Monthly Archives: March 2018

Tips To Gain Support for Your “Green” Program

One of the most difficult items for an environmental/sustainability manager to deal with is showing progress in a program that you know is beneficial, but others at the firm do not understand or are fearful of. How do you educate your colleagues and get them on your side, so you have support as you implement changes to be more “green”? Here are some proven ideas on how some companies promote “green” programs.

1. The standard is set at the top. There is no question that culture and change and importance of philosophy starts at the top, with – quite literally – the CEO. Whether it is just saving energy costs or a comprehensive sustainability program, the CEO stating support for the program goes a long way. I was involved in a project to establish a sustainability program for an entity and the head person was all for it. He understood the benefits and wanted to maximize these and get ahead of his competitors. He sent a mandate to cooperate and move toward a more sustainable future. An environmental committee was established. But then the Great Recession hit and several existential issues came up for the firm. The leader lost interest in sustainability. Then, members of the environmental committee stopped returning my emails and voicemails; the project ground to a halt. I convened a meeting of this committee and most members revealed to me they did not believe in climate change or sustainability, Al Gore was a ___ (well, I won’t use the language here!), sustainability was a foreign plot to take over the US, etc. When the head was interested in sustainability, these employees had to cooperate. But once the leader lost interest, they let their true feelings show and it derailed the project.

Since the “top” is so important to jumpstart a “green” program, it is important that you, as a manager, reach the CEO or other head and educate him/her on what the program is all about (I dealt with a senior VP of a company who thought a “green” program was just planting trees. Really!). Emphasize the benefits, but do not overpromise or give the impression these items will appear overnight. This education is not one-time, and it must be continual. You must keep track of how the program is doing and inform the leader. Also, manage expectations. Make sure leaders understand that achievements occur slowly, but they themselves will lead to more benefits down the road.

2. Establish a winning culture/brand. Perhaps more important than a strategy or procedures is establishing a “green” culture, such as no tolerance for environmental or OSHA violations or looking to avoid wasting of energy, water, etc. First, know the entity, its history, its own culture and people, and then you can establish a “green” culture that is likely to be accepted by most people. Software programs exist to help assess the current culture of a company. People like consistency, and stating and maintaining goals like these make others realize the value of a “green” program to a company (besides saving costs) and that the program is here to stay. This culture should be spread to other groups to give the environmental group a positive identity. Take the time to explain to all who will listen the culture and how they benefit.

3. Go beyond the workplace. While the top rung of management is most important to support a “green” program, it is important to communicate the program to all levels of stakeholders. Support is needed from all layers. One way to achieve this is not just to implement changes to reduce energy use, water use, etc. at the facilities, but also to recommend strategies for employees to engender energy, water, etc. savings themselves at home. Let them be “heroes” to their families for saving money or the planet, and they will return the support tremendously.

4. Communicate rationally, yet emotionally, too. We engineers tend to communicate using only facts, numbers, savings, comparisons, etc. It’s what we’re used to. But to promote a “green” program, this will not work for many; their eyes will glaze over! Therefore, in addition to communicating the facts, it is also important to engage one’s calls to action in their hearts as well as their minds. The “green” program not only benefits the bottomline, but also the livability of the immediate area and the Earth as a whole. Make others feel like they are part of something consequential, and you will engender more support. Of course, with a “green” program, there is much to choose to show positive consequential outcomes.

5. Assess and adapt. One strategy does not always work well or approaches need to change as a “green” program progresses and matures. Periodically assess where your “green” program is – not only how it’s doing, but also its acceptance in your company. You may need to make some changes to the communication or to who you communicate with to engender further support. Assess and adapt to new realities to gain followers and momentum.

6. Don’t give up. The first Earth Day may have been in 1970, but for many, the environment is this fuzzy concept that does not affect them. Education about the environment has lagged, and many still do not understand its importance to everyday life. And sustainability is an even newer concept. Certainly anybody who is a leader likely did not learn about sustainability in Business or Engineering School “back then”. People innately feel that if they did not learn it in school is must not be important.

Therefore, it is not only the rational and emotional message, but the fact that it is sustained that will make people learn and understand the importance of these concepts. Constant education and communication about different aspects of environment, energy, and sustainability are needed, not only during the early stages of establishing a program, but later on, as well, even after the major elements of the plan are in place. Communication by multiple means has been shown to be effective.

CCES has the experts to help your company establish a “green” or sustainability or energy conservation program – not just the technical expertise, but we can help you organize it and begin the communication process to engender support in your firm. Contact us today at 914-584-6720 or at

USEPA Attempts To End “Once In Always In” Policy

In late January 2018, the USEPA issued an internal memorandum and in early February USEPA Administrator Scott Pruitt testified to Congress of his desire to rescind its “Once In Always In” (OIAI) policy for major sources under the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) program. Under OIAI, major sources subject to Maximum Achievable Control Technology (MACT) standards are prohibited from reclassification that would excuse them from these standards even if the facility reduced air toxic emissions sufficiently to become a minor source. The memo reverses this position. This action is being done to reward major emission sources who have invested resources to significantly reduce hazardous air pollutant emissions to fall below the major source threshold. The USEPA plans to amend NESHAP text to codify this new policy beginning with a Federal Register posting. Legal challenges are expected.


The federal NESHAP program provides emission limits based on “maximum achievable control technology”, defined in the rule as fairly stringent requirements. MACT apples to sources that emit any of 187 listed hazardous air pollutants (“HAPs”) in over 100 source categories. NESHAP covers two categories of sources: “major” and “area” sources. Major sources have the potential to emit at least 10 tons per year (tpy) of any listed HAP or 25 tpy of all HAPs. Any source that is not “major” is treated as an “area” source. Most MACT standards only apply to major sources; area sources are exempt. However, MACT standards for some source categories apply to both major and areas sources.

Given this, it is possible for a facility to accept federally-enforceable emission limits to become an area source (“synthetic minor”) to get out of installing expensive MACT-compliant technology (and avoid significant recordkeeping and reporting requirements). This can be achieved potentially with air pollution control strategies that are less stringent than MACT or by reducing hours of operation. Given the sensitivity of HAP emissions which could result in adverse public health effects on those near a plant, the USEPA in the early 1990’s established a policy that a facility can become a synthetic minor, but only by doing so before a MACT standard became effective. One cannot avoid the standard after the MACT standard went into effect, leading to the OIAI policy.

USEPA Justification

The USEPA justified the new policy on the grounds that Congress in the Clean Air Act provided no language pertaining to the reclassification of major sources to area ones. Their new guidance memo wishes to inject “plain language” that a facility would switch from a major source of HAPs to an area source when an enforceable limit on potential to emit HAPs below the “10/25” thresholds is achieved and approved.

Intended Outcomes

The USEPA believes its new policy ending OIAI will have several outcomes. It would:

• result in “meaningful incentives” for facilities to undertake projects that will reduce HAP emissions below major source thresholds.

• eliminate a “punishment” for facilities whose HAP emissions have dropped not because of conscious emission reductions, but because of changes in processes or business shifts for remaining “major”. For example, facilities who have permanently substituted less toxic compounds for HAPs for any of a variety of reasons (cost, availability, worker safety concerns) and is no longer major would no longer be required to comply with MACT and robust recordkeeping and reporting requirements. Also, this would apply to whose business has changed and no longer produce products or produce less product that require use of HAP compounds. They would no longer be burdened given this policy change.

• remove the burden for facilities whose potential to emit (based on unrestricted operation) is above the major source threshold, but whose actual emissions are significantly below it. Facilities who were unsure how to limit their operation to have federally-enforceable limits were careful and went into a given MACT program. But for those whose subsequent operation confirmed that actual HAP emissions were truly well below the major threshold, it was too late for relief.

A Compromise Solution?

While this is an article of facts and background, I do wish to provide a compromise position that I think would achieve the goals of both sides of this debate. New York State has a policy that any facility wishing to permit itself just below any applicable threshold (even for non-HAP compounds) must be limited to 10% below the threshold to account for any unexpected or accidental release (the facility would likely still be below the threshold. Applied to this situation, if a facility can commit and abide by permit limits of 9 tpy for any HAP and 22.5 tpy of all HAPs, and maintain this for a set time, say, 2 years, then it can be changed to an area source and all MACT requirements removed.

What Facilities Should Do

While there are likely to be legal battles concerning the elimination of OIAI, facilities who are regulated as major HAP sources should review their current emission inventories to see if they have fallen below the major source thresholds or are close enough to make the reduction to below the threshold technically and economically feasible. It may be to the facility’s advantage to catalog that its actual emissions are below the major threshold or implement the changes that will ensure this. To codify this, one would need to modify one’s Title V Air Permit to remove that MACT standard as an applicable rule and in so doing, remove or lessen control, recordkeeping, and reporting requirements. Some states, which may be resistant to this change, may not implement any such changes until all court proceedings are completed. Also, some have “anti-backsliding” provisions that may prevent the loosening of existing restrictions. Such facilities should retain the proper technical and legal experts as they are proceeding.

Please note that this is a technical, not a legal, assessment of the change in federal OIAI policy. Speak to appropriate legal counsel before making any decisions on this or related matters. CCES has the technical experts to help you assess whether your current emissions exceed or are below any major applicability threshold and can provide advice on the most cost-effective ways to reduce HAP (and non-HAP) emissions for a variety of processes. Contact us today at 914-584-6720 or at

Saving Energy Can Also Improve Air Quality

This blog has covered extensively the many financial benefits of saving energy. According to a new report from the American Council for an Energy-Efficient Economy (ACEEE) and Physicians for Social Responsibility concludes that saving energy can reduce the number of asthma attacks and other adverse health effects of air pollution from power plants. See This report concludes that reducing annual electricity use by 15% nationwide would prolong more than 6 lives every day, prevent nearly 30,000 asthma episodes each year, and save Americans up to $20 billion annually in avoided health care costs.

The cause and effect is simple. When less energy is needed, power plant emissions decrease, reducing byproducts of combustion of coal, oil, and natural gas into the atmosphere, some of which are tied to asthma, lung cancer, and other maladies. The report estimates that this reduction in pollution and harmful health effects would be enough to pay the annual health insurance premiums for nearly 3.6 million families.

The report estimates total potential avoided adverse health effects, such as heart attacks, respiratory illnesses, premature deaths, and emergency room visits to treat asthma, that could be achieved with a 15% reduction in electricity use across the country. Using USEPA modeling tools to identify the quantity of pollutants which would be avoided, the report ranks states and the 50 largest cities by their potential health benefits. According to the analysis, New York City would see the greatest benefits (more than $1 billion/year in avoided health costs), followed by Chicago, Philadelphia, Pittsburgh, and Detroit. The dollar value of avoided health cost would average more than $70/person in the highest impacted cities, with Pittsburgh seeing the greatest per capita benefits: over $200/person on average. West Virginia would see the greatest benefits per person for a state: $184 on average.

Therefore, this evaluation demonstrates that a viable strategy to improve public health is to encourage improves energy efficiency. A further benefit is that the vast majority of energy efficiency measures results in energy savings and, therefore, reduced power plant emissions, over many years, meaning public health would benefit and costs reduced for many years. While the degree of benefit is certainly quite site-specific, any facility that undergoes an energy upgrade, becoming more energy efficient, can state that they likely will have, as an additional benefits, reduced emissions in areas around the power plant it gets power from and improved health of those nearby residents.

CCES has the experience to help you implement a smart energy efficiency program to reduce energy demand, reduce costs, and reduce air emissions from your facility and from the power plant that supplies you with electricity. We can help you economically reduce emissions from other sources to show a positive societal contribution. Contact us today at 914-584-6720 or at

Plan for Installing Occupancy Sensors

A few years ago I performed an energy audit for an office building and developed a good half-dozen sound energy strategies to save them money. While discussing occupancy sensors with the building’s owner, he understood its value. I offered to help, but he turned me down. He was going to go to the nearest Home Depot to pick up some on sale and install them himself. Well, big mistake. I suppose this owner so understood the simplicity of how an occupancy sensor works that he felt that no thinking was necessary. On the contrary, proper planning will make the difference between a reliable, cost-saving venture vs. an unsuccessful one. A few things to consider:

1. Invest time, determine where sensors can save the most by observation. Determine which areas have long periods of dormancy and can use occupancy sensors to save energy and which areas are regularly used. Yes, one can guess the need for occupancy sensors by evaluating a room’s use (for example, an IT room, where, theoretically, people enter rarely). One can review conference room reservation logs, but in many cases, rooms are fully booked, but hardly actually used. Thus, spend a few days to observe which rooms are actually unoccupied for long periods. Perhaps there is significant flow in and out of the IT room after all; perhaps a conference room really is or is not used as much as the logs show.

2. Accurate, up-to-date floor plans. Once areas are identified, plans are needed to determine which lights and electrical panels serve each space to place the sensors appropriately. With this information you can determine in which rooms to place occupancy sensors (connected to which panels) to get the best effect.

3. Placement of sensors. This is crucial to their effectiveness and occupant satisfaction. Sensors should be capable of “seeing” anyone who comes in the door. In some cases, multiple sensors may be needed for odd-shaped rooms or for spaces shielded by high cubicle walls or cabinets. Do you place the sensor high up on a wall “to see” more of an area, but make it inconvenient to repair? Or closer to where people work?

4. Pick your occupancy sensor brand carefully. Don’t buy them just because they are cheaper or are on sale. There are differences in quality and sensitivity. Installing the “wrong” sensors can affect morale and efficiency. If your budget allows, consider dual technology sensors, those that sense both motion and thermal, particularly for large or odd-shaped spaces. You don’t want lights going out just because people in a room have not moved in some time. This just happened to me. The host was quite embarrassed.

5. Provide early notification to staff. Establish an installation schedule and give advance notice to staff approximately when occupancy sensor installation will occur in their areas. Send staff either a brochure or some summary of the specs. of the sensors, so they have an idea of what it can and will do.

Final question: does one still procure occupancy sensors if one has switched to LEDs? Installing LEDs and saving energy costs should not preclude one from installing occupancy sensors. Even reduced wattage lamps, such as LEDs, represent wasted electricity and cost if on for many hours when a space is unused. The math may be different (lower savings because the cost of wasted electricity is lower), but in most cases there should be a reasonable, if somewhat longer payback for using occupancy sensors.

CCES has the experts to help you perform a full assessment of your lighting and total energy usage and needs, and provide detailed smart strategies to reduce usage, demand, and cost that have worked for others. Contact us today at 914-584-6720 or at