Category Archives: Air Pollution

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.

Background

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 karell@CCESworld.com.

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 http://aceee.org/research-report/h1801. 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 karell@CCESworld.com.

Environmental Evaluation of the Trump Administration’s 1st Year

December 2017

Recently, President Trump boasted about the number of regulations he repealed or otherwise inactivated, as the most in history. We’re not sure how factually true that statement is, but it certainly is true that the most active agency in carrying out this de-regulation was the USEPA. There have been a number of roll backs of Obama Administration rules and initiatives, headed by the Clean Power Act, as part of the Trump Administration’s desire is to encourage coal production. A recent article also stated that not only has the agency lost much in the way of personnel, but it is enforcing existing rules with much less vigor than in the recent past, even under a past Republican administration. See https://www.nytimes.com/2017/12/10/us/politics/epa-enforcement-methodology.html

In addition, the Trump Administration has cut drastically environmental and public health research and has scrubbed mention of Climate Change from its websites, educational materials, and conferences, including terminating research in these areas.

One of the few areas that the USEPA has remained active is in Superfund cleanups. The degree of cleanup has accelerated in the past year. Many think prioritizing certain Superfund cleanup projects coincides strongly with where valuable mineral and oil and gas deposits are found, which can be profitable for future owners or miners in the area.

However, one other area that has disappointed many in the environmental community is the President’s vigorous attempt to free up federal land for mining and oil exploration, including the Arctic Wildlife Refuge and several national parks, such as Bears Ears National Monument, in which President Trump announced that the section of this monument that is protected from private use and exploration will be reduced by 1 million acres or 85%, the largest reversal of national monument protections in US history. The proposed change has been challenged in court by conservation groups.

The good news in all of this is that this news has galvanized the environmental community and many citizens, worried about the impacts of repealed environmental rules on the health and wellbeing of millions in this country. Many states will maintain and strengthen their rules. Several political candidates have discussed environmental concerns, something that rarely happens. In addition, global images, such as extreme haze and people walking around with filters in India and China have shown all the importance of smart, workable environmental regulations.

However, all in all, 2017 was not a good year for environmental protections and governance in the U.S.

CCES has the experts to help your company stay in touch with environmental regulations and provide technical assistance on how to comply in the least expensive, yet reliable way, without disrupting operations. Contact us today at karell@CCESworld.com or at 914-584-6720.

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.

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.

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.

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.

Environmental Risk and Compliance in Aftermath of an Emergency

How do we treat environmental compliance in an area hit by an emergency? Do we suspend environmental rules and procedures as people and land recover? Or do we treat it as nothing has happened? The recent tragedies of Harvey and Irma put this question in perspective.

As Hurricane Harvey left destruction throughout southeast Texas, it was natural to allow residents to return to their homes as soon as it became passable to make their way back. However, was it safe to let people return so quickly?
The USEPA reported that over a week after Harvey hit Texas, over 800 wastewater treatment plants were still not fully operational and there were releases of untreated wastewater from sanitary sewers. 13 Superfund sites in the hardest hit areas were not even visited yet by the USEPA, although it was likely that the flood waters carried some toxic material with them. Over 100,000 people had no access to safe drinking water weeks after Harvey hit. Was it safe to allow people to return without a basic assessment of these issues? Did the government put the residents at further risk of health impacts by allowing a premature return? Remember how in the aftermath of the 9/11 tragedy, the affected area was declared “safe”, and many rescue workers came, only to face debilitating health effects in the future because the air still had high concentrations of ash and other toxic compounds.

In addition, in the wake of Hurricane Harvey, Texas Governor Greg Abbott suspended many environmental rules, such as waiving the requirement to operate pollution control equipment and regulating operations at different types of facilities on the theory that these efforts could hamper the recovery from the hurricane. These suspensions include air emission and effluent restrictions, as well as performing certain operations, maintenance, testing, and reporting and spill reporting and response requirements of hazardous waste, of which the heavy rains and winds carried outside of containment areas into areas where people may be exposed. Texas also issued guidance allowing local authorities to perform whatever recovery activities it believes will be most effective, even if there are environmental implications. It should be noted that this applies to state rules only, and does not apply to federal rules.

The scope of the suspension is only applicable where normal operations are unsafe due to the conditions and compliance would prevent or hinder actions needed to recover in coping with this disaster. The suspension is only valid in the areas hit by Harvey and only for the time that the area is considered a disaster area.

However, was this the proper decision? Might suspending rules and procedures increase the environmental impact and the risk of exposure to pollutants in the air, water, and solid areas?

Further study will determine whether these were risky decisions or prudent given the circumstances. Lessons will be learned.

CCES can help your firm assess the technical aspects of compliance with and risk from environmental regulations in your state and locality. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Some Environmental Legal Updates – August 2017

Things change so quickly, but here are a few new items that have gone on this summer. EPA Administrator Scott Pruitt had been very vocal about how he feels EPA regulations have hurt industry and job creation. Since taking office, he has quietly begun an effort to repeal or not to enforce several Obama-era environmental rules.

On July 3, the U.S. Court of Appeals for the District of Columbia Circuit nixed EPA Administrator’s Scott Pruitt’s attempt to delay a rule limiting methane leaks at oil and gas facilities. The rule requires companies digging for natural gas to plug leaks of methane, which would help them recover natural gas they can sell, as well as reduce emissions of a potent greenhouse gas and air pollutant. As part of his effort to ease regulations for industry, Pruitt decided, instead of having the rule repeal, to instead achieve the same end by suspending the rule’s compliance deadlines. The EPA had argued that the Clean Air Act allowed the EPA to do this (temporarily suspend a rule) while considering objections that could not have been raised prior to the rule’s issuance. However, the court found the claim to be false. The objections were clearly shown to have been raised earlier.

Pruitt’s actions to repeal or reduce enforcement of rules have been done very quietly without proper public notice or comment. The Administrative Procedure Act requires EPA to seek and respond to public input before taking major deregulatory steps. But Pruitt has been attempting to bypass that requirement by suspending rules indefinitely without public comment, instead of repealing them. Suspension can only occur for rules before they go into effect. Therefore, he has been successful in only suspending rules that had just been promulgated at the end of the Obama Administration, but had not gone into effect yet.

Once a rule goes into effect, elements of the rule, such as what is compliance and when it goes into effect cannot be suspended or altered without a request for public comment, and serious review of such comment. This has not stopped the EPA from suspending compliance deadlines for several rules after those rules went into effective.

On July 18, 2017, the EPA published in the Federal Register its proposed rule on the Renewable Fuel Standard (RFS) Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019. (https://www.gpo.gov/fdsys/pkg/FR-2017-07-21/pdf/2017-14632.pdf). The proposed volume requirements represent decreases from current standards for cellulosic biofuel, advanced biofuel, and renewable fuel. Only the requirements for renewable fuel is essentially the same in 2018 and 2019 compared to 2017. Comments on the proposed rule must be received by August 31, 2017.

While the proposed reduction in the amount of renewable fuel is relatively small, many in the biofuels industry are concerned that it sends the signal to the market that the U.S. renewable fuel industry will no longer grow. The proposed volume requirements may undercut the Administration’s goal of reducing U.S. reliance on foreign energy and reviving U.S. manufacturing, despite President Trump’s repeated pledge to support the ethanol industry.

Please note that this should not be considered a legal interpretation in any way. For further information, speak to a qualified environmental legal representative to fully understand new or modified rules and how they may affect you and your firm. CCES has the technical experts to help you keep abreast of new rule changes at the federal and state level and how to address them to impact you as little as possible. Contact us today at 914-584-6720 or at karell@CCESworld.com.

It Is Not Only Climate Change; Evidence That U.S. Toxic Air Pollution Still Harms Many

Of course, Climate Change is a big news item. How can it not be? The entire scientific community is in agreement that mechanisms are in place that will cause drastic changes to our climate and, therefore, our whole economy and way of life in a relatively short time. And President Trump’s decision to withdraw the U.S. from the Paris Climate Agreement has heightened the concern. Many in the media, when addressing Climate Change, show pictures of people walking around with masks over the faces and or stacks with large quantities of colored smoke escaping into the atmosphere. That has little to do with Climate Change. In fact, what it represents is a different, serious problem, and that is emissions of toxic air pollutants which can affect the health of people downwind of a source. While the U.S. has made great strides in the last 40 years of bringing down the ambient levels of many toxic compounds, a June 2017 study in the New England Journal of Medicine shows that toxic air pollution is still a major problem, and leads to the premature deaths of thousands of Americans each year. See: http://www.nejm.org/doi/full/10.1056/NEJMoa1702747. This is particularly true for the pollutants ozone and PM-10 (fine particulate matter).

The study estimates that about 12,000 lives can be prolonged annually by reducing the ambient level of fine particulate matter by 1 microgram per cubic meter below the current USEPA standards. The Clean Air Act requires the USEPA to revisit emission standards of criteria pollutants every 5 years, and adjust them accordingly based on the latest scientific knowledge. A House Committee recently passed a bill slowing down the oversight to once every 10 years.

A recent article in Scientific American (https://www.scientificamerican.com/article/the-other-reason-to-shift-away-from-coal-air-pollution-that-kills-thousands-every-year/) discusses this in detail, and recommends continuing the movement to shift away from coal-fired power plants to natural gas. This trend has been touted as a way to reduce greenhouse gas emissions, thus, addressing Climate Change. However, the article points out that these benefits are actually minor because increased digging for natural gas and other leaks leads to greater methane emissions, which is a much more potent greenhouse gas than carbon dioxide. The article points out that replacing coal-fired with natural gas-fired power plants would be more effective extending live, reducing hospitalizations, which would save the US economy tens of billions of dollars each year in hospital costs and productivity gains.

Yes, let’s focus on Climate Change because of the extreme, irreversible changes that are likely to occur if not properly addressed. But let’s remember that while the U.S. has made progress, there is still a ways to go to further protect public health in the U.S. and worldwide due to toxic compounds that are emitted from the same sources.

CCES has the experience to assess your emissions inventory and to develop a cost-effective plan to reduce emissions to meet regulatory requirements and improve your impacts. Contact us today at 914-584-6720 or at karell@CCESworld.com.