Category Archives: Air Pollution

Simple Step To Make Your Workplace (and Home) More Safe and Sustainable

A very simple step you can do to make your workplace more sustainable, healthier, and, ultimately save money is to purchase and use less toxic cleaning supplies. Such a move does not involve great technical planning or effort nor upfront payments. It is simply changing Purchasing policy to regularly purchase only less toxic cleaning supplies.

Cleaning itself is a critical part of any warehouse or industrial facility – or, even a paper-pushing office. Removal of bacteria, fungi, spilled chemicals, etc. rarely occurred in history, as it was not until the 19th century we knew of the “germ” theory that many diseases were caused by microorganisms. Cleaning of any surface, room, carpeting, walls, etc. is important in the maintenance of a well-functioning workplace, and thus, it is important to purchase and use effective cleaning solutions, which also reduces odors, which can be annoying and distracting for workers, and, in some cases, toxic.

The problem is that cleaning detergents, antibacterial cleaning agents, and chemical fragrances used regularly for these functions leave chemicals behind on surfaces, such as walls, floors, desks, equipment, toilets, and countertops. Many of these chemicals are volatile, evaporating into the indoor air we breathe, entering our lungs and blood stream which transport them around our body. Remember, these are effective cleaning solutions because they kill microorganisms; these same compounds can easily get inside us, possibly harming cells and organs and can stay in our bodies for some time. Growing public health literature links some of these compounds to cancer and other diseases. Given the amount of time we stay home, exposure at home to such compounds lead to many calls into poison control centers or emergency rooms.

And if that is not enough of a worry, the USEPA, which is supposed to address and regulate the use of toxic compounds in our environment, has not done a good job overall. TSCA, the main applicable regulation, has only tested and regulated about 1% of the estimated 80,000 potentially toxic compounds in cleaning solutions. States and consumer groups have tried to pick up the slack, but there are still many compounds common in home and office cleaners whose potential effects are not clearly understood.

Fortunately, growing demand has resulted in new alternative products that do a fine job of cleaning surfaces, while using less or non-toxic compounds. It is worth researching what is available, how well they work, and on what surfaces or problem areas. Once acceptable cleaning solutions are found, maintain the list and implement a Purchasing policy that only those brands are procured and used in the future. No hassle, no planning or major expenditure. It all becomes a part of your company’s everyday policy.

And a good way to improve the health, productivity and attendance of your workers, which always makes economic and sustainability sense.

CCES has the experts to help your firm develop and implement policies that will improve your local environment, reduce energy use, and improve productivity. Contact us to discuss today at 914-584-6720 or at karell@CCESworld.com.

Out-of-the-Box Approaches To Saving Energy

Many articles in this blog/newsletter have been written with conventional approaches to save energy: mainly on new technologies, or applications of old technologies, or behavioral or operational changes. I hope you have taken them seriously, implemented some, and reaped the benefits. If you haven’t, it’s never too late!
But there are other, unconventional approaches – some you have thought about in other contexts – that can successfully save energy, as well. One is using advanced scheduling and resource planning applications and software. This may be relevant to you in order to better utilize resources and staff, to better distribute inventory, to better produce product. But improved scheduling and organization can also save energy. An excellent article in a recent Chemical Engineering Progress discusses this concept well: https://www.aiche.org/resources/publications/cep/2017/march/improve-production-scheduling-increase-energy-efficiency.

Advanced production scheduling (APS) software uses mathematical algorithms and logic to optimize the use of inputs (resources, equipment, and labor) to develop schedules to optimize production or inventory given constraints. By improving equipment effectiveness, reducing changeover and startup timing, and improving supply chain utilization, not only can a facility schedule more effectively and predictably, but it can also save resources. And among the resources saved by more efficient scheduling of processes is energy and, as an extension, energy costs, as well.

Therefore, look into upgrading your scheduling processes, including obtaining the best APS software available for maximum benefits.

Another newer technology that can save energy and costs, but not thought of that way, is the driverless car, something that will likely soon be implemented. Of course, a lot of publicity about driverless cars centers on safety. Can one be driven safely in one’s neighborhood or across the country without an accident (or very few)? One thing that is forgotten is that with software and algorithms, controlling a car (and not a human with limitations and performing actions based on emotions) becomes more direct. The software can determine the true route of the shortest distance travelled, not the guess of a person. The software can control the movement of the car so that it is consistent and has fewer stops and starts. All this should lead to improved gasoline mileage and with that, gasoline costs saved, not to mention air pollution impacts reduced, too. Multiply this by millions of cars driven this way, it could lead to a great savings in overall gasoline or diesel usage worldwide (and improved air quality on the ground level). This is of particular interest in the trucking industry, which would look favorably of reducing labor and fuel usage.

CCES has the experts to help your entity find ways to save energy and energy costs, whether through conventional, proven technical upgrades of existing systems, changes in behavior, or “out-of-the-box” approaches. Contact us for more information today at 914-584-6720 or at karell@CCESworld.com.

USEPA On the Chopping Block

As of this writing, President Donald Trump’s proposed budget cuts USEPA funding by 31% and staff by 20%, the largest proposed cut of any agency or department in the federal government. What would this mean to us in the environmental community? Fewer environmental regulations and reduced enforcement. If the proposed budget is approved (initial budgets are rarely approved as proposed), the USEPA budget would be cut to $5.7 billion, its lowest level in 40 years, adjusted for inflation.

The Trump Administration says the budget cuts would move the USEPA’s focus back to its “core legal requirements” of safeguarding air and water.

The proposed USEPA budget would eliminate over 50 programs, including Energy Star, the Chemical Safety Board, and regional programs that not only clean polluted areas, but also provide job training in under-served areas. There would be major cuts in enforcement of Superfund and the Clean Air Act, promoting greater emissions. A number of governors – even Republicans – seeing other benefits to these programs, have criticized the proposed cuts. Therefore, many believe that Congress will renew and fund some of these programs before the budget is approved.

Philosophically, the new administration wishes to transfer lawmaking and enforcement responsibilities to the states, with the USEPA retaining only a minor support role.

In addition, on March 13, President Trump gave all executive branch agencies, including the USEPA, 180 days to conduct an internal review and to propose reorganization plans to “improve the efficiency, effectiveness, and accountability of that agency.” The intention is to recommend and then institute the potential elimination or major paring down of agencies or divisions deemed unnecessary and to merge redundant functions. The criteria for change includes:

• whether some or all of the functions of an agency is even necessary or important to the public, or justified by the public benefits that it provides,

• whether some or all of the functions of an agency would be better left to state or local governments to administer or be unregulated and left to the private sector,

• whether some or all of the functions of one or multiple agencies are redundant,

• the costs of shutting down or merging agencies, components, programs, and terminating staff.

This presidential order includes receiving comment from the public and affected stakeholders through Federal Register Notice.

In addition, a subcommittee of the House Energy & Commerce Committee recently heard testimony on how to improve the USEPA’s Clean Air Act and Brownsfield program of CERCLA. The intent of the hearings, according to the Republicans who head the subcommittee, is to determine how updating these environmental rules can result in expanded economic opportunities, infrastructure, and manufacturing.

It is no secret that a broad goal of the new administration is to revise or eliminate environmental laws that are perceived to hurt business growth. A major initial target of this effort is the repeal of the Clean Power Plan of the Obama Administration, which is expected shortly. A simple majority of Congress can repeal rules passed in the waning days of the previous administration. The same may be true of federal rules finalized in January that would increase fuel economy to the equivalent of 54.5 mpg for cars and light-duty trucks by model year 2025. Recent studies differ on the cost to auto manufacturers to comply. The new administration cited one study indicating a high cost, while a more recent study accused the first study of overstating the cost of compliance by industry by 40%. (https://www.theicct.org/us-2030-technology-cost-assessment)

Of course, critics and the environmental community have a lot to say about these various proposals, mainly that most environmental laws have public health benefits, such as reduced premature death, reduced hospitalizations, and improved worker productivity that is much greater than the costs of particular industries to pay for the environmental upgrades necessary to comply. For example, the Office of Management and Budget stated that between 2001 and 2011 that the benefits of USEPA regulations far exceeded the actual costs to implement and comply: $141 billion to $691 billion in benefits compared to $42 billion and $66 billion in costs. https://www.congress.gov/congressional-report/113th-congress/house-report/237/1

Also, by eliminating many USEPA programs, including scientific research, there will be less scientific data available to substantiate a need to modify or toughen a specific existing rule; yet the need may be there. If environmental management is left to the states, there will be less funds available to perform such research. This is part of an anti-science bias of the new administration alleged by critics.

CCES has the experts and experience to perform a comprehensive technical (not legal) review of your compliance status vis-à-vis air and other environmental regulations. We keep up to date on changes at the federal and state level. Contact us today to see how we can help you reduce compliance costs at 914-584-6720 or at karell@CCESworld.com.

New Leadership at the USEPA and Its Impacts

Scott Pruitt has been confirmed and is now the Administrator of the USEPA. His history and stated opinions about environmental compliance are different from probably every previous Administrator. What are the implications for us environmental professionals?

During the campaign, Donald Trump spoke robustly about his disdain for environmental regulations, probably because of the costs and delays he had to endure as a real estate developer. He clearly believes in removing barriers to short-term business growth and that complying with environmental regulations is one example. He has also stated a belief in using whatever source of energy is most convenient, cheaper, and home-grown, and not concerned about whether it is cleaner or not. Finally, President Trump has expressed strong skepticism about the science of climate change, although he has moderated his stance more recently. Scott Pruitt appears to mirror these beliefs of the President, and has shown to perform actions to argue against environmental laws to help industry produce more, faster, with less to clean up.

Therefore, we can expect to see an attempt to boost production of US-produced coal, natural gas and oil. While Pruitt may attempt to remove environmental barriers to business and energy growth, there are other factors at play, such as a nation with an oversupply of cheap oil from domestic producers looking for markets and foreign companies needing the revenues. Plus, we already have an excess of natural gas due to fracking. Even if environmental rules are relaxed, coal may well be the source of energy left out because of the large cost to mine and process it and to combust it.

As this is written, it appears to be a certainty that President Trump will issue executive orders to keep older coal plants competitive and to repeal (or never put in place) the Clean Power Plan, meant to reduce greenhouse gas (GHG) emissions. The Clean Power Plan was written and signed into law by President Obama as the US’s response to the Paris Climate Conference to reduce GHG emissions significantly.

Administrator Pruitt has written that he believes that it should be more the states and less the federal USEPA that make most environmental decisions as they are closer to the impacted populations than a Washington bureaucracy. The problem with this is that pollutants know no borders and can drift and impact the health of people in other states.

Ultimately, President Trump and Administrator Pruitt value business growth and the American jobs that will come from them more than cleaner air, a more stable climate, etc. They believe that this is a zero-sum game and that you cannot have good business growth while respecting the environment. This despite the calls of hundreds of major American companies to retain many current federal environmental rules and of a growing number of Republicans to introduce a carbon tax with the proceeds returned to the public to reduce GHG emissions. Even major oil industries, which are big in Pruitt’s home state of Oklahoma, have put out statements in favor of a carbon tax to replace the patchwork of international climate change rules. They well may favor this, too, because many also produce and sell natural gas and many are investing in renewable energy.

Another concern for all of us in the industry is the research and development function of the USEPA. There is talk that Administrator Pruitt will end or greatly reduce the research funding that the USEPA provides, research into alternative ways to treat contaminated air, soil, etc. and cleaner energy, not to mention the communication of such advances. All to reduce the budget deficit. Some Republicans have said that it is not right to “bet” public money on certain technologies. On the other hand, that little upfront funding has resulted in breakthrough technologies that are cheaper than older ones. There is a long history of federal funding of new technologies, such as through NASA. It is almost certain that Administrator Pruitt will cut some R&D; how much is the question. Might there be enough private money to continue such research, such as sponsored by Elon Musk, Bill Gates, and others?

Perhaps the biggest concern about the new administration of the nation and energy and environmental policy is whether it will be taken over and impacted by idealogues or whether some practicality and stability will remain. There has been talk about eliminating an agency; the Dept of Energy is now being headed by Rick Perry, someone who called for its elimination a short time ago. It is not likely to happen because Energy oversees nuclear weapons and the public would not allow scenes that are in the news recently of people in China, India, Poland, and other countries having to walk around with masks on during routine walks and travel. It is likely that the new administration will cut down on regulations and their enforcement, but keep enough on the books to save companies compliance fees, but not cause a catastrophic deterioration of quality of life. Of course, if they miscalculate and an accident happens, the tide can turn. Also, it is certainly important and proven that being energy efficient and conserving the environment makes good economic sense to all businesses.

It is unlikely that even repealing many existing rules and paring back the operations of the agencies will impact us in the long-term. Energy and environmental issues will not go away; neither will ignoring climate change. In fact, more private businesses – in a competitive field – understand good environmental policy is good business. And we professionals will be needed to implement the best science to move forward.

CCES has the experts to keep you abreast of changes in environmental and energy rules and their impacts to your operations. We can perform the technical assessments for you to determine compliance and recommend appropriate, cost-effective technical strategies. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Despite Election, Six Reasons Why Clean Energy Will Still Do Well In The Future

With a new presidential administration and team at Energy and the USEPA soon to be sworn in, it is assumed that the US will repeal many current environmental rules, attempt to develop more of its own fossil fuels, and walk away from Paris climate change commitments. However, there are strong economic, global, and non-political factors that will move the US away from these actions or prove that they are actually harmful for the companies that the new Administration wishes to benefit the most.

Here are six reasons:

1. Economic forces are stronger than repealing a few rules. Right now, there is a glut of oil relative to demand, as many nations are only slowly recovering from the Great Recession or are entering a new slowdown themselves (i.e., China). Should the US succeed in greater exploration of coal or crude oil or invest in improving pipelines to move the oil, this will be a “dump” in the market, pushing down prices more and reducing profit margins of coal and oil companies. This would be true even if this growth were to take a few years, as futures markets will react.

Further, if the Trump Administration gets its wish to relax or repeal many environmental rules, which they believe is “holding back” energy companies, economic forces will make coal, oil, etc. more inexpensive. Other oil and coal producers (Russia, Iran, Venezuela, Middle East, etc.) are all desperate for revenue to keep their regimes going and populations happy, and are likely to dump as much energy supply on the market as possible. The US will just add to that. Despite OPEC agreements to hold back putting oil on the market, countries will want to maximize needed revenue. Economic forces are greater than loosening some environmental rules.

2. The effort to get fossil fuel supplies. Even with a “green light” from Energy or the Interior, as time goes on, it will get harder for companies to drill for or mine oil, natural gas, or coal. Companies naturally look for the easiest and cheapest sources. In the future, companies will need to dig deeper or in further away places than years ago, raising the baseline cost. Because of oversupply the price of a gallon of crude oil or coal may not be worth the cost to produce it – even if environmental regulations were to be relaxed (if this is even allowed).

3. Improved technology favors clean sources of energy. Another economic force that even the Trump Administration cannot stop is technology. Improved technologies are being invented and successfully implemented all the time to make renewable energy more effective, practical, and affordable. New wind farms in west Texas can be built for as little as $22/MW, and solar farms in the desert for about $40/MW. In contrast, the cost to build a new natural gas-burning power plant is estimated to be about $52/MW and for coal about $65/MW. Even if environmental controls do not need to be included, there will still be a gap and that gap will climb as renewable technology improves more. There is also the crucial issue of time. Renewable power plants can be up and running in a matter of months; for a fossil fuel plant to begin operation, it’s years.

While causing GHG emissions, natural gas will also be favored because it is lower in GHG emissions compared to oil or coal and can be shipped overseas as LNG much more conveniently and cheaper than oil or coal.

There is also forecasted progress in battery storage capabilities. Thus, it is likely that eventually, all forms of transportation will be able to operate using electric power, lessening the need for gasoline or diesel oil combustion, resulting in lower GHG emissions and saving money, too. It is not an accident that major oil & gas companies are all investing in energy storage, LNG, and renewable energy.

4. Growing understanding of the impacts of “dirty” fuels. Another factor favoring clean energy is the strength of the problems and growing understanding about the impacts of “dirty” energy. There is much worldwide publicity about the air pollution issues in China with pictures shown worldwide of filthy vistas and people walking around in masks. Asthma and other lung diseases have risen dramatically, and the Chinese now realize that environmental issues are high impact economic issues, too, affecting future growth. Many other locations worldwide are learning this, too. So even if the Trump Administration tries to repeal many environmental and public health rules, it will not succeed because of the risk of such scenes becoming common in the US and that world markets, with the biggest component, China, in the lead, will move away from dirty fuels and toward renewables over the next few decades.

5. The power of the States. While those picked to run national environmental and energy policies have historically fought to repeal many regulations, the States have considerable sway in their energy mix. More than half of US states have laws requiring utilities to incorporate a minimum percentage of renewable energy into their generation mix. Some such rules are in force in states considered conservative politically. Some states have very aggressive goals. These will force utilities to contract for or build plants for renewable power in the near future, independent of who is President.

In addition, some states administer GHG emission rules that have been determined to be effective in getting utilities to move away from coal toward renewable power. The Regional Greenhouse Gas Initiative (RGGI) is a cap and trade system for GHG emissions from large power plants in 9 Northeastern states, and is considered a success as it met GHG reduction goals ahead of schedule at a relatively low cost to the regulated utilities. California has aggressive rules it is enforcing. Other states are considering similar rules to encourage renewable power in their states.

6. The power of the private sector. In addition to the States, some major corporations have thrown in their lot to move toward a heavy reliance for renewable power, including Wal-Mart, Microsoft, and Google. It is in their long-term plans to maximize renewable power as their source of electricity for a variety of reasons, including reliability of supply (the sun will always shine, while there could be an embargo or shortage of oil or coal). For the most part, these companies have succeeded and saved energy costs, as well. Other companies are likely to see the success and authorize their own programs to catch up and obtain the benefits.

While there is much to worry about in terms of our future work in the environmental and energy sectors, these factors, beyond the control of the upcoming Administration, should ensure that there is much progress in the future for clean energy, environmental safeguards, and renewable powers.

CCES has the experts to help your company assess impacts of future environmental or energy rules. We can provide you technical advice to help you determine your current status and determine strategies in the future to put yourself in a better place. Contact us today at 914-584-6720 or at karell@CCESworld.com.

USEPA Proposes Revisions To PSD And Title V GHG Permitting Rules

On October 3, 2016, the USEPA published a proposed rule to revise the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Rules in reaction to a US Supreme Court ruling in 2014 (https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0355-0001).

The most critical change is that the proposed rule would provide a Significant Emissions Rate (“SER”) for GHGs, 75,000 tpy CO2e SER. An applicant that is subject to PSD because proposes to build and operate a new facility or to an expand an existing one that would cause emissions of an existing PSD pollutant to rise by more than its significant level (an “anyway” source) and also GHGs by at least this amount would need to have performed a Best Available Control Technology (“BACT”) analysis for both the subject PSD pollutant and GHGs, as well. Previously addressing GHGs as part of a PSD Permit was limited to “anyway” sources (not sources that exceed a de minimis for GHGs). The proposed revision would prevent the USEPA from exempting from GHG BACT requirements “anyway” sources if it proposes to emit GHGs above the SER guideline.

The proposed rule would also revise several definitions, including a definition of GHGs itself and of CO2 equivalents (CO2e). GHGs is any of a group of 6 compounds, including CO2, N2O, CH4, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. CO2e is calculated by taking the tons per year emission totals of each compound (or set of compounds) and multiplying this by its “global warming potential” published in the rule, and summing them. The proposed rule also provides for the exclusion of GHG emissions from “major source” and “major modification” determinations.

The comment period of the proposed rule is over. Of course, with the new administration taking over in January, it is unknown whether the new USEPA administrator will drop these proposed changes and not have any action about GHG emissions and permitting under the Clean Air Act.

CCES has the experts to allow your facility to make the technical decisions concerning air emissions and compliance with GHG and Clean Air Act rules. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Study Shows Effects of Green Building Conditions on Human Performance

People spend about 90% of the time indoors. Therefore, the indoor built environment plays a critical role in our health and our ability to function at our jobs and as people. A major study by the Harvard T.H. Chan School of Public Health’s Center for Health and the Global Environment was designed to evaluate the effects of different indoor environmental quality parameters found in green and conventional buildings on human performance. See: http://www.chgeharvard.org/resource/impact-green-buildings-cognitive-function

The study had 24 people spend 6 full work-days in different controlled office environments, representative of conventional and “green” office buildings. Participants spent time in office space either with indoor air containing a “conventional” concentration of volatile organic compounds (VOCs); indoor air with a much lower concentration of VOCs typical of “green” buildings; or indoor air with the lower concentration of VOCs and an enhanced ventilation rate. Participants were not told what the conditions were in which they were working.

At the end of each day, participants were tested to evaluate live decision making capabilities by simulating real-world scenarios. On average, cognitive scores were 61% better for workers exposed to indoor air with lower VOC concentrations compared to conventional air quality and were 101% higher for workers exposed to the lower VOC concentration with the enhanced ventilation compared to those exposed to the conventional VOC concentration and ventilation.

Additional studies were performed exposing workers to different indoor levels of CO2 and determining performance. Correlation of improved performance to green building scenarios was also measured.

These studies provide further demonstration that properties that lead a building to be designated as “green” have real-time positive effect on a person’s performance in the workplace and on health.

CCES can help your buildings evaluate and implement changes to become more “green” and maximize the positive benefits of such upgrades, such as tenant performance and happiness, cost savings, reduced O&M, etc. Contact us for more information today at karell@CCESworld.com or at 914-584-6720.

The Future Of Energy And Environmental Policies In A Trump Administration

November 10, 2016

Last month I wrote an article about the potential course of events for environmental and energy policies if either presidential candidate was elected. Now we know there will be a Donald Trump administration. So first I will repeat the thoughts about what a Trump administration might look like when it comes to energy/environmental policy, and I’ll present some early policy areas being considered. Nothing here is written in favor or against any policy, but future issues facing the energy/environmental professional.

Energy: Donald Trump has been severely critical of current energy and environmental policy and has stated he will reverse many of President Obama’s initiatives. During a May 26 speech, Trump reflected a desire to achieve US energy independence by reducing federal regulations on the energy industry, increase investments in fossil fuel development and infrastructure to bring it to market (such as supporting the Keystone Pipeline), and reduce federal investment in renewable energy, as he has criticized both solar and wind power. Trump also supports increased use of nuclear power.

Environment: Trump has stated he would rescind a number of President Obama’s environmental rules, such as the Clean Power Plan. As a real estate developer, Trump has a particular aversion to environmental rules which he felt has cost him unnecessary money and delayed his projects. He has also specifically pointed to the Clean Water Act as another regulation he would greatly weaken. Reversing or weakening these and other EPA rules would require EPA rulemaking, requiring a public notice process. A Trump Justice Department may just not defend these and other environmental rules when challenged in court by industry. Neither approach would ensure success, as environmental and other groups would surely marshal forces in defense of the rules. Furthermore, courts could rule that these regulations are valid, legal, and necessary.

Climate Change: Trump stated on the campaign trail several times that climate change has not been proven. However, closer to the election, he was more neutral about the topic. He certainly feels it is not a high priority. He has expressed his intention to withdraw the US from the Paris Climate Agreement, which may be difficult to do. Trump could do as little as possible to implement it, which has weak enforcement mechanisms. He has also stated he would stop all US payments toward UN climate change initiatives.

Early Steps

One of Trump’s main advisors on environmental issues is Myron Ebell, a known climate change denier. There is speculation that he may be put in charge of the EPA. Mr. Ebell has been very critical of not only climate change, but also of recent Obama environmental rules. There is speculation that he may even call for the repeal of signature environmental rules, such as the Clean Air Act and Clean Water Act, and the dismantling of the EPA. This would likely require passage by Congress. Both houses of Congress are controlled by Republican majorities, but slim ones. There are many Republicans who believe in climate change and environmental rules or live in districts with constituents who would be bothered by radical change like this.

Published reports have stated that Mike McKenna has been a major advisor for the transition team on energy issues. He is a former DOE employee, and has been a lobbyist for several oil & gas and chemical companies. It is believed that a Trump-led DOE and Republican Congress would open up more federal land for oil exploration and encourage more coal production by repealing rules discouraging it. This would lead to greater energy supply, lowering prices for consumers, but also potentially raising risks of costly environmental damage. Many have argued that with other countries willing to supply much oil, gas, and coal to the global market and with rising exploration costs, the market may convince many oil & gas and coal firms to restrain anyway. With fracking and a large natural gas supply, coal and oil may yet be too expensive to invest in even with reduced regulations. But it appears that’s the direction of the new administration.

While this is happening on the federal level, it is certainly conceivable that states or groups of states will re-double their efforts to enforce meaningful environmental rules. However, with weak federal rules, one state’s lax rules could attract new businesses in place of a state with stricter rules to protect its public’s health.

And finally, there is the market. Many people were shocked by Trump’s electoral victory, but the sun still came out the next day, and with it solar and other renewable energy. While Trump has been critical of its implementation, the market has certainly favored this and being more energy efficient, as renewable power and energy efficiency programs have grown tremendously in the last few years. Renewable power is generally cheaper, growing in reliability, and reduced in cost compared to many fossil fuel applications. While dis-incentivizing these programs may set them back, positive results in the market should still attract business.

CCES can help you evaluate your company’s energy use and environmental impacts and can perform the technical aspects to determine compliance with current rules and develop opportunities to reduce your energy usage and diversifying sources, saving you money and decreasing business risk. Contact us today at 914-584-6720 or at karell@CCESworld.com.

The Future Of Energy And Environment Policies Under The Next Administration

October 17, 2016

While most of the analysts predict a Clinton victory and Democratic administration, here are some thoughts about what a Trump administration might look like when it comes to energy/environmental policy and what may change in a Clinton Administration. As I have written in other blog articles, nothing here represents writing in favor or against a candidate or policies, but instead addresses future issues facing the energy/environmental professional.

Should There Be a Trump Administration.

Energy: Donald Trump has been severely critical of current energy and environmental policy and has stated he will reverse many of President Obama’s initiatives. During a May 26 speech, Trump reflected a desire to achieve US energy independence by reducing federal regulations on the energy industry, increase investments in fossil fuel development and infrastructure to bring it to market (such as supporting the Keystone Pipeline), and reduce federal investment in renewable energy, as he has criticized both solar and wind power. Trump also supports increased use of nuclear power.

Environment: Trump has stated he would rescind a number of President Obama’s cornerstone environmental and energy achievements, such as the Clean Power Plan. Trump has also specifically pointed to the Clean Water Act as another regulation he would greatly weaken if he were elected. Reversing or weakening these and other EPA rules would require EPA rulemaking, requiring a public notice process. A Trump Justice Department could just not defend these and other environmental rules as they are challenged in court by industry. Neither approach would ensure success, as environmental and other groups would surely marshal forces in defense of the rules. Furthermore, courts could rule that these regulations are valid, legal, and necessary.

Climate Change: Trump has stated on the campaign trail that climate change has not been proven. In a recent speech, he was more neutral about the topic, but has expressed the feeling that this is not a high priority. He has expressed his intention to withdraw the US from the recent Paris Climate Agreement. With the Paris Agreement officially ratified, it would be difficult to withdraw, although Trump could likely do as little as possible to implement the Agreement, which has flexible objectives and no enforcement mechanism.

Should There Be a Clinton Administration.

Energy: To enable energy independence, Hillary Clinton has outlined a wide ranging list of investments by the federal government, such as clean energy, upgrading energy infrastructure, promoting responsible domestic drilling for oil and natural gas, and building on many of the core energy and environmental programs of the Obama Administration, such as the Clean Power Plan and Paris Climate Agreement. Clinton has spoken out in favor of natural gas development, citing it as a bridge fuel in the transition away from coal, including supports for fracking, although she has stated that deference should be given to localities who wish to ban it in their communities. Despite the “all of the above” approach in energy development, Clinton has stated policies that would discourage coal as an energy source, unless acceptable environmental levels are met. Clinton issued an infrastructure plan, prioritizing the development and repair of large-scale energy infrastructure across the country. Clinton would likely seek to continue the current Administration’s strong support for renewable energy development, call the US a future clean energy “superpower.” Clinton’s specific plan increases the percentage of renewable generation to 25% of total national energy mix by 2025.

Environment: Clinton supports the Clean Power Plan and wants to expand it in other industries in order to implement “smart” pollution and efficiency standards. Clinton has given no specifics, but states she supports additional policies to reduce US greenhouse gas emissions.

Climate Change: A Clinton Administration has committed to continue to abide by the Paris Climate Agreement. The Democratic Party platform stated: “Democrats believe that carbon dioxide, methane, and other greenhouse gases should be priced to reflect their negative externalities, and to accelerate the transition to a clean energy economy.”

Control of Congress.

Remember that while the President wields considerable power through the EPA and DOE, control of Congress is certainly important, too, in “setting the tone”, promulgating new rules and funding existing agencies. Republican control of the Senate and perhaps the House is in play in the upcoming election. A Democratic control could dramatically change the policies of several related committees in the Senate and House.

Senator Lisa Murkowski, the current chair of the Senate Energy and Natural Resources Committee, has been a strong advocate of the “all of the above” approach to energy. She supports energy exploration on federal land, such as in her home state of Alaska. Senator Maria Cantwell is the ranking Democrat on this committee and would likely chair it if the Democrats take control of the Senate. She has billed herself as a champion of “smarter” energy policies to diversify energy sources and lower costs for consumers. Senator James Inhofe, the current chair of the Senate Environment and Public Works Committee, is a noted climate change skeptic and strongly supports scaling back environmental regulations and promoting greater domestic energy production. If the Senate flips to Democratic control, Senator Tom Carper is expected to chair this committee.

CCES can help you evaluate your company’s energy use and environmental impacts and can perform the technical aspects to determine compliance with current rules and develop opportunities to reduce your energy usage and diversifying sources, saving you money and decreasing business risk. Contact us today at 914-584-6720 or at karell@CCESworld.com.

Cross-State Air Pollution Rule Affecting Power Plants Finalized

On September 7, 2016, the USEPA finalized an update to the Cross-State Air Pollution Rule (CSAPR) for the 2008 ozone National Ambient Air Quality Standard (NAAQS) by issuing a final CSAPR Update. See https://www.epa.gov/airmarkets/final-cross-state-air-pollution-rule-update. The final rule has not yet been published in the Federal Register.

CSAPR was designed to address facilities that cause significant pollution that travels long distances impacting people in other states. States in which these facilities operate have not been motivated to regulate their emissions as it does not affect the health of their citizens. This federal rule achieves this. USEPA estimates that the rule will reduce summer (May – September) emissions of nitrogen oxides (NOx) from power plants in 22 states, result in benefits totaling up to $880 million, and reduce ground-level ozone exposure for millions so people, reducing rates of asthma, cancer, and other diseases.

Beginning in May 2017, the new rule will affect 2,875 electric generating units at 886 coal, gas and oil power plants. The USEPA says affected power plants can achieve the required NOx emissions reductions using existing, cost-effective technology.

Under CSAPR, each of the 22 states hosting an affected electric generating unit must develop state implementation plans meeting minimum NOx emission requirements under the supervision of the USEPA which could issue a federal implementation plan for each state that fails to submit an approvable plan.

The power industry has come out against CSAPR since its inception, suing the USEPA. The US Supreme Court upheld the CSAPR in 2014. However, the US Court of Appeals, DC Circuit in July 2015 remanded parts of CSAPR to the USEPA for updating, and this is the final update. This update is based on downwind areas meeting the 2008 ozone NAAQS of 75 parts per billion, and not the subsequently updated standard of 70 ppb. The power industry is still not happy with the updated version and a legal challenge to CSAPR is likely.

CCES has the technical experts to help your company implement the technical requirements to comply with a variety of environmental and air quality rules. Our engineers can perform an emissions inventory and determine from a technical point of view how to maintain compliance or get in compliance with federal and state air rules. Contact us today at 914-584-6720 or at karell@CCESworld.com.