Interest In New Gensets Is Growing

The number of facilities choosing to generate their own electricity using generators or “gensets” is growing. Companies are recognizing that the physical and business impacts of even one severe storm can undo all the planning a business does and even wipe out or severely hurt the business. In addition, with the acceptance of climate change as real the chances of a severe storm impacting a facility will rise in the future. A facility having its own secure source of electricity independent of the grid and its wires and vulnerable infrastructure can better ensure that basic functions can be maintained in a storm, saving personnel and processes and having electricity to maintain operations during such events. As a result, the genset market has been growing.

Part of this growth is due to another phenomenon, some utilities provide financial incentives for facilities to procure and operate gensets to relieve them as they are unsure of reliable power and don’t want to hurt key users in their area. In addition, several such programs require the genset operator to go off the utility’s grid and operate the genset for distinct periods during peak demand periods (hot weather) to relieve pressure on the grid. These programs, often called “Demand Response” or DR, can be lucrative for facilities. The utility pays most of the capital cost of the genset, the facility fully owns it, and they get paid a fee each time a DR event occurs and a genset is used.

One complication of such programs, however, is environmental. The federal Clean Air Act, followed by nearly all states, specifically exempts from permitting and meeting emission standards gensets that are used only in emergencies (this includes the necessary regular exercising of a unit). However, once a facility uses a genset in a DR program, this exemption goes away. Therefore, facilities entertaining joining a DR program must set aside budget and effort to obtain the proper air permit (or modify its existing one) and comply with any applicable emission standard. Nitrogen oxide (NOx) is the most common pollutant that is regulated. If the NOx emissions of your genset exceeds the regulatory standard, it may be necessary to retrofit the unit with Selective Catalytic Reduction (SCR) or equivalent technology. The cost of such a retrofit can approach 6 figures. The USEPA designates models as meeting certain “tiered” standards. Tier 4 gensets are the most advanced and will likely currently meet all applicable emission regulations. Tier 3 gensets probably meet most of them. Tier 2 units probably do not meet many of them, again, if applicable. So if you are procuring a new genset, look to invest in a Tier 4 which should meet all applicable NOx emission standards. Particulate matter (PM) is sometimes regulated, too. A sure way to meet any PM standard is to combust natural gas, not to mention it is currently cheaper than oil. Natural gas-fired gensets are particularly selling well these days.

Finally, another variation of the genset that many facilities are considering is combined heat and power or CHP, where both steam and electricity are produced by the unit. The improvement in efficiency can save significant fuel costs. It is important for an experienced engineer to evaluate whether your demand for both steam and electricity and when the demand occurs will make CHP a good investment.

CCES can help your firm determine whether a genset or a CHP can be beneficial for you, as well as manage its procurement, installation, testing, and use to maximize the financial benefits. We can determine likely financial costs and savings. We can perform the needed environmental permitting and determine whether it meets existing applicable emission limits. Contact us today at karell@CCESworld.com or at 914-584-6720.

Underevaluated Source of Energy Usage: Plug Load

When a building owner or manager calls for an energy audit, they are usually looking for ways to upgrade lighting, HVAC, insulation or windows to save energy. The big items. Technology has improved markedly in recent years in these areas to justify upgrades resulting in significant energy use savings.

However, one area that is sometimes overlooked in an energy audit is plug load. According to the US Energy Information Administration, plug load can comprise up to 30% of total energy consumption of a commercial building. It should not be neglected.

Plug load is energy demand (almost always electricity) from devices plugged into electrical outlets (one notable exception is a stove/oven, plugged into a supply of natural gas. These devices include computers, speakers, printers, monitors, scanner, copiers, chargers, TVs, space heaters, fans, refrigerators, microwaves, coffee machines, vending machines, task (desk) lighting, and others. These are mainly small items and taken for granted because they are so commonplace. However, while each item may draw less electricity compared to a large AC, cumulatively they can use significant energy and if not properly planned and controlled, can impact your energy costs.

3 Things You Can Do To Lower Plug Load Energy Costs

Use Efficient Equipment

While these may be “small” items one just “runs in” and purchases quickly, there are differences in energy use among similar equipment. The USEPA and USDOE have a joint program called “Energy Star” which compares many plug load items. Brands that are Energy Star-certified generally use at least 20% less energy (usually, electricity) than the average for the item, yet performs the same. Such items have an Energy Star logo displayed prominently on the equipment and box. A McKinsey study lists different strategies to reduce GHG emissions (usually matched with energy reduction), and puts plug load programs like Energy Star at or near the top in terms of economic effectiveness. See page 5 of the report from: https://www.mckinsey.com/business-functions/sustainability-and-resource-productivity/our-insights/impact-of-the-financial-crisis-on-carbon-economics-version-21. Many Energy Star products may be a few more dollars (or for larger equipment, $50) more expensive than the average one, but the energy savings will pay back that extra upfront cost very quickly, normally in just a few months. And then the savings for the rest of the time you own the equipment is “gravy”.

Another advantage of Energy Star is that it is an energy cost saving approach that does not rely on engineering or any kind of “work.” It is simple: a change in policy by Purchasing to purchase only Energy Star products allow you to lock in cost savings.

Controls

Smart controls allow you to program equipment for, say, “sleep” mode during certain hours or off altogether. For example, software can turn a vending machine’s lights and refrigeration off or reduce them slightly during non-office hours to save energy, yet keep food fresh. Sensors can turn off computers or lights when not in use. Make sure controls can be overridden, when necessary. This allows you to keep energy from being used when not needed, yet does not involve daily manual efforts to do so, which rarely work.

Raise Awareness

Make sure your employees/residents understand the importance of plug load as contributing to energy costs, which affect their costs as employees and renters. In time, they will be motivated to turn off equipment when not in use, saving energy. And they’ll do so at home, saving them costs, as well.

CCES can help your building or company review and analyze your energy use, including equipment, software controls, and operations with the intent of finding common sense and technological solutions to enable you to save significant energy costs while enhancing productivity. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Growing Proof That Improved Indoor Quality Results in Healthier Occupants

Harvard University scientists recently published an article in the journal Building and Environment summarizing 30 years of public health research demonstrating that improved indoor environmental quality directly results in better health outcomes. “The Impact of Working in a Green-Certified Building on Cognitive Function and Health” by MacNaughton, Satish, Laurent, Flanigan, Vallarino, Coull, Spengler, and Allen, Building and Environment 114 (2017) 178-186

One recent research project utilized 109 participants from 10 buildings in 5 different US cities that met ASHRAE Standard 62.1 (2010) ventilation requirements and had low indoor total volatile organic compound concentrations. In each city, buildings were matched over time by tenant, type of worker, and work functions. Buildings were distinguished concerning whether they had achieved green certification. Workers were administered a cognitive function test of higher order decision-making performance twice during the same week while indoor environmental quality parameters were monitored. Workers in green-certified buildings scored 26% higher on cognitive function tests, controlling for annual earnings, job category and level of schooling, and had 30% fewer sick building symptoms than those workers in non-certified buildings.

These outcomes may be explained by a number of indoor environmental quality factors which certified green buildings must meet, such as temperature control and lighting. However, the findings suggest that the benefits of green certification standards go beyond measurable environmental quality factors. The researchers have given the name “buildingomics” to describe the holistic approach for examining the complexity of factors in a building that influence human health. They believe further research will identify how these different factors lead to positive cognitive and health results.

In response to this growing trend, the USGBC has recently developed and issued new building standards to maximize indoor environmental quality known as WELL. The first buildings are being evaluated for whether they meet WELL standards and the first practitioners are studying for and becoming accredited as WELL professionals. See: https://www.wellcertified.com/

CCES is growing our expertise about WELL, as well, and can provide for you information about the standards and be able to provide insight and perform a study to demonstrate whether your existing or planned building meets WELL standards and, if not, what can be done to meet the WELL certification standards, including estimated costs to achieve WELL, and to maximize the health and financial benefits of WELL certification. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Update on Energy – October 2017

October 2017 has been an eventful month in US energy news.

Trump Administration Takes Steps to Repeal Clean Power Plan

On October 10, the Trump Administration’s USEPA submitted a proposal to repeal the Clean Power Plan (CPP), which mandates 32% reduction in CO2 emissions by 2030, undoing a signature achievement of the previous administration. The proposed change would repeal the CPP entirely, not just the portions that the Administration disagrees with. While the agency has said it will submit a future ”carbon” rule, it did not give any details of when that might be. Therefore, many think this represents repeal, but not replace, of CPP. While some commentators believe the CPP usurps the rights of states to regulate energy and would force a shift from coal, others say that CPP does provide states flexibility on how to comply with the greenhouse gas (GHG) reduction requirements. Even USEPA Administrator Scott Pruitt acknowledges that GHGs must be regulated due to the “endangerment” rulings made by the Supreme Court in 2007 and 2014; greenhouse gases meet the legal definition of an “air pollutant”, and the Clean Air Act requires its regulation to reduce emissions.

However, the impact of a repeal of CPP, if it survives the inevitable lawusits, is hard to determine. The US has already succeeded in reducing GHG emissions by 13% in the last 9 years, mainly because of a shift from coal to natural gas and growth in renewable energy (both due to market prices). Certainly more and more companies are learning that using cleaner fuels and energy conservation result in major, multiple financial benefits. The recent major storms, some of which were acknowledged to be exacerbated by Climate Change, impact businesses. Between these two, it will be interesting to see how business interests react to the potential elimination of the CPP and disincentives toward clean and renewable power.

USDOE Directs FERC to Issue Rules Supporting Nuclear, Coal

On September 29, USDOE Secretary Rick Perry directed the Federal Energy Regulatory Commission (FERC) to undertake rulemaking to enable generation assets in regional transmission organizations and independent systems operators to receive payments for reliability and resiliency benefits viewed as uncompensated under current market rules. If adopted, the proposed rule would provide revenue to coal and nuclear generators by allowing cost-based recovery, independent of normal market forces counteracting market forces that have recently have exerted significant downward pressure on rates. Coal producers and nuclear facilities would receive payments just for being “there” in case of an emergency, even if they are not used to supply a utility with electricity. Secretary Perry considers this a security issue, as making coal and nuclear sources more viable would raise the reliability of the US’s electric grid in case of market changes and its resiliency in case of severe storms or conditions. Others feel that this is a way to support the coal and nuclear industries; pay fees for not producing electricity. The proposed rule must be implemented by FERC, not USDOE; thus, it may take some time to go into effect.

Utility-Scale Solar Costs Fell 29% Last Year

A recent National Renewable Energy Laboratory (NREL) report showed that utility-scale solar costs fell 29% last year to roughly $35/MWh. This continues a trend as utility-scale solar power purchase agreement (PPA) costs have dropped nearly 75% since 2009. The report can be found: https://www.nrel.gov/docs/fy17osti/68925.pdf. The USDOE Laboratory based its study on 189 PPAs nationwide totaling nearly 11,800 MW. The cost decline is attributed to lower equipment component costs, improving efficiency of converting sunlight to electricity, and lower labor costs. The NREL study indicates that USDOE’s SunShot Initiative (https://energy.gov/eere/sunshot/sunshot-initiative) has already reached its 2020 cost target for utility-scale solar systems three years early. The report offered that the rate of cost reduction is declining; however, the growing flexibility given by new battery storage projects attached to utility-scale solar will only grow utility-scale solar project’s value.

CCES can help your company with technical issues concerning energy whether it be how to maximize financial benefits of being more energy efficient and how to have your energy system serve you more reliably and resiliently. Contact us today at 914-584-6720 or at karell@CCESworld.com.

U.S. Climate Change News October 2017

Trump Administration Takes Steps To Repeal the Clean Power Plan. On October 10, 2017, USEPA Administrator Scott Pruitt submitted to the Federal Register proposed legislation to repeal the Clean Power Plan, President Obama’s signature legislation to significantly reduce U.S. greenhouse gases (GHG) by developing stringent GHG emission standards for power production. As coal-fired power plants cannot reasonably meet these emission standards. The USEPA believes it is unfair to have legislation to target a particular fuel type, and began the repeal process to encourage growth in coal usage from U.S. mines. This is quite controversial as coal, a high emitter of GHGs, as well as other and toxic compounds, is still a major source of energy in the U.S. electric industry. By encouraging coal production and use, the U.S. would be hard-pressed to meet the Paris Climate Accord goals, although President Trump has already announced that the U.S. will leave the Accord anyway. In addition, much has been written that this move may make little difference, as other economic factors makes coal a non-ideal choice as a fuel for a utility (see below), such as the declining cost of building and operating a renewable plant. The public has 60 days from initial publication in the Federal Register to comment after which the USEPA must respond before making the repeal official.

States, Cities And Private Businesses Put U.S. Halfway To Paris Climate Accord Goal. According to a study released on September 25 by New Climate Institute and the Climate Group, efforts to address climate change by states, cities and corporations have already put the U.S. halfway toward its Paris Accord climate goal despite the current Administration’s attempt to reverse recent federal efforts. The study estimated that such efforts will cause GHG emissions to drop by 12-14% below the 2005 baseline by 2025. The study, based on certified data from the Carbon Disclosure Project, found that U.S. private sector commitments were the biggest factor in reducing GHG emissions. The decline in emissions are being caused mainly by these commitments of switching from fossil fuel combustion to renewable power.

First State-Wide, Economy-Wide Carbon Tax Is Proposed. Earlier this year, a bill was introduced in the Massachusetts House and another in the Senate that would establish a tax on fossil fuels with the goals to reduce GHG emissions and return the proceeds to consumers and businesses. https://malegislature.gov/Bills/190/H1726. Both bills would impose an initial tax of $10 or $20 per ton of CO2 emissions, rising to $40 per ton in the future. Several years ago, the USEPA estimated that the cost of a ton of GHG emissions was about $42 per ton, which was why they chose this endpoint. It was understood it needed to be approached gradually. Both bills require refunding of some or all of the tax proceeds to households and businesses.
It is estimated that should either bill become law the price of gasoline and heating fuel in Massachusetts would eventually rise by about 35 cents per gallon. The bills contain rebate programs to incentivize energy efficiency, rewarding businesses or households that reduce energy usage per employee (or member), not just energy usage as a whole.

Currently, Massachusetts enforces GHG reduction rules targeted to power plants. However, with electric generation comprising just 28% of GHG emissions in Massachusetts, legislators felt it was time to regulate other sectors, as well, particularly, the transportation sector, which accounts for about 30% of statewide GHG emissions.

While certain business groups are concerned about competitiveness and disproportionate impacts, the bills have many co-sponsors. Therefore, it is likely that some such bill will pass and with a sympathetic governor, a carbon tax would become law in Massachusetts, perhaps signed in 2018, going into initial effect in 2019.

CCES has the technical experts to help you assess your energy needs and help you be more energy efficient, which has many financial benefits, including preparing for future carbon taxes or monetization of GHG emission credits. Contact us today and we can help at 914-584-6720 or at karell@CCESworld.com.

Breathe Easier: What To Do About Indoor Air Pollution By Jackie Edwards

If you think about air pollution, your mind conjures up images of smog, fog and busy city streets. You don’t necessarily imagine that your home or workplace could be a major perpetrator of pollution, that could actually be one of the main factors contributing to conditions like asthma, COPD, and even skin problems such as eczema and psoriasis. It is estimated that the indoor air we breathe could be between two and five times more toxic than the air we breathe outdoors. Given that productivity loss due to sick time off is a growing issue for workplaces, how did it get to be such a problem, and how can we address it?

Household items are part of the problem

While the main causes of indoor air pollution are combustion related, one only need to look deeper into the home or office to find more surprising causes of such issues. Items such as furniture, carpets and flooring, and personal care products – everything from shampoos and hairspray through to air fresheners and cleaning products. https://www.budgethomeservices.com/the-air-in-your-home-is-dirtier-than-outside-and-what-you-can-do-about-it/

They all have the potential to contribute to indoor air pollution.  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3018511/

Air pollution explained

The USEPA rates outdoor air pollution using a scale on the Air Quality Index, or AQI. The levels are registered as follows:
Good = 0 to 50
Moderate = 51 to 100
Unhealthy for sensitive groups = 101 to 150
Unhealthy = 151 to 200
Very unhealthy = 201 to 300
Hazardous = 301 to 500

Outdoor air in most urban places in the U.S. falls in the 100-150 range.

At risk groups

Unsurprisingly, it is children and the elderly who are most at risk from indoor air pollution, as active children breathe in more (polluted) air per body weight than adults and seniors have weakened defenses. Conditions like asthma are the ones that are more likely to keep children out of school than any other. Mold and mildew in damp classrooms can also contribute to indoor air pollution and breathing difficulties.

Similarly, the elderly can also be troubled greatly by chronic breathing problems, that are contributed to by unclean air, particularly if they live in sheltered accommodation or are living in a care home where heating has to be on to a high level and at all times of the day.

But even working age adults are vulnerable to illnesses caused by indoor air pollutants and could lose significant time at work or suffer pre-mature death if not addressed.

How do we address these issues?

One of the key ways to help solve these issues is proper and adequate ventilation throughout the home or workplace. Keeping doors and windows open or on a vent facility to keep air circulating all the time can be of real benefit. While commercial buildings are designed for a constant ventilation flow, sometimes such systems do not work or are not optimal. https://www.epa.gov/indoor-air-quality-iaq/improving-indoor-air-quality

However, that’s not the only thing you can do:
• Make sure any appliances that are flammable are adequately ventilated.

• If you have a clothes drier, make sure there is no blockage and it ventilates the dust outside rather than inside.

• Storage of chemicals, paints, inks, garden poisons, and kerosene or gasoline should be kept strictly away from where workers spend the most time or any living quarters, preferably locked in a safe space outside.

• Try not to overuse candles, smoke indoors or the grill on your oven

• After you’ve bathed or showered, open your windows and keep them like this for at least forty-five minutes, but preferably longer.

• Adding air filters to bedroom spaces can make a difference to people at both ends of the age spectrum who suffer from breathing problems, as can installing a professional HVAC system to your home.

Why Energy Should Be Incorporated As Part of Your Company’s Strategy

It’s approaching the end of the year, which means self-evaluation of your company. What went well; what did not. What can be changed or should be incorporated to ensure growth moving forward? Historically, companies focus on sales and profits. Look at the headlines in major business journals: “XYZ Reports Auto Sales Jumped by X% In 1 Year”, etc. Expenses are pretty important, but the one that most companies seem to focus on is labor, as in how can it be lowered (lay off workers, increase automation, etc.). While companies cumulatively spend billions on energy annually, that expense is considered a fixed expense with little need for managing. This is a mistake. Companies can reduce energy costs and at the same time reduce risk and improve resilience.

Energy should be more important to a corporation given the fixed supply of it and issues involving regulations due to environmental, climate change, and business trends. Companies can now make choices about its energy sources and usage that it could not have made before with impacts on profit, costs, and flexibility. This is exemplified by the shift in the U.S. from traditional industrial manufacturing to more IT, cloud-based services by corporations, where energy costs can be a potential deal breaker.

Sources

Companies now have many more options of where energy comes from than before. A major new force is renewables. Solar, wind, hydro have been around for a while, but major technological advances now make building an operating a solar PV farm comparable to purchasing electricity from the local utility or running your own cogen. With the growing number of states who want to achieve a higher percentage of power derived from renewables and utilities wanting to get more facilities to become independent because of infrastructure concerns, incentives exist to sweeten the pot even more if one wants to invest in renewable power.

Another approach is to look at site-specific approaches and restrictions. You have a specific facility in a certain country or region. What are the sources of energy that are most easily accessible and plentiful in that region? Companies should make sure that equipment is capable of using that fuel or be ready to invest in new plants to secure that energy source. And they should take the long view. Which fuels may be impacted by future climate change rules or by future shortages for political or technical reasons?

Usage

Obviously, reducing usage of a fuel critical for your operations will reduce costs. But doing so will also improve your operational flexibility. If there is a looming shortage of a critical fuel, and you use less of it than your competitors, that flexibility puts you in a more commanding position, needing less. Being able to use more than one type of fuel for critical operations is beneficial, too, and gives your firm tremendous flexibility to ride price upheavals.

An overlooked issue in minimizing energy usage and improve flexibility is treatment of heavy equipment. Boilers, AC equipment, electric generators all need to be maintained and replaced at the appropriate times. It is a positive investment to perform retro-commissioning to maintain that the equipment is operating as you wish it; for you, the owner, to get your money’s worth. Also overlooked is proper training. Sometimes the first to be let go are maintenance workers; they appear not to contribute to the “bottom line”. But good maintenance people and managers (overseeing good procedures) can lengthen the effective life of equipment and keep down usage and costs very effectively.

How-To

A key to getting energy to be taken seriously as a top-of-the-line corporate interest is to have the top person, the CEO, involved. He/she should understand the importance of managing energy in a robust way and what the benefits are to the company’s moving forward. There may be doubters in the C-suite, including people who may not want Energy to “elbow its way” into decision making. But if the CEO understands the ultimate value of considering, tracking, and managing energy sources and usage, then those doubters can be silenced. So invest time in educating the entire C-suite, but particularly the CEO and update him/her on developments.

Make sure that energy is tracked as well as other business items, such as sales, workforce, profits, etc., and is included in business reports. Make sure that gains and benefits are explained and recognized.

CCES can help your company develop a robust energy program to serve your company. Its infrastructure, as well as technical evaluations of strategies to raise its value in the company and to demonstrate financial benefits. Contact us today at karell@CCESworld.com or at 914-584-6720.

New, Supplemental and Complementary Green Building Standards: WELL

The most widely used green building rating system in the world is LEED, created by the US Green Business Council (USGBC). LEED certification is a globally recognized symbol of sustainability achievement, and the standards provide guidance to help building owners and managers conserve energy and water, reduce waste, and minimize building and occupants’ environmental impacts. LEED has been well received and more and more new and renovated buildings are becoming LEED certified. Building owners are beginning to reap real, significant financial benefits of their LEED-certified buildings.

However, for some LEED is a standard with limited benefits. Some company and building owners realize that their tenants, whether residents, employees, shoppers, or students, are more concerned with their health. Can buildings contain features that will improve the health and welfare of occupants, making them happier and more productive, as well as raising the asset value or driving demand for the space?

The USGBC has addressed this by publishing such unique standards called WELL Building Standards, or “WELL” for short. WELL consists of features across seven concepts that comprehensively address the design and operations of buildings as well as how these features impact and influence human behaviors related to health and well-being. The seven concepts addressed in WELL standards include:

• Air
• Water
• Nourishment
• Light
• Fitness
• Comfort
• Mind

Like LEED, WELL standards contain mandatory pre-requisites across these areas that all WELL-certified buildings must meet at a minimum, as well as a point system that must be satisfied for WELL certification. These standards to improve the health and well-being of occupants include, but are not limited to, proper ventilation, reducing the level of indoor air pollutants, improving drinking water quality, reducing infiltration of water, promoting the use of natural light, and having specific building areas devoted to improve fitness and relaxation. Like LEED, WELL has a system to accredit professional practitioners, so having an accredited WELL professional on your certification team means being professionally guided to achieve WELL certification. Innovation in design and building operation to optimize meeting WELL standards is also rewarded.

WELL is a new program, and the first initial projects are being undertaken now and the first professionals accredited. How much will a WELL-certified building benefit a business, in terms of worker health, reduced sick days, improved productivity, etc.? The data will be collected and we will soon be able to validate the claims. However, there is no question that the common sense standards can only succeed in reducing sick days, improving both health and morale, and raise confidence and motivation, critical in sales.

If you are interested in learning more about WELL standards, learning whether this is the yardstick that is best for your building or business, and determining what it takes to become WELL-certified, contact Ms. Bonnie Hagen of Bright Energy Services today at bonnie@brightenergyservcies.com or at 914-425-1376 or Marc Karell of CCES at karell@CCESworld.com or at 914-584-6720.

The Importance Of Planning for Extreme Storms

As Texas and Florida begin to recover from Hurricanes Harvey and Irma’s onslaughts, the full impacts are being assessed and lessons learned. Besides the dozens of people who lost their lives, the property damage is well into the billions. Particularly hard hit are people’s homes, their biggest investments, in most cases, with no or inadequate flood insurance. In addition, for some time nearly one-third of US refining capacity was affected. At least one chemical plant suffered several explosions, causing a mass evacuation from miles of the plant. There have been several reports of releases from pipelines. This toll certainly points to the importance of preparedness and response to minimize damage in the future when future storms hit. Such efforts need to be a partnership between government and the companies affected to be most effective.

Government needs to give companies guidelines on what level of safety in an emergency is acceptable; what level of protection should be provided to the public and institutions. While many do not like regulations, fair, consistent regulations that defines a level of protection and implemented across the board in a smart way (mainly for at risk areas) makes the most sense. In 2011, the Clean Water Act was amended to require facilities that could release oil or natural gas to prepare and be ready to implement facility response plans in case of an emergency. The system worked, as few discharges of oil products were reported, given the new plans and the advanced warning of Harvey that we had.

Of course, it is impossible to expect no environmentally-sensitive spills occur given the historic rainfall (more rain that had ever fallen in a short period in the whole US). We should remember that this is a long-term process, a learning experience. As plants and pipelines re-open, care should be given to assure that before equipment and processes are re-started that they be inspected for viability (replace, if necessary, damaged parts and equipment, make sure the whole system is working) so there is a smooth re-start of operations (with minimal discharges and emissions) and to fully learn lessons to lessen impacts from future storms.

This is also important for municipalities. While Harvey and Irma represented extreme rainfall and wind events, the question that comes up is whether the municipalities were able to handle the water and winds and can they do so the next time. Stormwater systems need to be re-examined and potentially improved. Escape routes better planned and improved, if necessary, in order for emergency services to continue in the area and for greater resiliency. If necessary, municipalities NOT impacted by Harvey and Irma should take note and ask themselves how they might have fared if storms similar in scope hit them and go back and plan and spend to protect citizens better. The images we all saw of floods and wind damage in Texas and Florida should be enough motivation for all municipalities to review and bolster their emergency planning and services, even if it means spending more money and, yes, raising taxes. Harvey and Irma can represent models against which we plan for.

CCES can assist your company in emergency planning, resiliency, and sustainability. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Future of the Clean Power Plan Under Pruitt

September 2017

It is well known in this first year of the Trump Administration that many existing rules – particularly those promulgated during the Obama Administration – are being weakened, delayed, or repealed. One example is the Clean Power Plan, meant to regulate emissions from coal-fired power plants. The Obama era rule is being litigated in court. USEPA Administrator Scott Pruitt has used this as justification to state that the agency would not object to any state delaying its implementation of the Clean Power Plan and not follow any part of the schedule stated in the promulgated Plan. A number of state attorneys general have issued a letter warning Pruitt that these actions are ill-advised and potentially illegal. This matter is heading to court. After all, Congress has not amended the rule, no court has not called the Plan unconstitutional, and the US Supreme Court continues to cite greenhouse gases as legitimate pollutants that the USEPA must regulate. A presidential executive order earlier this year for the government to not enforce the law apparently has no legal standing.

The Clean Power Plan would require reductions in CO2 emissions from 2005 levels by 32% by 2030. Ironically, the US is already about half way there, independent of the rule, mainly because of market forces encouraging many power plants to switch from coal to natural gas as its fuel; gas combustion results in much lower CO2 emissions than coal.

The US Court of Appeals last year upheld the objections of some parties to the Plan, and subsequently allowed the delay of some aspects of it. But that court substantiated that the Plan is still the rule of law and only some deadlines can be bypassed.

In addition to a number of states objecting to the delays in administering the Clean Power Plan, a number are also promulgating their own new rules and standards to reduce greenhouse gas emissions from power plants and from other sources in response to the Trump Administration announcement that it would withdraw from the Paris Climate Agreement. They are using Paris goals for their own new rules. Many Fortune 500 companies are also creating and implementing their own plans to reduce greenhouse gas emissions, understanding the financial benefits from doing so. With the states and major corporations together achieving major greenhouse gas emission reductions, it may not matter what the courts rule about the validity of the Clean Power Plan, the US involvement in the Paris Agreement, and other climate change rules.

Please note that this article is not meant in any way as a legal briefing or discussion. Please do your own research in terms of the future of climate change or any environmental legislation. CCES can help your company reduce your “carbon footprint”, achieve long-lasting greenhouse gas emission reductions, and do so in ways to benefit you financially, from reduced utility bills to improved productivity to reduced maintenance costs to higher asset values. Contact us today at 914-584-6720 or at karell@CCESworld.com.