marc karell


Green Guru Memeber Marc Karell guided New York Daily News reported David Sheftell with last week's article:

"Lower East Side Coop Installs New Natural-Gas Boiler to Heat 2,700 Units"

Marc supplied technical expertise on this very interesting project. 




wind_energyAs an engineer, I hate to admit this. But for a long time, I used to think that achieving something, such as reducing your energy or water usage or increasing productivity, was the end all. You are doing good for your organization. Period. But this is not the whole battle. Documenting and presenting your achievements effectively to stakeholders is as important. If you succeed in meeting your goals, great; you will reap financial and clean energy benefits. But if you don’t document your triumphs and communicate it properly to your customers, employees, stockholders, etc., then you’ve missed the opportunity to show the program’s success and impact that will benefit both your organization and your own career. While we engineers like to achieve physical success, writing a sustainability report is essential, as well, although not necessarily one of our strengths.

If you are involved with a team writing a sustainability or CSR report, start by evaluating your audience. Who is likely to read it? What may those that actually read it look for? It is likely that people with different interests will read the report. People in Financial will be interested in the program’s monetary gains (how much money was saved); people in Environment or Sustainability will want to know GHG emission, waste and other metrics; people in Marketing will look to see how this can be used to further sell products or improve the company’s image. Therefore, make sure to include diverse bottom line facts in the report, so readers can glean satisfaction from it from their points of view.

As engineers and scientists, we take pride in data to prove our point, and data should be part of such a report to demonstrate indisputably what we say we achieved. However, it is important not to overwhelm the reader with data. A small number of summary charts or tables showing before and after are most effective. Bar graphs and pie charts are best to visualize a comparison. Make sure data is normalized to a business metric (GHG emissions / ton of product or / square foot of space) and can be benchmarked to compare to other facilities (including those of competitors).

Perhaps the most critical part of the sustainability report is the Executive Summary because, silly as it sounds, even people who this is important to are pressed for time and may not read the whole report. The Executive Summary must provide basic information and make an impression. So make sure not to write this hastily, throwing it together as the end of your reporting effort. Do not copy and paste from other sections. Make sure it is clear with key bottom line information for the different audience groups.


air_pollutionJune 2012. It may be summer, but the USEPA is working to push forward new rules that will affect your company and job in the air pollution and climate change areas. Of course, potential rules go through public comment and the USEPA must address many from well-organized industry and environmental groups. Thus, how final rules will shape up is always up in the air. Here are some air rules addressed by the USEPA in 2012.

New NAAQS Standards


The USEPA just announced (June 14) new, tougher draft NAAQS standards for fine particulate matter (PM2.5). In addition, there will be a proposed secondary standard to protect visibility. The USEPA proposes to reduce the primary PM2.5 annual standard from 15 to 12-13 µg/m3, and the new secondary standard would be 28 to 30 deciviews (24 hour standard). The NAAQS for coarse PM will remain unchanged. These proposed standards have not been published in the Federal Register yet, but will trigger a 63 day public comment period. The USEPA plans to issue the final PM standards in December 2012. These changes, if finalized, will cause more areas to be non-attainment for PM2.5 and states to promulgate new rules to reduce transport and stationary PM emissions.


The ozone NAAQS is also very controversial. The proposed 2008 standard of 0.075 ppm has been held up by legal challenges. On Apr. 30, 2012, the USEPA issued a final rule directing its implementation, which will be similar to the way it was done previously with end of year assessment of percentage of 8 hour periods in excess of the standard and 5 different nonattainment categories. The USEPA also noted that new proposed ozone standards must be made every five years and thus, the agency will likely issue new draft ozone NAAQSs based on the latest health science studies in 2013.

Boiler/Incinerator/Area Source MACT


On Dec. 23, 2011, draft changes of final MACT rules for industrial, commercial and institutional boilers were published in the Federal Register. These will be 40 CFR Part 63, Subpart DDDDD (“5 D’s”) for boilers at major sources for HAPs and Subpart JJJJJJ (“6 J’s”) for boilers at area (non-major) sources, such as many office buildings, shopping malls, hotels, universities, residences, etc.. The USEPA announced in March that it will not enforce against area sources that have not reported to the program. The draft changes are currently being reviewed by the Office of Management & Budget and the final amended Boiler MACT standards are expected to be published in July 2012.

Utility MACT

The final MACT standards for power plants went into effect on Apr. 16, 2012. After much machinations over 11 years, the final rule still generated controversy. The rule gives the USEPA the option to add an additional year to comply. However, the requirement to reduce mercury emissions from coal-fired plants by 90% is felt by some to be the death knell for many older plants. Senator James Inhofe, a Republican, has put a bill in the hopper to prevent the implementation of this MACT rule. While it has not been voted on yet, there is an interesting controversy as Republican Senator Lamar Alexander of Tennessee has offered support for Utility MACT, even though it will impact Tennessee Valley Authority coal-fired plants, stating that the Utility MACT will improve the health of his constituents impacted by emissions from other states; thus, TVA plants must comply, too. With a well-known Republican supporting the Utility MACT, it is presumed that Inhofe’s bill will have problems passing. The utility industry has warned it would challenge various aspects of the rule, although no court action has begun yet.

Cross-State Air Pollution Rule

The USEPA issued the Cross-State Air Pollution Rule (CSAPR) on July 6, 2011 to replace the Bush-era Clean Air Interstate Rule (CAIR) under an order of the U.S. Court of Appeals in 2008. This regional rule protects downwind states from emissions of NOx, SO2, and PM2.5 from Midwestern and Southern coal-fired power plants that was preventing them from meeting ozone and PM ambient air quality standards. CSAPR was subsequently challenged in court by several industry groups on the grounds that the USEPA did not have the authority to adopt such cross state rules.

The U.S. Court of Appeals issued a stay preventing implementation of CSAPR on Dec. 30, 2011, forcing the USEPA and state agencies to re-enforce the CAIR rule. The USEPA issued minor modifications of the CSAPR rule published in the Federal Register on Feb. 21, maintaining the emission standards, but providing greater flexibility in meeting deadlines and in helping affected states raise their enforcement budgets through credits. On June 5, the USEPA replaced these changes with similar ones. Meanwhile arguments were heard in the DC Circuit of the U.S. Court of Appeals in April about the validity of the rule, and a decision is expected to be announced shortly.

Greenhouse Gases (GHGs)

A draft rule regulating GHG emissions from new or modified electric utility generating units under New Source Performance Standards was published in the Federal Register on April 13, 2012, the first time GHG emissions would be regulated under this rule. The public comment period just ended. The draft rule is unique, setting a GHG emission limit based on a 30 year averaging period. In other words, an affected coal-fired plant (high GHG emitter) can continue to operate normally, then rely on a future technology, such as carbon capture and storage, to reduce emissions to the 30-year average standard. There is no language on consequences if a viable control strategy is not available, enraging many environmental groups. A final rule is expected to be issued late in 2012.


algaeResearch into biofuels, fuels obtained from living matter that captures CO2, is beginning to show promise as a future fuel for many industries to consider. Biofuels got bad publicity from sugarcane, corn, and other plants that barely scratched the surface of our energy needs, yet caused shortages in staple food supplies and higher prices to those who could least afford it, as well as adverse environmental effects (agricultural destruction and deforestation). One biofuel that has been “under the radar” because its image is not as wholesome as corn but could be a viable biofuel in the future is algae.

Algae has several advantages over plants like those mentioned above and even certain natural grasses that have excellent oil production properties. First, algae can produce ten times more fuel per acre than corn or other plants. The US Dept of Energy estimates that only 15,000 sq. miles of land (half the size of Maine) would be needed to produce enough algae-based fuel to replace all the petroleum-based fuel in the US. Timewise, algae can be produced (it grows) much faster, too. Algae does not divert fresh water from other uses, unlike most other biofuels and other energy sources, such as hydrofracking and even solar cell production. In fact, algae can be successfully grown in wastewater, pond scum, or other “unproductive” lands. More important, algae would not cause the diversion of any agricultural products from the human food chain.

Of course, we are not talking about burning algae per se. Instead, there are different methods to extract and use the lipid or oily portion of algae and convert it into a biofuel. Depending on the species and the technique, different biofuel products can be obtained, such as biogasoline (similar to gasoline in composition), biodiesel, and methane.


Of course, the combustion of a biofuel, such as that from algae, emits CO2, the main greenhouse gas. But because the biofuel source is a plant and grows by taking in CO2 from the atmosphere, then biofuels are “carbon neutral”, and is officially considered this when performing GHG emission inventories (carbon footprints) by all of the international agencies overseeing the carbon counting process.

Why isn’t algae use more widespread? The cost and practicality of algae biofuel usage is enormous right now. There are no successful algae biofuel applications at a commercial scale. Research still needs to be conducted before that can be achieved and to reduce the huge initial costs. However, because of its high productivity in taking CO2 out of the atmosphere and its combustion efficiency, algae-derived biofuels could be a strong option in the long-term future to consider in one’s energy portfolio.


balloons_There has been some discussion lately about large EHS consulting firms beginning to staff up in anticipation of a lot of “catch up” work as the recession ends. These firms advertise quite a bit that because they operate many offices located, in most cases, around the world, and offer a wide breadth of technical services they are the best firms to provide comprehensive, multi-sector EHS assistance to companies, municipalities.

However, in many instances, small consulting firms – even solo practitioners – can offer a competitive alternative to such huge firms. Because of the recession many highly experienced EHS and energy professionals laid off from their former large firms have founded their own consulting firms, and these small firms provide client companies with a viable alternative when procuring consulting services. Depending on the project, these small firms can provide services that are equal to or superior in quality for a lower cost than those provided by the large consulting firms.

I have seen it from both sides, having worked for two huge firms and now heading my own small EHS and energy consulting practice. Here are six advantages of using a small consulting firm:

1.    Personalized service. At most small firms, the owner himself or herself serves the client, and work is conducted by the owner or a trusted senior staff member. Through this arrangement, the client speaks directly to “the boss” and does not have to go through channels as is required at a large consulting firm.

2.    Expert service. With a small firm, the client gets the direct benefit of the owner’s or senior person’s many years of experience unlike at some large firms where projects are shuttled to junior staff. The small firm’s owner or experienced practitioner has direct involvement in the project from start to finish.

3.    Passion. Most small firms are thrilled to have a client’s business, as even one good project can positively impact their workload. This differs from a very large firm where a given project is one of many. Small firms tend to take the time to build close personal relationships with their clients. While large firms care for their clients too, small firms are almost always quite appreciative of their clients’ business and give that extra effort to please (sometimes providing “extras” beyond the Scope of Work) because their level of service is a direct reflection of the owner and the firm.

4.    Flexibility. Of course, a disadvantage of using a small firm is the limited depth of experience compared to a large firm. No one can know everything. However, there is a growing tendency among small companies to create teams to expand the breadth of their expertise. For example, I was recently involved in a teaming arrangement with 3 other small firms representing other sub-specialties that were needed to deliver detailed greenhouse gas reporting services. A Fortune 50 company compared the capabilities, personnel, and experience of our team to those of a huge consulting firm, and chose ours – based on merit! That large firm did not have expertise in all 4 areas that we had. The evaluation did not even consider that our cost was lower than the big firm’s.

5.    Lower costs. Of course, small firms have lower overhead costs (e.g., reduced office expenses, few or no non-technical employees, such as HR and marketing) than large firms. Project labor costs also tend to be lower with a small firm because there is less duplication of services (a second or third person reviewing the work of junior staff at a large firm). Therefore, in most cases, smaller firms can perform the same work at a significantly lower cost.

6.    Local know-how. Many small firms have an intimate knowledge of the regulations and even the unwritten procedures in the states where they practice. At many large firms, staff must perform projects in many locales and may lack experience in all jurisdictions. It is important to receive services from practitioners who have actual experience in your locale.


Companies seeking EHS, sustainability, and energy consulting services should consider both small and large firms in addressing their needs. While some situations may be better suited to a large firm, many can be solved just as well, if not better, by the right small firm.

There is a profound change going on in business attitudes as seen in several business publications recently. A growing focus for companies is on conservation of energy and other natural resources (i.e., water, raw materials, etc.) they depend on for their product. Lately, there has been relatively great volatility in the global supply and demand of many of these, meaning risks (both cost and even business survival – of not being able to make your product in a reliable manner at a reliable cost) are real and potentially significant. For most industries, costs for energy and natural resources are a greater percentage of overall business costs than ever. Controlling these costs – or at least keeping them stable – are of growing concern.
laptopWhat is driving this price and availability volatility? Our global economy. Currently, we have about 7 billion people on Earth, but of these about 1 billion are “like us”: high energy and resource users. If you are reading this article, you probably are using a smart phone, personal computer, printer, or some combination of all three. And if you own and use these, you probably also own and operate one or several TVs, music systems, automobiles, go on frequent trips, and can control your comfort (heating and cooling) with the touch of a few buttons both at home and at work. Yes, you are a high energy user. There is nothing wrong with this. We work hard and deserve to use and enjoy the latest technologies. But this comes at a cost. According to the demographers who study this, by 2050 we will have about 9 billion people on Earth, but of greater concern is that we will triple the number of people who are high energy and resource users, over 2 billion additional middle class people in less than 40 years. Why? Because of economic growth in the BRIC countries. This is not a theoretical exercise based on a computer model. We are seeing frequent reports of large numbers of people in China, India, Latin America, etc. trading in their bicycles for automobiles, their multifamily, poor housing accommodations for larger, single family, climate-controlled homes, etc. This drives up global demand and prices for all of us gasoline, water, building materials, etc.
However, the resources that everybody on Earth needs to prosper and grow into this lifestyle (energy, drinking water, chemicals, cement, plastics, food) are, for the most part, finite. Therefore, based on discoveries of new sources and availabilities of such resources, both shortages and gluts of these resources have and will continue to occur, affects resource availability and price and the very the operations of any company or plant. For example, natural gas prices are currently quite low in the U.S. because of new sources being successfully exploited. Oil and coal, the fuels of choice in most of the developing economies, leads a growing global demand that will cause their prices to increase for all. Companies dependent on oil and coal to supply heat for processes or comfort will likely be hit hard in the bottom line by future volatility in energy prices and perhaps even availability of the fuel.
Therefore, your role as EHS or Sustainability Manager may need to change in the coming years as companies recognize the importance of conserving usage and diversifying sources. Instead of protecting your company’s emissions and discharges from violating rules and from damaging the local environment and worker and public health and safety and counting carbon and other parameters, your role may also include managing the needs of these valuable, dwindling resources. The less dependent your company is on energy, water, etc. (i.e., the less needed to produce the same amount of product), the lower your company’s costs and business risks are. Similarly, the ability to diversify your sources of energy, water, raw materials, etc. (i.e., ability to combust more than one fuel type, multiple agricultural raw material sources and areas for fresh water) will result in a much lower risk of not having a key resource available and to keep manufacturing your products consistently and to meet your business goals.
For example, I worked on a project several years ago for a U.S. manufacturer which wanted to build two new manufacturing plants in Southeast Asia making certain consumer products. One of their major concerns was the source of energy to power large boilers to produce the large amount of heat needed for prodution. We investigated sources of energy easiest available in that country, including renewable sources, and modeled likely long-term prices. We recommended (and the client accepted) designing the boiler system to combust one fossil fuel and one renew-able fuel source (local, easily regrown trees) for these new plants. These are the most available long-term energy sources, and will reduce their risk of running low on energy.
Business leaders are beginning to acknowledge this critical challenge. Therefore, your role in your firm may grow to include managing critical resources. You may need to keep track of the availability and of prices of these resources and contribute to determining and implementing strategies for your processes concerning usage of natural resources to conserve their use and diversify sources.
Management of natural resource usage does not only involve minimizing your direct dependence on those that you need to make your product, but also should include minimizing their need for use in your products used by your customers. For example, if your products force your customers to have to use (and spend) more on energy to operate them, then your customers will begin to investigate alternatives that are more energy efficient. Conserving resources by your products makes them more competitive.
So watch out for the new buzzwords of resource management being important to a well-being of a company given their growing relative costs. Provide the technical expertise and work with your business professionals to reduce costs and risks for long-term gains.
Marc Karell
While the focus of the environmental controversy concerning hydraulic fracturing (“fracking”) has been contamination of aquifers and other water supplies, a recent U. of Colorado study indicates that a much bigger health risk may be air emissions from fracking, such as high levels of air toxic, VOC, and methane emissions. With this in mind, the USEPA promulgated new final rules regulating air emissions from fracking and other production methods of natural gas on April 17, 2012. The rule is really 4 rules, 2 New Source Performance Standards and 2 NESHAP (air toxic) Residual Risk rules for the oil & gas sector. See: Summary:

On the effective day of the rule (60 days after it will be published in the Federal Register), VOC emissions from all fracked wells will need to be flared during the well completion period. By Jan. 1, 2015, all natural gas fracking operators will be required to capture exhaust from gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, glycol dehydrators, sweetening units, and storage vessels using reduced emission completion (“REC”) equipment (also known as “green completion” equipment). REC equipment allows operators to capture natural gas normally escaping from wells or other equipment which can be used for greater sales. The USEPA estimates that these requirements will enable the industry to net an additional $11 to $19 million per year. In capturing these gases, emissions of VOCs, NOx, and air toxics, known carcinogens, such as benzene and hexane, from a fracking operation would be drastically lowered, by as much as 95%, the USEPA estimates. The USEPA is allowing the delay of REC required usage until 2015 because there is believed to be insufficient quantity of REC equipment available for all fracking operations nationally. Low pressure and research wells are exempted from these provisions.

The new rules also contain reporting requirements. For example, operators must notify the USEPA and/or state/local air agencies at least 2 days before well completion work begins. Well operators must also submit annual reports detailing all well completions for the prior year. The reports must be certified by a company Responsible Official.

CCES can help you assess your compliance status vis-à-vis new or existing federal and state air quality rules. We can devise multiple, cost-effective options for compliance. We can devise compliance systems to integrate with your current systems to reliably monitor your compliance status in the future.



Sustainability, the concept of using fewer resources and polluting less to be productive while saving our natural resources, is thought to apply only to “those big polluting manufacturers.” Well, that’s not really true. While we poke fun at offices thanks to the brilliant TV comedy of the same name, any office or store, big or small, can make sustainability gains to save resources and also save money and expenses and motivate personnel.


Here is a list of common environmental concerns in an office setting:

  • Printing of needless documents or excess copies, resulting in increased waste
  • Leaving lights on
  • Not recycling excess paper or other waste
  • Inappropriate climate control or setting of thermostats
  • Excessive use of paper products, like cups, plates, etc.
  • Coworkers not printing double-sided when they can
  • Having to store paper copies of documents when they already exist electronically
  • Not powering down computers when going home

These are legitimate concerns and all can be addressed in an office. Many of these concerns can be effectively addressed with conservation. You and your co-workers need to ask yourselves of whether the light bulb, computer, or other device really needs to be on all the time or at the end of the day or during lunch. You can begin an office culture that it’s important to turn off unnecessary devices. This can provide your company with best savings, going from on to completely off. While lights are obvious to turn off, appliances, computers and other equipment use power even in “sleep” mode. Therefore, if feasible, develop procedures to turn them off, too.

Another approach can be use of simple software or technology. Yes, it means an initial investment to purchase and train on the software, but will pay you back if used properly. For example, there are software products with print management capabilities. Such software can manipulate printer commands to significantly lessen ink jet or toner usage. While printers are fairly inexpensive, businesses are learning that the costs of replacing toner and ink jet cartridges are more significant. Printers can also be set to automatically perform double-side copying. Not only will this reduce paper use and cost, but this will also reduce shipping costs and the recipients of your reports will probably be happier to lug around lighter documents and reduce the necessary storage.

Forming an office “team” can effectively reduce expenses and, at the same time, engender company spirit and loyalty and a sense of accomplishment.

IMG_3402Green Guru Network member Marc Karell is sighted in Tom Zeller Jr.'s Huffington Post Article. Overlooking the Business Case For Climate Change Adaptation. Being poised to be of service is important for adapting to our quickly changing climate. The business sector is always top perfomer in the catagory of change. New opportunities for growth and new niches are evolving. Wondering what business is doing locally? Connect through our Directory, Wetchester Green Business Challenge, or Green Drinks Westchester.

meter_ggnBy Marc Karell

I recently attended a local environmental conference and a senior manager from a local company gave a stirring talk about the recent investments and upgrades made at her facility to improve sustainability and energy efficiency, including upgrading their boilers and other “roll up your sleeves” strategies. She mentioned that her company noticed significant reductions in fuel usage, and they were approaching their ROI. Afterwards, I asked her how this good news was being received by her stakeholders: upper management, employees, customers, regulators, etc. Not very well, she said. People nod their heads, approvingly, then just walk away. The problem, I said, is that people cannot grasp the meaning of “boiler upgrades”, even “cost savings”, but need real, understandable metrics to truly determine value. The metrics for these types of changes that would resonate to stakeholders would be fuel use avoided and/or greenhouse gas (GHG) emissions reduced. And even these could be enhanced by translating them into “number of cars taken off the road” or “equivalent number of trees planted.”

Environmental metrics is a new item for us in the field. We used to occupy our time with purely compliance related metrics (i.e., Are our emissions exceeding our permit limits? Any accidents this quarter? Were we cited this year?). Now, more and more companies are linking environmental performance to overall business performance. While this is a greater burden on the environmental professional, it is also potentially more rewarding if we can make the link of how EHS or Sustainability is helping the company’s business, whether bottom line financial benefits and/or satisfying its stakeholders.

So what strategies exist that make sense for you to monitor and measure performance?

  • Measure what can add value to your company, and link it to money saved.
  • See what others in your industry report and be similar for beneficial comparisons.
  • Express metrics in ways for stakeholders too busy for or not understanding the details to make sense of it (i.e., GHG emissions, cars off the road, etc.).
  • For reputation, ensure that metrics are accurate, relevant, unbiased, validated.
  • Accurately shows trending (i.e., fuel usage reduced by X% compared to …)

This last point may be the most important. Good metrics can result in the best strategic investment of you valuable funds to improve the chances of meeting future goals and continual improvement. Looking at it the other way, poor metrics could lead to inappropriate strategies, wasting valuable resources. The correct set of metrics can also show to powerful stakeholders your company’s performance vis-à-vis EHS, Energy, and Sustainability to show overall organizational value. Spend time to strategize and develop the right environmental and energy metrics to benefit you and your company.

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