Monthly Archives: July 2015

Basics of Sub-metering: Why It’s Good For You

Benefits of Sub-metering

Given the expense decades ago of purchasing multiple electric meters and the needed wiring, many multi-tenant buildings (both residential and commercial) have a single master or small number of meters to record electric usage. This leads to many issues, such as fairly assigning electric usage to specific tenant or operation and lack of motivation to conserve energy usage. If a building hosts a variety of tenant operations, it is likely one business or resident will pay more relative to what it is using (say, an office of any type compared to a restaurant). If you are paying a set percentage of the reading of the master meter, what motivation do is there to reduce usage?

Given the benefits and reduction in costs to do so, sub-metering is becoming an option many are considering. At least two cities, New York and Philadelphia, have promulgated laws to mandate sub-metering in certain situations. A recent report in EE Reports ( provides robust guides to the basics of sub-metering.

Perhaps the biggest argument for sub-metering is the eventual cost savings. If each tenant of a building has its own electric meter and learns what they actually use and have to pay for it, behavior (when it comes to energy usage) will change fairly quickly. The DOE has published the range of 5-15% savings in energy usage as tenants absorb the meaning of their high bills, realize they can now control their usage, and begin to implement simple strategies to reduce usage (more efficient equipment, not leaving on equipment, etc.). And these strategies have a short payback, generally under 3 years. A recent study in a NYC high-rise residential building showed 20% overall energy savings.

Planning for Sub-metering

Like many things with energy, this is not a matter of going out and quickly buying and installing meters and expecting great savings. Planning is important. Ideally, the building owner should research different types of sub-meters with different types of data displays, such as graphical, by time (hour by hour), or basic digital. Hour by hour is particularly powerful as it may identify areas of electricity usage you were unaware of, such as why is usage so high at night? Or why is it so high during a certain period in the workday? What equipment or department or group may be responsible? In addition, with many paying special rates for high demand during peak periods, hour by hour data can help you plan and verify that electricity-using operations are moved to non-peak periods, saving you tremendous costs on high peak demand charges.

Also, make sure that sub-meters that you procure be able to be checked and calibrated; that they are part of your measurement and verification (“M&V”) operations to ensure they are operating properly over time.

For more information

See for the full “Metering and Sub-metering 101” and “102” Guides and more unbiased information about energy efficiency.

CCES can help you assess the value of sub-metering your buildings and can plan and manage its complete implementation to maximize your financial benefits. Contact us today at 914-584-6720 or at

How To Think About Energy Efficiency

Last week, I gave a talk to an engineering society about sustainability, with the emphasis on energy conservation and greenhouse gas emission reductions. I discussed “The 9 Purely Business Reasons to Reduce Energy” (published earlier in this blog) to demonstrate the many purely common sense, financial reasons to invest in energy efficiency. Give credit to us engineers. A few people in the audience questioned the viability of these reasons and gave me a hard time. Although I emphasized the business value of reducing energy usage, these people were quick to point out that improving energy efficiency was no guarantee of cost savings; a strategy may be so expensive or not feasible such that it will not pay back the initial investment. This is true, and that’s why one needs to look individually at every building and situation and devise a host of potential strategies. Some will have a better ROI than others. And that’s a good reminder that “just going to Home Depot” to pick up some LEDs, does not guarantee savings (or proper lighting). We experienced engineers are needed.

My favorite example is a small business called Colonial Needle, a light industrial / warehouse / office 2-building complex in White Plains, NY. The buildings were built in the 1950’s and underwent essentially no changes since then, including having their original windows and boiler. Not only were their energy costs sky high, their workers were still uncomfortable; some were wearing parkas at their desks in the winter! Colonial Needle finally realized they had to upgrade and did so comprehensively. For example, they knew that there were cracks in many of the single-pane windows. While a window upgrade to double pane generally does not have a fast payback, it was critical for worker productivity and morale for wind not to blow onto people at their desks! Each building and situation is unique. It is important to bring in the right energy professional to lay out options and to look deeper into what the long-term costs and benefits are.

Another factor is to take advantage of incentives that exist for many energy efficiency projects. Governments – even in red states – are beginning to understand that incentives for private companies to implement energy efficiency projects is a productive way for a government to spend money. Some examples:

• Improved energy efficiency, by reducing a company’s expenses represents a boost for tax revenue and for creating new jobs, beneficial to any government.

• One or many buildings using less energy (more efficiently) also has health benefits. Less fuel combustion means reduced air pollution buildup and, therefore, reduced asthma and other respiratory diseases, meaning a happier and healthier population, using less government services.

• Using less energy in peak times reduces the stress on the energy delivery system. One apartment complex that switched from oil to natural gas (oil backup) noticed that the number of annual oil truck deliveries dropped from nearly 300 to two, through the narrow, complex streets of the neighborhood. Besides causing traffic jams, truck deliveries took workers away from other jobs, not to mention. So this change benefitted many.

• Reducing the amount of electricity used allows utilities to avoid or scale back the building of new or expanded power plants, transmission lines, and other necessary equipment and use existing infrastructure more effectively. This not only saves the utility much money and risk of potential failure, but also saves the consumers, too, as we all ultimately pay the bill.

This last point is a major reason why more and more utilities offer incentives to customers to use less energy. Yes, that sounds ironic – paying a bonus to customers to use less of the product they sell. But such incentives make sound sense given the alternative, multi-million or multi-billion dollar capital upgrade projects, which may or may not be fully funded and may or may not lead to unbridled success.

But back to you, our readers, who primarily work for companies and building owners and deal with a finite number of buildings and facilities. Why should your company invest in energy efficiency and how can you get others to push for this?

 The payback period for energy efficiency fell by over half when productivity and operational gains are estimated and brought into the calculations.

 Energy efficiency strategies can make buildings more comfortable, yielding healthier conditions for workers and residents. According to the International Energy Agency (IEA), for every $1 invested, energy efficiency provides up to $4 in benefits when the cost of medical care, lost work time and child care costs are considered.

 Energy efficiency strategies can attract new business, tourists, and investment dollars to the company or building. This is especially true in real estate, as energy efficiency can attract more potential renters (giving the owner the upper hand), the entertainment and health care industries, and for universities.

Companies, building owners and managers, governments, utilities, and yes, even engineers should stop thinking about energy efficiency as just another expense, and instead think of it as an investment to be studied and benefits maximized. No, not every energy efficiency project will pay back well. An experienced professional is needed to determine the most cost-effective projects. But so many opportunities in energy efficiency exist (growth in better systems/technology) to benefit nearly any company.

CCES has the experts to perform an energy audit to determine specific energy efficiency projects for your building or facility. We have the experience to quantify potential costs and long-term benefits, not only direct cost savings, but other business benefits, as well. Join the growing number of businesses who understand energy efficiency is a positive business investment with many short- and long-term benefits. Contact us today at 914-584-6720 or at

Case Study: CCES Performs Evaluation of Exterior Lighting for College

Climate Change & Environmental Services (CCES) performed an evaluation of the exterior lighting for a large college campus in New York City. While crime and other security issues were considered not a problem, the college understood that there were unlit spots in sections of its campus giving the perception of security issues, and that a number of lighting fixtures were broken.

CCES performed a comprehensive exterior lighting survey of the entire college campus, taking light meter readings during evenings approximately every 10 meters. Readings were recorded and compared to foot-candle standards used at other colleges to determine areas that are likely underlit given their use. In addition, fixtures with missing or broken lights were recorded.

Using Google Earth images throughout the campus, CCES developed maps of the campus showing the light meter readings and indicating areas that were underlit compared to recommended levels at college campuses. In fact, most of the exterior of the campus was determined to be underlit. Areas most walked through and most underlit were identified and highlighted to help the college prioritize their upgrade. Broken fixtures were also identified. Finally, the college committed to replacing broken lamps and upgrading and adding new fixtures to raise campus lighting levels with LED lamps wherever possible.

Follow Up on Supreme Court Ruling on Mercury Emissions

The U.S. Supreme Court ruled on June 29, 2015 that the USEPA acted unreasonably when it determined that it was appropriate and necessary to regulate mercury emissions from coal-fired power plants without including a cost analysis. The hazardous air pollutant section of the Clean Air Act (Section 112) states that the agency must first conclude that it is appropriate to regulate a hazardous compound, then propose, post, and promulgate the rule. The Court ruled that the agency failed to consider the cost of the regulation during that initial assessment of whether regulation of mercury was appropriate. The USEPA argued that it could not do an effective cost assessment early in the process until it determined at the required level of mercury emission reduction.

The Supreme Court’s decision does not invalidate the rule, but merely remands it back to the U.S. Court of Appeals, which can either vacate the rule or leave it in place while the USEPA provides further justification of its appropriateness. Absent in the Supreme Court ruling is any requirement on how it should consider costs in the future. The Court concluded that it is up to the Agency to decide how to account for cost.

As legal commentators have stated, if the mercury rule is vacated, it may have the ironic effect of helping the USEPA defend its forthcoming GHG rules for existing power plants, as one legal objection is that the USEPA lacks authority because it already regulates mercury emissions.

Another issue of concern in the Supreme Court ruling is the cost analysis performed by the USEPA when the rule’s parameters were finalized. The USEPA stated that the cost for compliance for would be several billion dollars per year, while the benefits would be in the millions per year range. But this was direct benefits due to decreased mercury emissions. If one considers additional secondary benefits (the same technology reduces other hazardous and non-hazardous air pollutants, such as fine PM, reducing other public health impacts, such as asthma), then the benefits are much greater, and exceed the cost. The Court noted, but did not rule on whether the Agency must look only at direct benefits for the pollutant(s) being regulated or can look at additional benefits, too.

It appears that in the near future, at least, the USEPA in performing its “appropriate and necessary” analysis before proposing a regulation for a hazardous air pollutant will need to determine probable emission limits necessary to at least minimally protect public health, and perform a cost-analysis on that basis.

According to legal commentators, this is among several decisions that appear to contradict each other (for example, a different court ruled that OSHA did not need to perform a cost-benefit analysis to promulgate its worker protection rules). So it is likely that this issue will be discussed in courts in the future.

Please note that this is not intended to be a legal analysis of the Supreme Court ruling. Please speak to a legal professional for an in-depth evaluation. This article is written for the reader’s general knowledge. CCES has the expertise to help your company assess its hazardous air pollutants and recommend the most cost-effective technical strategies to reduce emissions. Contact us today at 914-584-6720 or at

USEPA Eliminates Startup, Shutdown Malfunction Exemptions

On June 12, 2015, the USEPA published its final regulatory action requiring 36 states to remove from their State Implementation Plans (SIPs) exemptions from emission limits during startups, shutdowns and malfunctions (SSM). See:

This action requires 17 states to remove automatic exemption from emission limits in rules (affirmative defenses) because of SSM from their SIPs. This change will likely impact the operating procedures of many facilities that have automatic SSM exemptions included in their air permits and increase their compliance liability.

The USEPA first proposed this action in 2013 as a result of a Sierra Club petition. The USEPA revised its original proposal in 2014 after the D.C. Circuit Court held that an affirmative defense against civil penalties for toxic air emissions by Portland cement manufacturers, even in the event of an unavoidable malfunction, cannot be made.

In its discussion of this final action, the USEPA stated that while the agency was now prohibiting automatic SSM exemptions and affirmative defenses, it will allow discretion by air agency personnel exercised on a case-by-case basis. It encourages alternative emission limits or mandatory work practices to be required specifically for SSM events.

Affected states must submit their SIP revisions to the USEPA for approval by Nov. 22, 2016.

In the meantime, to properly prepare for implementation of this change affected facilities (those currently with SSM exemptions) should research and determine alternative emission limits that it can meet or work practices that it can implement during SSM events to provide to the applicable air agency when elimination of automatic SSM exemptions and affirmative defenses goes into effect, and the air permit must be re-examined and revised. It is likely that states will require such information during a future renewal or modification of an air permit. It is better for a facility to be “ahead of the game”, and provide proposed changes with rationale to the agency, who may have little basis to make a decision.

CCES has the experts to help you establish workable alternative emission limits and work practices during SSM events, and help you modify your permits – under your terms – and negotiate with your regulatory agency. Our Air Permit experts have much experience in industrial emissions all over the country. Contact us today at 914-584-6720 or at

USEPA Announces Changes to Self-Audit Policy

While the USEPA spends a lot of time researching and writing rules that it has promulgated, another area of importance is enforcing these rules – to ensure they are fairly and evenly complied with. Besides the “stick” of fines, potential imprisonment, and bad publicity, the USEPA also uses the “carrot” of encouraging companies to comply by establishing a formal policy to waive the punitive portion of any penalties that would otherwise be assessed for violations if they are discovered independently by the facility, voluntarily disclosed to the USEPA, and promptly corrected. The USEPA’s “Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations” has been around since 2000 (modified in 2008) and been used successfully by companies since with compliance self-auditing programs, giving many a “clean slate.”

In 2012, during a time of budget cuts and reduced staff, the USEPA signaled that it may reduce involvement or even terminate the Audit Policy program.

However, on June 10, 2015, the USEPA held a webinar to confirm its strong support for the concept of self-auditing and announced changes to its Audit Policy and Small Business Compliance Policy to meet the same goals, while allowing the Agency to reduce effort spent. ( The USEPA has made the process electronic, creating an “eDisclosure Portal” to more efficiently collect information needed to determine whether a disclosure qualifies for the Audit Policy. It was designed to make the process close to self-executing. The trade-off for this efficiency increase is less flexibility to addressing unique individual circumstances.

For example, the Portal will track initial discovery, disclosure, compliance correction and certification dates, and automatically notify the submitter whether a deadline is missed (Audit Policy is non-applicable). The system is supposed to grant up to 30 additional days to complete compliance corrections above the normal 60 days. The applicant can request additional time to comply, but the USEPA will not rule on such a request until it reviews the entire request. Therefore, facilities taking added time to achieve compliance may find their extension request not granted and get no benefits under the Audit Policy.

Another potential problem with the new eDisclosure system for the user is that even if the system indicates that a facility meets all of the criteria to qualify for the Audit Policy program, such a final determination is only made by the USEPA after it reviews information inputted, and it has the right to contradict any statement from the system.

The USEPA does expect that the new eDisclosure system will ultimately benefit disclosing facilities, reducing their time and costs if they fully understand how to use the new system, collect and disclose all needed information fully, and meet all deadlines.

The eDisclosure system is expected to be launched in fall 2015. The new system may provide less certainty and less flexibility to applicants than current procedures, but will reduce time and costs to submit to the Agency necessary data, providing incentive to continue to use the Audit Policy to quickly disclose and correct violations and be rewarded for doing so.

CCES has the Air Quality experts to help your facilities determine potential violations of federal and state Clean Air Act regulations early in the process, help you correct them in a cost-effective manner, and initiate monitoring procedures to allow you to monitor your operations effectively. Contact us today at 914-584-6720 or at