Category Archives: Climate Change

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 or at 914-584-6720.

U.S. Climate Change News October 2017

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

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

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

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

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

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

Future of the Clean Power Plan Under Pruitt

September 2017

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

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

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

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

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

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: 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 ( 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

Future of Renewable Energy Investments

The young Trump Administration and the House of Representatives have published preliminary tax reform plans that will likely have an adverse effect on the future growth of renewable energy in the US. If enacted, these may be a dis-investment for new projects. While exact details are unknown, as this is published, the fear of future dis-incentives to build or finance a project itself has a chilling effect.

One matter that has not been discussed openly is the future of renewable energy tax credits. Currently, investments in solar and wind projects are eligible for an investment tax credit. However, over the next few years the credit, used for many solar projects, is scheduled to decrease to and remain at 10% beginning in 2022. The production tax credit for producing power from wind will phase out entirely in 2020. Might the Trump Administration accelerate the decrease in these incentives or eliminate them sooner? During his confirmation hearings, Secretary of the Treasury Steven Mnuchin said that he does not intend to accelerate the phase-out of the production tax credit.

Note that the current renewable energy credit programs result in tax credits that can only be used to offset taxes (not increase a refund). With the proposed major reduction in corporate and individual income tax rates and accelerated write-offs for business expenses, the value of renewable energy credits would therefore be sharply reduced (lower taxes to offset with credits from a renewable energy project). This could take away the financial incentive to invest in large-scale renewable energy projects.
The Trump Administration’s proposed tax reform also includes a border adjustment tax, raising the cost of imported material and equipment. Since many solar and wind farms components come from China, this could add to the cost of new projects, if adopted.

In another tax-related item concerning energy, 22 US Senators recently introduced a bill containing a proposed extension of EPAct (Section 179D of the IRS Code) until 2019 and beyond. EPAct allows a building owner (or significant contributor for tax-exempt buildings) to earn tax deductions for successful energy efficiency projects. EPAct has expired and is currently not in effect. The proposed bill contains changes to the old language, including new technology-neutral tax incentives for clean energy. If this version of the bill is enacted, the maximum deduction for energy efficiency projects would increase to $4.75/sq.ft., based on achieving a minimum of $1.00/sq.ft. deduction for achieving a 25% reduction against the ASHRAE 90.1-2016 standard, and an additional $0.25/sq.ft. for every additional 5% reduction above that. The proposed bill also contains a new provision, entitling building owners to achieve a tax deduction of up to $9.25/sq.ft. for comprehensive energy upgrades that exceed energy saving targets. While the old 179D allows minor deductions for small upgrades, the proposed version would reward a building owner that exceeds robust energy goals. It is unsure whether this new version of 179D will pass Congress and, if so, when.

In summary, while details are unknown, the proposed new tax reforms of the new Administration may potentially hurt renewable energy projects. At this early stage, it is unknown whether these proposals will be enacted and in what form. Might the changes be enacted and the renewable energy industry in the US be hurt in order to raise revenue to offset the many tax rate reductions the reform plan currently proposes or as a way to discourage renewable energy and encourage growth of fossil fuel plants? The answers are unknown, but the implications should be part of any company’s planning.

This is meant as a general overview based on publicly published material. Discuss specific implications for your business with your accounting or tax professional. CCES is here to help you with technical assessments of your energy usage and systems. We can present sound technical strategies to reduce your energy use and peak demand and save you considerable cost and provide other tangible, financial advantages, as well. Contact us today at or at 914-584-6720.

Some Thoughts About the U.S. Leaving the Paris Climate Accord

June 2017

Of course, this blog and newsletter stays away from politics. But I will make a rare exception here just because the name of our firm, Climate Change & Environmental Services, is so close to the news at hand: President Trump decided that the U.S. should pull out of the Paris Climate Agreement. I wish to share some thoughts about it. Please feel free to comment, in agreement or disagreement. Respectful comments are what our democracy is about.

First of all, the withdrawal was no surprise. While I am not a professional psychologist nor have ever met President Trump, it is pretty obvious that he is a narcissist. He thinks of himself and raising he ego first, second, and at all times. Part of that is he not a team player. He thinks of himself first with others to be used and tossed away, even his most loyal supporters, whether they be contractors working on his projects or his own government professionals who he has embarrassed by changing his story. Thus, he would never have accepted being part of a deal where he represented only one of 195 countries, even if it were the most powerful. He does not know how to abide by rules and compromise meant for many. And especially in a topic he knows little about and probably fed falsehoods by some advisors. Nobody should have been surprised.

That said, I have my problems with the Paris Climate Agreement, in line with many critics (and Trump supporters): that it has no punitive actions for countries that do not succeed in their GHG emission reduction goals. This is no different from the previous Kyoto Accord. For example, Canada not only did not reduce GHG emissions by its goal in that Accord, but raised theirs significantly due to its discovery in the ‘90’s of the tar sands in Alberta. With the windfall Canadian companies made from that, even punitives would not have hurt Canada. How much might they have been fined? And who would collect it? And this went on for other countries, too. Same thing with the Paris Climate Agreement. Who would have the nerve and ability to “fine” a country for not making its goals and how much? Billions? However, that said, an agreement is an agreement and even one with flaws is better – given the Climate Change crisis facing us all – than business as usual. So it was important to work through this framework, and a missed opportunity for the U.S. to lead in Climate Change response and technology.

I am heartened, however, by the response to President Trump’s withdrawal by leaders in the U.S.: mayors, governors, and many business leaders. They have said they will re-double their efforts to reduce GHG emissions and use renewable power. They see the many business advantages of doing so, and will continue to do so. Let’s hope that their efforts will help the many, many small businesses and smaller governments in the U.S. to have the motivation to move forward and to help make such technologies affordable to them. If this momentum can grow and people see the advantages of addressing Climate Change issues, then this withdrawal from the Paris Climate Agreement may turn out – unexpectedly – to be a positive for the U.S. after all.

CCES has the experts to help you be on the right side of things when it comes to a Climate Change program and to help your company or entity get the greatest economic benefits from doing the right thing concerning GHG emission reductions with the lease disruption in your operations. Contact us today for a free discussion at or at 914-584-6720.

Be Careful Of What We Say In Environmental Communications

There has been a lot of talk and concern about the lack of scientific thought in many of the pronouncements of the Trump Administration. Scientific facts are discarded and simplistic non-truths are becoming the backbone of some decisions in the energy, environmental, and health areas. I don’t mean to play politics here, but this seems to be predominantly the doing of the “Tea Party” and other right-wing groups, trying to deny the validity of climate change and the importance of environmental stewardship, all in the name of “small” government or short-term economic and jobs growth.

As an engineer and citizen, I feel this is terrible. But, this has been well-covered, and I don’t wish to “pile on” here. I do want to note that this is not unique to the right wing of the US political spectrum. I have seen examples of scare tactics and lack of reasoning from the left wing environmental community, also. We need to be vigilant and hold all sides accountable. Everyone (right or left) is entitled to their opinions, but not their facts.

What brings this to mind is an environmental group local to where I live (which shall remain nameless) which puts out many misleading emails and articles, that a common situation is so untenable, that it will lead to public health or environmental disaster. The other thing they do is attack a certain facility or process, demanding it be shut down without discussing what would replace it.

I know the person who runs the organization. She’s smart and has quite a personal story. I have tremendous respect for her. But she has only superficial knowledge of environmental matters, and, again, feels that everything is a tragedy about to happen.

A few years ago, we both gave presentations at a local environmental event. I gave an overview for the general public about what climate change is and what scientists know about it. In explaining greenhouse gases, I stated the fact that GHGs are not in and of themselves toxic even at elevated concentrations, but cause the trapping of radiation to conserve energy from leaving into outer space. We have lived in balance with a certain GHG concentration in the atmosphere, but now are affecting it adversely. Afterwards, she took me aside and berated me for saying anything “positive” about GHGs. They were the bad guys, in her view, and needed to be seen as such. I challenged her to find any published article that states that GHGs have direct toxic effects and I’ll personally apologize to the event organizer and reach out to every attendee with a correction. She never did (of course). I told her the only way we can fight climate change effectively is for the public to fully understand the topic. It is not simple (“good guy” vs. “bad guy”) with a simple solution if only governments understood as she does.

Her organization is sponsoring a movie about zero waste and she put out an email about it and advocating the shutdown of our county’s waste-to-energy facility. It releases toxic compounds, she wrote, affecting all our health. We are in a dangerous area with high ozone and particulate levels. We must shut down the facility ASAP.

There are so many holes to her arguments. Zero waste is a great concept; I am for it. However, cities (San Francisco comes to mind) have had this as a formal goal and spent millions to research and implement and has failed. This is not something that will be achieved overnight. Even if the techniques and technologies are developed to do so, there is always the implementation by cities, counties, etc. and the willingness of the public to use them (many don’t like change or an added expense). As for the waste-to-energy facility, yes, it is certainly not emissions-free, but it operates under a Title V Permit which mandates compliance with several state and federal air quality rules specific for such facilities, developed with public health in mind. It has continuous emission monitors and does annual testing to ensure these emission standards are met.

The county that the facility is in (as well as where the movie is being shown) was recently moved from severe to moderate ozone non-attainment, and has not had an exceedance in nearly 3 years. Besides, it has been demonstrated that most of the ozone forerunners come from sources many miles upwind of our county. This facility is not the cause of the current ozone non-attainment, nor would shutting it down solve this. The county meets the particulate attainment standard (why did they say it does not?).

Finally, the statement from the group demands the immediate shut down of the facility. Fine. But what would one do with the garbage? The alternative is to truck it to a landfill, hundreds of miles away. Given the size of the facility, that would mean hundreds of trucks traveling this distance daily, combusting diesel fuel oil. The use of any fossil fuel is another frequent target of their attack. So they are indirectly promoting a solution they oppose. Conveniently not mentioned in the email! Not to mention this alternative would require many workers to be in contact with the waste, risking their health. And not to mention the methane gas and other pollutants potentially emitted from the landfill. Methane is 21 times more potent than the CO2 emitted from the waste-to-energy facility.

So, we in the environmental community also need to be careful what we say in our writings. That what we say and write is scientifically grounded, thorough, and accurate; is not wishful thinking nor simplistic; and that alternative scenarios are thought through.

I am curious your thoughts and experiences. Please let me know what you think of this.

CCES can help your company develop a science-based, effective environmental and energy program that can meet achievable goals and can help you communicate this with the public and with regulators. Contact us today at 914-584-6720 or at

Changes to Lights: You Won’t Recognize Them!

Lights as we know them are changing radically and probably quite fast.
In many technological upgrades, the upgrade is introduced first, but is slowly implemented as it is expensive. But as more competitors get into the business, both raw materials and the manufacturing process drop in cost, so that the upgrade becomes more affordable and with its advantages, takes over the market. This is exactly what we are seeing with LED lights. Initially, many people and companies while recognizing the steep drop in electricity usage, put off purchasing them because the upfront price was so expensive, even with government and utility rebates. But now raw material costs and global competition have forced prices downward, shortening the payback. So much so that many government and utility LED incentive programs are being slashed or even eliminated. Why provide a rebate when the technology is affordable? The payback is shortening so much and LEDs are so useful and reliable that it is a real “no-brainer”.

Similarly, occupancy sensors and other controls will be fairly standard, too. They have become more reliable since the days when sitting still in a room would lead to lights turning off. And, now due to “Alexa”, the whole concept of lighting control has changed.

Which leads me to my main point. Not only is lighting control changing, but the concept of lights is changing. For a century, lights were these bulbs that emit lumens of light after an external signal (electricity) turns on and off the mechanism of burning (in tungsten in an incandescent). A physical effect causing the ability of the bare bulb to produce light. But now, lights are no longer items that just produce light. Lights in a ceiling or outdoors are now becoming little computers that can both do many things and be controlled easily through the internet. Besides being turned on and off, they can be dimmed or made into strobes or other waves, or emit different color light over time, such as dimming or making a warmer tone close to bedtime. The miniaturization that allows a whole host of functions on an easy-to-hold cell phone can allow a simple “light bulb” in a high hat in a ceiling to perform many functions – even outside of lighting, such as being a sensor with a loud alarm or projecting onto a screen.

These functions can be controlled (turned on and off or made more or less intense and timed) using a cell phone or another computer hooked up to the Internet. You have probably already seen how Amazon’s “Alexa” can turn on and off lights (and other appliances and devices) with simple verbal instructions. There may be a day very soon where light switches on the wall are obsolete and no longer designed in buildings, as all lights will be controlled by a human voice. Apple’s “Siri” and Google’s “Home” are moving in this direction, as well.

The major LED light manufacturers (Philips, Cree, Lutron) already sell “smart” bulbs that can be wirelessly controlled though your home’s Wi-Fi. You are probably familiar with those circular timers that are plugged into an outlet and the lamp plug goes into it. When the time is a certain time, the raised portion turns on or off the electricity turning on or off the lamp. This same effect can now be done wirelessly. You can program into your PC or cell phone the times to turn on and off lights (for example, on at sunset, off at bedtime). You can program them to turn on or off groups or individual lights in a room or change their brightness to create the atmosphere you want (for doing desk work, for cooking, for eating, for watching TV) when you want.

The voice-activated systems, like “Alexa”, allow quick changes from programmed timers. Alexa does not have to be in the room with the lights whose timing needs to be changed. Certainly an advantage of any of the voice-activated system is to turn on lights in the dark when one is concerned about falling or tripping. Alexa, of course, operates through Google’s “Echo” voice system, a physically standing system in one or several rooms. Apple does not operate such a system for Siri. One would need to speak into a cell phone to give Siri directions which it could use to control lights. Cell phones are often forgotten or misplaced. A standard Echo system always in a particular room may – for some – be more reliable.

Smart lights can also be used for commercial purposes. Imagine a retail store changing the lighting patterns to emphasize certain products on shelves or mannequins based on the outdoor light and customers present and other factors. Imagine a manufacturing facility adjusting lights to the needs at a particular phase of the manufacturing process.

And – here’s a scary thought after we have spent so much time educating the public on LEDs – may they soon be obsolete? Growing research shows that lasers can be used in many lighting applications successfully and using less energy. Stay tuned.

CCES has the experts to help you evaluate, design, and install the most efficient, sturdy, and flexible lights for your building and usage, while maximizing the financial benefits. Contact us today at 914-584-6720 or at

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

Despite New Administration, Regional, State Climate Change Rules Progress

While the Trump Administration has stated its skepticism about climate change and actions to combat it, a number of states are planning to continue existing programs to address climate change issues and reduce greenhouse gas emissions (GHGs). These programs also help in encouraging energy conservation and reducing the need for infrastructure upgrades, resulting in greater reliability of the electric grid and significant cost savings for businesses and consumers.

On the day of President Trump’s inauguration, Jan. 20, 2017, the California Air Resources Board (CARB) released a draft Scoping Plan to reduce state GHGs. Under the state’s climate change law, Assembly Bill (AB) 32, CARB is required to produce a scoping plan every 5 years. The proposed plan may result in changes to the state’s GHG emission rules and cap and trade program in order to meet California’s enacted goals to reduce GHGs by 40% from 1990 levels by 2030. The proposed plan would extend the state’s cap-and-trade program out to 2030. CARB auctions off remaining emission allowances to sources of GHG emissions as the cap declines to the long-term reduction goal. The proposed plan would also require oil refineries to reduce their GHG emissions by 20%. CARB plans to issue a final Scoping Plan by the spring of this year.

The proposed plan makes no change to the state’s current Renewable Portfolio Standard of 50% of electricity from renewable energy sources by 2030. It adds a goal of reducing methane and hydrofluorocarbon emissions by 40% from 2013 levels by 2030.

CARB’s grand 40% GHG emission reduction goal was planned to be met mainly by the cap and trade program with enactment of some mandatory GHG emission reductions by certain industries. However, because there is litigation against the program (that the state does not have the legal authority to manage a mandatory cap and trade program) the proposed scoping document looks into alternative strategies for CARB to pursue, including additional industry-specific GHG emission reduction rules, a carbon tax, or a “cap and tax” system, which would consist of a more flexible cap and trade system together with a carbon tax for each ton of GHG emitted.

The Regional Greenhouse Gas Initiative (RGGI) composed of 9 Northeast and Mid-Atlantic states’ cap and trade program for utilities continues to progress well. The 2016 RGGI adjusted cap was 64.6 million short tons, decreasing 2.5% each year until 2020. The average price of CO2 allowances at the latest auction was about $3.55/ton. An estimated $4 billion in funds over the length of the program has been returned to the 9 states to implement energy efficiency programs.

While these are rules pertaining directly to climate change, there are myriad more rules that many states, cities, etc. are enacting and enforcing that will result in reducing GHG emissions. These include many energy benchmarking and conservation rules. New ones appear to be coming up “every day”. (For example, St. Louis just finalized an energy benchmarking rule.)

CCES has the experts to help you assess your GHG emissions and help you reduce it to maximize your financial benefits whether you are in a GHG program or not. Contact us today at 914-584-6720 or at