost to implement them, and an overall positive cash flow.

I hope this primer will help you approach your bosses for some smart energy efficiency ideas and projects for 2017! CCES has the experts to help you design and implement energy efficiency projects to maximize the financial benefits and to ensure they are implemented properly and work well. We want you to succeed and get the benefits and credit! Contact us for an initial discussion at or at 914-584-6720.

USEPA Releases New Final Landfill Emissions Rules

August 2, 2016

On July 15, 2016, the USEPA released a new final amended rule limiting emissions of greenhouse gases (GHGs) and other compounds from both existing and newly-constructed municipal solid waste landfills. This is the first modification to the federal landfill emission rule in 20 years and, for the first time, addresses GHG emissions. There has been the realization lately that any approach to successfully reduce GHG emissions nationally mist include reduction of methane emissions, a major component of landfill gas, because it is 21 times more potent on a mass basis than the main GHG, CO2, which had been the focus of most GHG reduction strategies. Therefore, came this focus on amending the main federal municipal landfill air quality rule.

Newly-constructed or modified landfills after July 17, 2014 will have emission limits found in New Source Performance Standards (NSPS) or Sect. 111(b) of CAA. See For existing landfills built before this date, emission guidelines have been published to be implemented by each state in their specific plans. See The USEPA estimates that the new standards will cover over 1,100 new and existing landfills at a combined compliance cost of approximately $60 million by 2025.

The new standards apply to landfills that have design capacities of 2.5 million metric tons and 2.5 million cubic meters or more of waste, no change in the current rules promulgated in 1996. Under both the rule and the guidelines, facilities that meet the design thresholds and emit over 34 metric tons of non-methane organic compounds (NMOC) per year will be required to install a gas collection control system (GCCS), such as flares, an enclosed combustion system for energy generation, or gas treatment system for its sale or beneficial use. A landfill may be exempt from GCCS requirements even if it meets this applicability threshold if it can demonstrate that the surface NMOC concentration is below 500 ppm for consecutive quarters.

The rule and guidelines will take effect 60 days after publication in the Federal Register (which has not occurred yet as this article is posted). Any facility that exceed the design capacity and NMOC emissions thresholds will have 30 months to install GCCS. The USEPA estimated that > 100 newly-built or modified landfills will install GCCS by 2025.

Capturing landfill gas can be beneficial as it is combustible and can be useful in generating electricity, heat, or hot water. So while being mandated to capture landfill gas can be costly, it is a “free” source of energy that can be converted to useful energy to reduce your energy costs.

CCES can provide for you the technical portion of the advice to determine which federal and state air quality rules are applicable to you and the most cost-effective strategies to maintain compliance. Contact us today at 914-584-6720 or at

Quarterly Energy and Environmental News

July 2016

News affecting the US energy and environmental areas happens. CCES will keep you up-to-date on important issues quarterly. We may not cover every issue and jurisdiction. Make sure you work with a qualified professional to determine how such news affects your business and career. But we hope this will help keep you up with changing US trends.

Reducing Methane Emissions

The Obama Administration is entering its final months, and there is concern that they have not properly tackled all options concerning reducing greenhouse gas (GHG) emissions in response to climate change. While the focus has been on reducing CO2 emissions from fossil fuel combustion, it is understood that methane (CH4) emissions (21 times more potent than CO2) must be reduced, as well. There is a debate on how to do this. Recent technological advances, such as fracking, has encouraged conversion of coal and oil plants to natural gas, effectively reducing CO2 emissions. However, increased usage of natural gas means greater leakage and emissions of CH4 such that GHG emissions are not being cut significantly in total. While the Republican candidates for President have not discussed the issue, different factions of the Democratic Party have different strategies, ranging from a total ban on fracking to supporting fracking under certain conditions, such as minimizing water and CH4 leakage. The platform of the Democratic Party deals with this in compromise form, requesting minimizing CH4 leakage, requiring companies to publicly list the chemicals used in fracking, and banning fracking in communities or states that oppose it.

The Obama administration has pledged to reduce CH4 emissions from the oil and gas sector by 40 to 45% below 2012 levels by 2025, and has begun to draft standards for CH4 emissions through the Clean Air Act, although they will likely not become law until the next administration.

US Court of Appeals Delays Hearings on Clean Power Plan

The US Court of Appeals for the DC Circuit announced that it was delaying oral arguments concerning the Clean Power Plan until September 27 in front of the entire Circuit. The Clean Power Plan would establish federal standards for CO2 emissions from existing power plants. The timing is such that a decision by the full Circuit would probably be made after this November’s elections. Who becomes the new President may itself alter the landscape and breadth of the Clean Power Plan. The losing party to a Court of Appeals decision after Election Day would likely appeal it to the US Supreme Court which could hear arguments and rule by June 2017.

The Obama Administration and the USEPA believe they have the statutory authority to amend the Clean Air Act to include such regulations. Arguments against the Clean Power Plan include whether the USEPA exceeded its authority under the Clean Air Act to set CO2 emission standards that rely on emissions beyond a facility’s control (if other facilities combust high-GHG emitting fuels or use renewables). The Clean Air Act allows the USEPA to only regulate activities at the actual power plant to reduce emissions (e.g., efficiency improvements). The USEPA responded by stating that the Clean Air Act allows it to take “generation-shifting” measures to determine emission reduction targets.

Obama Administration’s Initiative for Solar for Low, Moderate Income Housing

The federal government announced in mid-July the Clean Energy Savings for All Initiative, aiming to increase the use of alternative energy by 10-fold in low and moderate income housing. See
The program aims to increase solar use by about 1 GW by 2020, covering about 1 million additional low and moderate income homes.

Key elements of the Initiative:

• New guidance to use Property-Assessed Clean Energy (PACE) financing;

• A “Community Solar Challenge” to award teams in many communities up to $100,000 in cash or technical assistance, to develop innovative models to increase solar installations and reduce low income communities’ electric bills;

• DOE will provide technical assistance to qualified low income housing groups;

• Solar-related job training for low- and moderate-income people; and

• Over 120 housing authorities, rural electric co-ops, power companies, and others in over 36 states have committed to investing $287 million for over 280 MW of solar energy projects in low- and moderate- income communities.

New NPDES Standards for Discharges from Construction

The USEPA is expected to shortly update its NPDES General Permit for Discharges from Construction Activities (GCP) to go into effect next year. The proposed updates to the GCP are intended to clarify current permit language and contain new requirements that non-stormwater discharges from external building washdown not contain hazardous materials such as PCBs, revise current effluent limits, require cover or other appropriate temporary stabilization for all stock or debris piles unused for 14 or more days, require waste containers to be closed or covered when not in use, and impose requirements on the demolition of structures exceeding 10,000 sq. ft. of floor space, which were built before 1980, to limit PCB-containing building materials entering stormwater.

We hope that this information is useful to you and your firm. Please speak to professionals in the appropriate fields before implementing any strategy or addressing any regulation. CCES can provide the technical advice to help you comply with a new environmental or energy regulation and to help you prosper as you do so. Contact us today at 914-584-6720 or by email at And feel free to comment on these articles or suggest topics of interest.