New Proposed Federal Commercial AC Efficiency Standards

On Sept. 18, 2014, the US DOE issued a proposed notice of rulemaking to revise the Energy Policy & Conservation Act (EPCA) with updated energy efficiency standards for commercial air conditioners ( A public hearing to discuss the proposed measures will be held at DOE Headquarters in Washington on Nov. 6.

The following table summarizes the proposed standards, which would go into effect 3 years after publication of the final rule in the Federal Register, estimated in late 2015. After the three-year period, no applicable unit can then be manufactured or sold in the US unless it meets the following energy efficiency standards:

Packaged AC or Air-Cooled Heat Pump (HP) ≥65,000 Btu/h to <135,000 Btu/h cooling capacity
AC Elec. resistance or no heating 14.8 IEER
All other types 14.6 IEER
HP Elec. resistance or no heating 14.1 IEER 3.5 COP
All other types 13.9 IEER 3.4 COP

Large Commercial Packaged AC or Air-Cooled Heat Pump (HP) ≥135,000 Btu/h to <240,000 Btu/h cooling capacity
AC Elec. resistance or no heating 14.2 IEER
All other types 14.0 IEER
HP Elec. resistance or no heating 13.4 IEER 3.3 COP
All other types 13.2 IEER 3.3 COP

Very Large Commercial Packaged AC or Air-Cooled Heat Pump (HP) ≥240,000 Btu/h to <760,000 Btu/h cooling capacity
AC Elec. resistance or no heating 13.5 IEER
All other types 13.3 IEER
HP Elec. resistance or no heating 12.5 IEER 3.2 COP
All other types 12.3 IEER 3.2 COP

IEER = integrated energy efficiency ratio; COP = coefficient of performance (for heat pumps).

The DOE presented an economic analysis where they believe the payback in energy cost savings on the additional capital needed to procure such energy efficient units will range from 2.2 to 6.6 years. Given the average lifetime of such equipment of 18.4 years, the building owner would realize a strong economic benefit. The DOE also estimates that the standards would reduce electricity use by about 1.3 trillion kWh.

CCES can perform an assessment of your building for the efficiency of your heating and air conditioning systems to determine if it makes economic and comfort sense to switch now to a new, more efficient unit. We can also help you improve your current system’s efficiency by evaluating your building for air leaks, poor insulation, etc. Contact us today at or at 914-584-6720.

Reducing Your Peak Demand for Electricity – Critical to Control Costs

Your operations – whether you manage one or several office buildings or industrial facilities – depend on electricity. You don’t have electricity, your company does not function. It’s as simple as that. Whether at home or at work, we are used to paying for electricity by how much we use (kilowatt-hours, kWh). Makes sense; you use it, you pay for it. But a new financial paradigm is impacting electricity cost and that is peak demand. On a hot summer day (and climate change will result in more such hot summer days), there is growing demand for electricity (in kW) as more buildings are being operated, with more space being air conditioned, plus more lights, laptops, and other electricity-using devices. Utilities know that reliability – getting electricity delivered in full – is expected. To reliably get electricity to all customers at all times utilities must grow their infrastructure, costing hundreds of millions of dollars or more annually – an expense that is difficult to recover. Also, with a number of coal-fired power plants being shut down at least in part because of stricter environmental and potential future greenhouse gas rules and nuclear plants shutting down because of age (and the high cost to build new plants), new electricity generation to meet peak demand may not be assured.

Therefore, there is a growing realization by utilities that it must get its customers to reduce peak demand, that period of just a few hours on a hot summer afternoon when demand is greatest. More utilities around the nation are encouraging customers to reduce peak demand to ensure complete electricity delivery and reduce the risk of a blackout, and are offering customers incentives to achieve real reductions.

In many parts of the US, facilities pay both usage and peak demand charges. The peak demand is based on the single 15- or 30-minute period during the month when you use the most electricity. It may be an outlier of your typical usage, but you are charged for it. Your goal is not only to reduce total usage, but also “shed” load during peak periods.

Many facilities are wisely looking into renewable energy to reduce electricity costs. This is terrific. If you can generate your own electricity and use less from the grid, you will save money. This is true, but only on the usage side. What if there is a single 15-minute period during a month when it is hot, your building is fully using all its laptops, AC, and lights, but it is cloudy (a thunderstorm coming) and your solar panels are not producing any electricity. Despite your solar investment, your demand from the grid for that short period will still be high and you would have to be pay the full high demand charge. Therefore, should you be considering the installation of solar PV or wind turbines, make sure to consider the existing demand charge as something that may not be reduced. Perhaps you can negotiate with your utility to reduce or eliminate your demand charge.

What can be done to reliably reduce your peak demand to reduce this charge?

1. Fully Understand Your Demand Charge. How much are you being charged for peak demand? What percentage of your electric bill is this? Is your demand charge based on your highest 15-minute period of demand during the entire billing cycle or is it for the peak period during the utility’s peak period of concern (often 2 pm to 6 pm)? The latter is called “coincident” demand, coinciding with the utility’s peak period to provide electricity. This is an important distinction and will influence your strategy to save costs.

2. Fully Understand Your Usage Throughout the Day. Make a reasonable estimate of your electricity usage throughout the day. Monitors can be purchased or leased to provide better accuracy. When might your peak demand occur? Software exists to track your usage and demand and may be worth purchasing and using. Such information can also help form an automated demand response program to determine best strategies.

3. Sensible “Behavioral” Changes To Reduce Peak Demand. Is it feasible to move certain operations to another time of the day – to an otherwise non-peak period? Might some workers be willing to work a non-traditional shift? Are there low-cost strategies to reduce your peak demand, such as shades on windows that get afternoon sun?

4. Feasibility of More Sophisticated Technologies. Given your demand charge and the growing number of incentive programs to decrease peak demand, it may be cost-effective to install and operate relatively sophisticated controls. One example is an expansion of what you may already have: using your backup generators to produce electricity during peak periods only. Yes, you will have to pay for gas or oil usage. But reducing that peak demand charge may make it worth it. Of course, you need to check and potentially modify your air permit to ensure that your backup generator can be used in such a non-emergency situation. But this can avoid grid electricity use and perhaps you can make a formal arrangement with your utility to sell it the excess electricity you produce for a profit. Another example is to automatically shift certain electricity-drawing operations to a short time before a peak period is coming up. To reduce electricity usage for air conditioning on those brutally hot days, systems exist to manufacture ice during the overnight hours and blowing air across the ice for cool air for the building. Electricity is used, but mainly at night (when the ice is being made), far from a peak period; little is used during the day. Also, look into batteries. Can excess power drawn at non-peak times be stored and used during the peak? Again, the economics of incentives and a reduced demand charge may justify such strategies.

Utilities around the country are either beginning to introduce or revving up peak demand charges in response to the pressure they are under to reliably deliver power during these periods. Reducing your peak demand will not only save you cost, but also provide you with greater flexibility and reliability. For most, it is worth investing resources for.

CCES has the experts to review and advise you on your energy costs and system, to help you gain the maximum financial benefits of both reduced usage and reduced peak electricity demand. Contact us today at 914-584-6720 or at

Bright Long-Term Outlook for Solar Energy

Solar energy as an option is no longer “pie in the sky” or “experimental”, but is now undeniably mainstream. CitiGroup has joined UBS, Deutsche Bank, Morgan Stanley, Barclays, and others in publishing predictions of a positive, long-term outlook for solar energy. According to the recent CitiGroup report here, solar will see continued growth in energy generation market share and will become more competitive with fossil fuels due to favorable economics, fuel diversification by utilities, and new financing structures.

The reports recognize the favorable economics of power developed by solar and predict that these factors will remain improve in the future. Solar manufacturing costs have declined significantly and energy efficiencies have improved. The reports recognize that solar is competitive in lower costs per energy unit. As the US economy recovers from the Great Recession and manufacturing makes a comeback, it will be recognized that most major new buildings and renovations should at least consider solar. Solar is also growing worldwide, in both industrialized and emerging nations. Even new construction in oil-rich Middle East includes solar PV in many instances. Finally, solar will benefit by the growing trend of distributed power or microgrids. Entities, such as corporate parks, industrial facilities, and neighborhoods can develop their own source of electricity, independent of the centralized grid, to continue to function in case of climate change effects or catastrophe. On-site solar PV can be part of many distributed energy plans.

Many states have rules mandating their utilities generate a certain percentage of their power from renewable sources. Many utilities also realize that this is good business practice to “spread the bet” among many sources of energy. The recent increases in cost of coal and its heavy regulation is certainly an example of a fuel that went from being among the cheapest to among the most difficult and expensive in a short period. There is even concern about how long natural gas will stay relatively inexpensive.
In the last decade of increased installation of solar PV, many government and financial institutions have implemented financing incentives for solar “farms” down to one-family homes. Capital is available to address start-up costs for production and installation.

The CitiGroup report believes that solar energy would conservatively represent 11.2% of all newly-installed generation in the US in the next few years, making it a permanent part of our energy options. This represents a trillion dollar investment and opportunity to grow. Solar and other renewable options are now mainstream and should at least be seriously considered in all new constructions and energy upgrades.

CCES has the experts to assist you in evaluating the sources of energy of existing or planned changes in your buildings and facilities. We can evaluate available financial incentives and estimate relative energy cost savings of a number of options, from updated technology to renewables and distributed power (microgrids). Contact us today at 914-584-6720 or at

More Energy Efficiency Tips for You to Use

by Jordan Jacobs, Industry Insights

Last month some simple, effective energy efficiency tips were posted for readers to use to save energy costs not only at their businesses, but at home, too. Jordan Jacobs of has some additional ones to share with you. Representing a technology company offering public and private cloud hosting services, Jordan wanted to focus on some of the ways that everyday technology consumption like email, social media, and data storage affects your and your company’s energy usage.

Electronic communications aren’t exactly carbon free. According to Mike Berners-Lee — professional carbon-emissions consultant and brother of the guy who invented the World Wide Web — every time you send an email into the ether(net), you’re using up 4 grams of carbon.[see footnote] And that’s if you don’t add any attachments.

OK, 4 grams doesn’t sound like much, and in the grand scheme of things, it really isn’t. But think about how many emails you send today, then multiply that by 365. That’s a lot. Basically, each year the average person emails emit an amount of carbon equal to the exhaust of a 200-mile car ride. All the emails sent scurrying around the Internet in a single day generate more than 44,000 tons of carbon per day! Now, this is not to say that email is a bad thing: it’s certainly better than sending all of those messages on paper in paper envelopes using sticky paper stamps. But there are a lot of ways to cut down on carbon by checking the number of emails that go whizzing by.

Stop replying to all. “Reply to all” works by sending duplicate emails to all the people listed in To: box. You are really sending separate emails to individuals, multiplying your carbon footprint at the same time. Before replying to all, take a quick moment to see if everybody on the list really needs to get your message. You’ll also avoid aggravating all those people who might otherwise ask, “Why the heck did you send me that?”

Don’t spam. Nobody likes to think they’re a spammer, but it happens. Even reputable companies with great products tend to carpet-bomb people’s inboxes with marketing messages that go mostly unread, in the hopes of finding just one new customer. Just because you can send an email to everyone doesn’t mean you should. Tailoring your audience help you increase conversion rates while cutting back on carbon.

Unsubscribe. On the flip side, if you’re receiving emails that you don’t have time to read, take a minute to remove yourself from the mailing list. It’ll help keep your inbox clean, and you can feel even better knowing you’re helping to trim your carbon footprint.

Start a conversation. We’ve all done it; emailed that person who is sitting close enough that you could literally talk to them without even raising your voice. Instead of sending that email, have a little chat. Even if they’re down the hall, get up and go talk to them. You’ll use less carbon by talking than you would by sending that email.

Less social media, more social awareness. Speaking of conversations, maybe email is not your thing. Keeping messages short and sweet — say 140 characters, a quick pic or a sentence-long status update — can’t really take up much carbon, right? Actually, that is right. The carbon footprint of a tweet is estimated to be 0.02 grams [see footnote] Facebook reported that the average user consumes about 311 grams (0.7 lb) per year.

Still, those calculations only take into account what’s happening on the company’s end. If you’re using your laptop, tablet, or smartphone to explore social media sites, chances are you’re also browsing a bit, seeing what your friends are up to, making comments, playing a game or two. That sort of thing. Let’s face it, most of that stuff is probably a waste of time — and a waste of carbon. There’s nothing wrong with using social media, but cutting back isn’t a bad thing either. While reducing social media usage isn’t going to stop global warming on its own, every little bit help. Here are a few thoughts:

Cloud your data. With the rise of cloud computing, you can reduce your personal carbon footprint by relying on the economies of scale that cloud storage provides.

While data centers do use a lot of energy, our company has managed to reduce our own carbon footprint is by installing LED lights, taking advantage of cool-weather conditions, and making strides in server virtualization, which helps us run our processors at peak efficiency. It’s worth asking yourself whether you’re wasting energy, space, and money by keeping your servers on site.

Climate change won’t be solved by any single person, company, or even government. It’s going to take a lot of people all over the world working together to understand how their everyday activities affect the environment. We at SingleHop believe that most people are not merely mindless consumers of technology, but want to use technology to make connections with others so they can live richer, more fulfilling lives. In the end, it’s about awareness. Hopefully this post has helped you learn more about a few of the ways you can make small strides in reducing carbon consumption through technology.

Berners-Lee, Mike. “An email.” How Bad Are Bananas? Vancouver: Greystone Books, 2011. EPUB file.
Bellona, David and Tash Wong. Tweet Farts. Accessed Aug. 7, 2014.
“Carbon & Energy Impact.” Facebook. n.d. Web. Aug. 7, 2014.
Wilson, Jacques. “Your smartphone is a pain in the neck.” Sept. 20, 2012. Web. Aug. 7, 2014.
Wortham, Jenna. “Feel Like a Wallflower? Maybe It’s Your Facebook Wall.” The New York Times. April 9, 2011. Web. Aug. 7, 2014.


U.S. Is Low in International Energy Efficiency Rankings

A recent ranking by the American Council for an Energy-Efficient Economy places the US 13th out of the 16 largest world economies in energy efficiency. ( Germany was 1st, followed by Italy. Even developing countries like China and India, where power failures are common, ranked higher than the US. Only Russia, Brazil and Mexico were worse.

Why did the US rank so low despite our high level of education and entrepreneurship? The US is one of only two nations on the list with no national energy or GHG emission reduction plan and is very dependent on centralized sources of electricity and heat, and thus the high inefficiencies in power transmission. US industry uses comparatively little combined heat & power (CHP). Finally, the US transportation sector is poor because of our overall poor fuel economy and relatively high miles traveled per vehicle per year. Per capita, US mass transit serves fewer people than in most other nations considered.

This has many financial implications. The US is losing a lot of economic opportunities. While American business is quick to lay workers off to improve labor efficiency of performing tasks, there is not the same attitude to reducing energy to improve economics. Not only does this represent a great opportunity for direct cost savings (money in the bottom line rather than an energy supplier’s pockets), but it saves on natural resources, provides greater operational flexibility, and lowers transit costs.

What can be done to make the US more energy efficient as a nation? The biggest issue may be that US energy efficiency efforts are inconsistent. Different states and even cities and counties have innovative programs to improve energy efficiency, such as new building codes and financial incentives to become more efficient, while many states and even areas within states have no such rules or programs; large contrasts exist. There needs to be national energy efficiency standards and incentives. Ironically, one of the few national programs, EPAct (IRS Code No. 179D) expired Dec. 31, 2013, and while both parties say they wish to extend it and even strengthen it, it has not happened yet.

Absent of a new national energy policy (which is unlikely based on the recent actions of Congress) some improvements may be gained through future GHG regulations. A very effective way of reducing GHG emissions is energy efficiency – using less GHG-emitting fossil fuels for work that needs to be done. Implementation of new rules can improve energy efficiency. In addition, greater spending for mass transit systems should reduce the number of cars on the road, improving efficiency and reducing traffic, too.

CCES has the experts to help your entity become more energy efficient, evaluating your production processes, your general use of energy (buildings), and for your fleet of vehicles. We have documented success in saving significant costs for many entities. Contact us today at 914-584-6720 or at

Window Film As A Cost Saving Measure

In most energy audits, replacing old windows with modern, double-pane, low-e units is an effective way to reduce energy loss, yet allow light in to bring in warmth in the winter and to reduce electricity use from artificial lights, particularly with workers around. The problem is that modern windows are usually fairly expensive, and therefore, have a longer payback than most other energy conservation measures. An alternative way to save money is to place a film inside your existing windows to improve insulation. Effective window film is usually made for clarity, tensile strength, and stability.

While window film can succeed in reducing fuel and electricity use, for a relatively cheap cost, be aware of the following items you may need to check pertaining to window film:

• Window integrity. Should your building have old, single pane windows, window film can enhance their insulation properties. However, window film cannot improve or cover over any structural deficiencies. If existing windows are cracked or if the surrounding brick needs upgrading, well, window film will not help. Before installing window film, make sure existing windows are inspected and upgraded should there be cracked panes or areas needing caulking.

• Drafts and pressure. Window film does not have the integrity of a window or a wall to keep out air, particularly from high winds or from high pressure differences. Before installing window film, make sure leaks are sealed and the building space is balanced. Anticipate air leakage during major wind events.

• Moisture. Window film is generally not effective at keeping moisture from moving, particularly in areas where window seals or frames are ineffective. Keep an eye out for condensation or other reasons for moisture buildup on walls, particularly on higher floors and in corners.

If your windows are not very old and of a strong structural integrity, window film may be a cost-effective way to improve energy efficiency and to allow workers to be more comfortable. However, if your building and its windows are old and damaged, it is critical to inspect all windows and to either invest in efforts to improve the structure of your windows (caulk or replace cracked pane) before installing window film or replace the windows altogether. It may be that a certain portion of your building has sustained more damage than others and window film can be more effective in certain parts than others.

CCES has the technical experts to help you assess your energy profile and develop and implement a variety of reliable energy conservation measures to save you energy costs, reduce maintenance, and make your staff more comfortable and productive. Contact us today at 914-584-6720 or at

Optimizing Your Energy Audits

According to a 2012 Lawrence Livermore Laboratories study, the US wastes about 61% of the energy it uses. Yes, more than half! The US wastes more energy than the UK uses! Such energy waste costs the US hundreds of billions of dollars in capitalized asset value and reduces profits of US businesses by many tens of billions of dollars.

Even if your buildings and operations are doing better than average, there is likely a lot to be gained from a thorough review of energy usage. If an energy audit has not been performed in the last 4 years, then there is much to gain as new proven energy technologies have advanced so much since then. There is an excellent chance that a thorough audit will reveal multiple upgrades with significant financial benefits for you.

But the key is not just doing an energy audit, but doing it right. You need to not only use technical experts, but also those that understand your business goals and expectations.

Here are two items, often made available, you want to avoid:

Free Energy Audit. In some places, entities offer free energy audits. Well, ultimately you get what you pay for. I was once approached by a utility to perform free energy audits. The pay was terrible, and I turned it down. The only people who would do these had to be people (non-engineers?) with little or no experience. Is that what you want to base financial decisions on? Also, free energy audits are often actually sales calls, ignoring some energy usage areas and only focusing on their sales areas. A thorough audit covering all major energy usage areas that is product “neutral” will serve you best.

Here’s another story. A corporation once asked me to prepare a proposal to perform energy audits of all of their approximately 30 diverse facilities. We estimated a cost of just over $100,000, and we decided to be bold and estimated that the audits would likely save them cumulatively about $3 million per year in energy costs. Well, the company decided to decline the proposal but mandated each facility to have performed a free or cheap energy audit. Well, needless to say, this became a problem.

“Virtual” Audit. Some companies claim they can perform a useful energy audit without ever setting foot in your facility. Just provide a year’s worth of energy bills, model numbers of all equipment, and some building drawings and they can do it. While this may work for benchmarking (developing an EnergyStar rating), there is no substitute for actually walking through the facility, going up on the roof, going to the boiler room, etc. The experienced auditor needs to see how energy is used. Perhaps the most valuable information is just from talking to facilities workers, who can tell stories about the building or equipment that even management may be unaware. Again, you don’t want to make financial commitments based on data obtained without several walkthroughs.

Yes, the best way to maximize your financial benefits is with a thorough engineering study, run by professionals. Not only can good energy saving strategies be identified, but it can be done not favoring one vendor or another, better ensuring success and competition for providing the upgrade, maximizing financial benefits. Such a top-notch energy audit also may result in additional training (formal or not) for staff to operate equipment more efficiently – for you to get your money’s worth out of the equipment you have purchased.

Here are things to look for to develop the best energy audit for you:

Communicate boundaries and goals. Before the energy audit begins, a building owner or manager should communicate to the auditor what you wish to gain plus any restrictions. Maximize financial benefits? Improve the look? Just focus on one area (lighting only? HVAC only?)? Only focus on strategies with a payback of less than X years? Etc. This enables the auditor to use time more effectively to meet your goals.

Prepare for multiple site visits. Pre-set a date or dates for the site visit(s). Make sure that the facility manager is available to escort the auditor around and have at the ready information the auditor may need (drawings, equipment brochures, etc.). I once performed an energy audit and the facility manager kept me waiting over an hour. Then when he came to me, he shook my hand, told me to walk around anywhere I wanted, and quickly left. While emergencies can occur and it is thus understandable when the manager must leave the auditor, initial plans should be held to as best as possible.

Go deep into developing many energy conservation measures. The auditor should not only develop many “ECMs”, but should develop for you not only the direct financial cost of the upgrade and cost savings, but also each one’s secondary benefits. For example, LED lights not only save significant electricity cost, but last much longer than T12s and others, meaning building maintenance staff gain flexibility to work on other tasks and also take fewer trips up the ladder (reducing accident risk). Similarly, some upgrades enable workers or customers to be more comfortable, raising productivity and even sales. While hard to quantify, other benefits like these should be accounted for.

Communication. It is very important that a thorough report of the energy audit be prepared. Make sure the auditor does this. The style of the report can vary based on the company’s standards, but it should at least provide background, a description of the current building and energy equipment, the current energy profile, and a full description of all ECMs. Work with the auditor and address potential issues of interpretation by upper management. I once performed an energy audit with ECMs and the facility’s general manager was very upset at me. He felt that the way the report was written listing many areas of potential improvement made him look like he was not managing his property well. So don’t take offense, and work with your auditor so that the report is not taken as an indictment of anybody. In reality, technology changes so rapidly that there are always many areas to improve; the emphasis being cost savings.

CCES has the experience to perform any type of energy audit from ASHRAE Level I through III. We are always looking for ways for our clients to maximize the financial benefits of all energy upgrade strategies. See the benefits yourself. Contact us today at or at 914-584-6720.

Business Practices Are Being Watched By Outsiders

Companies are under growing pressure from outside advocacy organizations to improve their practices, not only in their products’ image, but even in their supply chain and how products are made. We have been in a globalized economy for some time now, as companies have outsourced manufacturing to or obtain raw materials from farflung countries, which not only do not have environmental, safety, and labor laws nor enforce them like in the US, but actually offer incentives to lure them over, such as tax breaks and very cheap labor. Another lure is that by doing much production work overseas, it would be beyond the ability of watchdog groups to watch.

But some have done just that. One of the first examples 2 decades ago was Nike, who underwent much criticism of the underage and underpaid labor used to produce Air Jordans and other brands, not to mention the unsafe conditions and equipment used. Now more advocacy groups are able to spend more time investigating a wide variety of companies. In addition, the ease in documenting and publicizing supposed misdeeds through social media has resulted in the greater potential for bad publicity for a variety of consumer brands to occur in a short amount of time.

Much of this exposure has moved into the environmental and sustainability areas, as standards for the derivation and use of energy, minerals, water, food, chemicals, and others have been scrutinized and publicized. Environmental and business practices have never been so closely reviewed and publicized by outsiders ever.

What is a company to do? A company’s reputation with its consumers is of extreme importance in this age of almost instant publication of information. A company must know that its upstream suppliers, retailers, investors, and the public all be satisfied that operations, once thought to be private, are not embarrassing in any public way.

Therefore, companies need to take a deeper look into how they manage their water, energy, resources, and environmental impacts, as well as labor and social issues, so they are beyond reproach by an external group and beyond demonization. This can best be achieved by a thorough external review of processes.

Companies must adapt to a new world of being able to research in detail many procedures thought of as beyond review and the ability through social media to publicize any perceived failings in hyperspeed. A thorough review and optimization of processes that are positive for sustainability will only make such companies look better.

CCES has the experts to help your company or entity perform detailed reviews of environmental and sustainable procedures and can make recommendations to make your program more robust and beyond reproach. Contact us at or at 914-584-6720.

Proposed Revisions To Fed. Risk Management Program

On July 31, 2014, the USEPA published a Request for Information (RFI) to seek comments on potential revisions to its Risk Management Program (RMP) regulations.


Also see Executive Order (EO) 13650: Improving Chemical Facility Safety and Security. The EO is intended to enhance safety and security at chemical facilities and reduce the risks to all potential affected parties (workers, public, etc.) associated with a hazardous chemical release.

RMP (Section 112[r] of the Clean Air Act) was created in the 1990’s in response to deadly accidental chemical releases in Bhopal, India and Institute, WV. The goal of RMP was to prevent major chemical accidents from causing disasters by establishing a prevention and response program. All facilities that store or use a regulated chemical at or above threshold levels are regulated under RMP. Now that over 20 years have passed since its original inception, the Presidential EO asks whether the program needs to be upgraded, particularly to meet new security (9/11) concerns since its origination.

EO 13650 requires the USEPA and OSHA to review the chemical hazards covered by their existing risk management programs and develop options to improve them. OSHA issued an RFI on potential changes to its Process Safety Management (PSM) standard on December 9, 2013. The USEPA’s recent RFI coordinates with the potential changes to OSHA’s PSM program for accident prevention measures.

The USEPA is considering potentially updating the list of RMP-regulated substances, and adjusting their threshold quantities and toxic endpoints based on up-to-date toxicity research. The RFI seeks comment on potentially changing several existing process safety procedures under RMP including compliance audits; equipment maintenance; management of change; emergency response capabilities; and incident investigation. It also seeks comments on potential additional risk requirements, such as mandatory use of safer technologies; process safety metrics; automated monitoring of releases; emergency drills; stop work authority; and siting risks.
Public comments and other submittals for the RFI, EPA–HQ–OEM–2014–0328, are due on October 29, 2014. They may be submitted by mail or online:

CCES can help your facility determine compliance with the current RMP rule, assist in making your compliance program more streamlined and effective, and in assessing the effects of any future changes to the program to your facility for effective planning. In addition, we can help you assess all of your potential air emissions, as well. Contact us today with any questions at 914-584-6720 or at

Pres. Obama Announces Climate Change Initiatives

President Obama announced a series of climate change initiatives on July 16, 2014 aimed mainly at improving the nation’s ability to withstand adverse physical effects of climate change (adaptation), such as safeguarding electricity production and transmission, improving flooding, erosion and storm surge planning, and better managing landslide risks. A Fact Sheet describing the initiatives:

These actions were among the recommendations of the President’s State, Local and Tribal Leaders Task Force on Climate Preparedness and Resilience, a group of 26 officials who have worked since November to develop the proposals.

One of the recommended projects involves safeguarding the nation’s power supply during climate catastrophes, such as extreme storms damaging power infrastructure and lines and hotter weather resulting in greater surges in demand that the system may not be able to currently meet. The Dept of Agriculture awarded $236.3 million to 8 states to improve electricity infrastructure in rural areas.

Addressing another recommendation, the US Geological Survey and other federal agencies said they would spend $13.1 million to develop advanced 3-dimensional mapping data available to any municipality to provide information to draft strategies in response to weather-related disasters.

The Centers for Disease Control and Prevention released a guide titled “Assessing Health Vulnerability to Climate Change” ( to help identify health hazards that might be caused by climate change.

These new initiatives are part of a broader White House strategy to address climate change. Besides these initiatives to prepare for adverse physical climate change effects, the White House wishes to become a leader in reducing GHG emissions to lessen climate change impacts. It issued an Executive Order to support a USEPA plan directing states to submit proposals to reduce GHG emissions from coal-fired power plants. The plan is expected to reduce demand for coal, spur growth in the usage of natural gas for power (which emits much less GHGs than coal per Btu), and foster research into reducing GHG emissions from coal combustion.

CCES has been researching and is qualified to consult in ways for you to adapt to future climate change effects. Lessen the damage and negative business impacts on you of severe storms, drought, and extreme hot weather, and also enable you to bounce back (be resilient) faster. We can help you survive and thrive. Contact us today at 914-584-6720 or at