building a more sustainable world

The Magazine for Environmental Managers November 2018

Building a More Sustainable World

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em • The Magazine for Environmental Managers • A&WMA • November 2018

Operationalizing Sustainability with Life Cycle Thinkingby Angela Fisher

ColumnsEPA Research Highlights: Understanding Air Pollutionin the Southeastern United Statesby Ann Cornelius BrownPreliminary findings from the Southern Atmosphere Study.

Regulatory Roundup: EPA Proposes ACE Rule; MATS Overhaulby William H. HaakRegulatory Roundup highlights key changes to the U.S. regulatory landscape.

DepartmentsMessage from the President: Making Public SectorParticipation a Priorityby Chris Nelson

Last Stop: Getting to Know A&WMA’s Organizational Members

Thank You to This Month’s Advertisers:• Blue Mountain• Tri-Mer Corp.

Practical Strategies to Implement Manufacturing Energy Efficiency Projectsby Michael Grossner

Taking Corporate Social Responsibility to the Floor:A Case Study from Stanley Black & Deckerby Gretchen Hancock

Sustainability Analytics: The Critical Link between Sustainability and Business Strategyby Ram Ramanan

Table of Contents

Building a More Sustainable Worldby Jennifer K. Kelley

This month’s issue of EM looks at sustainability with respect to industry and corporations. Experts discussthe topic of sustainability and weigh in on various aspects and tools companies can utilize to build or improve their own sustainability culture.

As one of the largest natural sources of nitrogen oxides, it is estimated that lightning-induced NOx (LNOx) contributes up to 15 percent of the total global NOx emissions budget. Following on from the focus of last month’s topic, Advances in Air Quality Modeling, this article considers the impact of LNOx on air quality through robust LNOx production and distribution schemes in air quality models.

Lightning NOx Emissions and theImplications for Surface Air Qualityover the Contiguous United Statesby Daiwen Kang and Kenneth E. Pickering

EM Exclusive

Message from the President

I spent the first 13 years of my career working in a state environmental agency. When I first arrived at 3M, my new bossasked me to visit a manufacturing site in another state. I felt experienced in these processes, having written a number of travelrequest memos during my state service, some going as high as the Governor’s office for approval, to ensure my out-of-statetravel was appropriate. I wanted to avoid looking like a rube and asked my manager how I should address my travel request. Willour VP approve it? He looked dumbfounded and said, “I just asked you to go. It’s approved. Just go.”

<< • >>

by Chris Nelson, P.E. » [email protected]

Making PublicSector Participationa Priority


A&WMA is finishing 2018 with strong programming,including three in-person events in December: the 43rdAnnual A&WMA Information Exchange (http://www.awma.org/infoexchange); Vapor Intrusion, Remediation, and SiteClosure Conference (http://www.awma.org/vapor); andNew Source Review Workshop (http://www.awma.org/NSRWorkshop). One of our key challenges is to ensurebroad participation by all segments of our membership and customer base.

Many of our member companies have tight travel and training budgets, when compared to historical levels. Despitesome limitations, A&WMA can attract those members to events with diverse attendance and relevant content.One of our real challenges is to facilitate public sector participation.

In fact, one of the A&WMA Board’s strategic goals is to increase public sector engagement with the Association. If wecan provide appropriate content for them, more companiesand consulting firms will also participate. It becomes a virtu-ous cycle. As I travel on Association and 3M business, I oftenask agency colleagues how A&WMA can help them with professional development. Many organizations have minimaltravel budgets. Others have restrictive policies on professionaldevelopment spending. One organization, I learned, re-quires its employees to both pay for conferences out oftheir own pocket and take vacation time to attend.

It isn’t only a problem for A&WMA if our public sector colleagues cannot attend professional development events. All our organizations have employee turnover and need totrain new staff on compliance requirements and programs.Given that we must all work collaboratively to implement our environmental rules, it is helpful if we can learn togetherand discuss policy outside the context of specific permits or compliance negotiations. Fragmented training by sector or organization is not as effective as real discussions and learning with peers from different backgrounds and withvarying expertise.

My experience with professional travel when I moved fromthe public to the private sector helped me appreciate howwe must make an effort to include all our members in ourprograms. Our Association will continue to offer program-ming that benefits environmental professionals in the public and private sectors as well as academia. Whether at the local unit or international level, our Association leaders should reach out to state and local agencies, tailoring programs to their needs and ability to participate.We can encourage public sector leaders to run for Boardpositions and serve on committees. In the end, I hope our efforts will strengthen our Association and our profession while contributing to better environmental programs and outcomes.

Thanks for reading EM and supporting A&WMA. em

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A look at sustainability with respect to industry and corporations. Experts discuss

the topic of sustainability and weigh in on various aspects and tools companies

can utilize to build or improve their own sustainability culture.

Cover Story by Jennifer K. Kelley

Building a MoreSustainable World


Merriam-Webster defines sustainable as “a: relating to orbeing a method of harvesting or using a resource so that theresource is not depleted or permanently damaged and b: ofor relating to a lifestyle involving the use of sustainablemethods”. Unfortunately, there are many examples, both inindustry and in our own communities, where the definedmethod or lifestyle has failed to be achieved. Examples arethose with broad impact such as the Great Pacific garbage patch(first discovered in 1988 the plastic is now estimated to weigh80,000 metric tons!), our own personal use of resources anddisposable items, and habitat loss or destruction, to those examples from specific instances such as Deepwater Horizonoil spill, Chernobyl (1986 catastrophic nuclear event), Bhopalgas tragedy (considered one of the world’s worst industrialdisaster), and the list goes on.

Short of halting all industry and returning to a hunter-gath-erer society or finding an alternative Earth and moving theentire population there; more progress will need to be madetoward creating a sustainable world. Taking a positive approachto this topic: humans are very innovative, and these problemshave the potential to create business opportunities such asmore efficient or renewable power sources, better batterytechnology, improved recycling technologies, etc. In additionto creating new technologies, we are capable of building cultures inside our companies and our communities that candrive toward sustainability.

Wikipedia defines sustainability as “the process of maintainingchange in a balanced fashion, in which the exploitation of resources, the direction of investments, the orientation oftechnological development and institutional change are all inharmony and enhance both current and future potential tomeet human needs and aspirations”. The articles in this issuepresent how companies can improve within the different domains of sustainability: environmental, economic, and social.

In the first article, Angela Fisher, co-founder and chief sustainability strategist at Aspire Sustainability, discusses acompany’s potential to operationalize “Life Cycle Thinking,” a systems-based philosophy or approach to taking in the bigpicture to identify, weigh, and compare between options byusing the Life Cycle Analysis (LCA) tool. She delves into thespecifics of the LCA explaining what the tool is and when itcan benefit a company. She completes her article by including

the limitations and pitfalls of the tool and how companies can potentially avoid them.

The author also provides a case study for performing a cradle-to-grave, multi-criteria LCA of a 2.5-MW onshore windturbine. The results of the LCA led to design improvements,reduced environmental impacts, customer satisfaction, and enhanced supply chain relationships, ultimately proving the casethat LCA is an effective approach for advancing sustainability.

In the next article, Michael Grossner, manager of greenhousegas and energy efficiency for General Electric and adjunct asso-ciate professor in the Department of Chemical and Biomolecu-lar Engineering at Case Western Reserve University, makes thecase for manufacturing facilities to focus their efforts on energyefficiency as the resulting effect is a decrease in bottom-line utility costs coupled with a reduced environmental footprint. He discusses some common roadblocks companies experiencewhen trying to implement energy efficiency projects andprovides strategies for overcoming those obstacles.

Next, Gretchen Hancock, senior director of corporate socialresponsibility for Stanley Black & Decker, Inc., lays out a casestudy of how Stanley Black and Decker built their sustainabilitystrategy by defining the company’s purpose and how that relates back to corporate social responsibility, as well as settingtargets against it that can be driven, measured, and showprogress. The case study highlights how the company movestheir own sustainability needle by expanding their goals andgaining ownership of the results throughout the company byleadership focus and accountability.

Finally, Ram Ramanan, affiliate research professor with theDesert Research Institute, writes that corporations can utilizesustainability analytics to transform information into measuresand data enabling them to accomplish their social responsibilityand sustainability goals. The author first builds the case for whycorporations should take responsibility for sustainability, thendiscusses the metrics and data analytics to support their chosen strategy allowing them to focus in on where they canmake the biggest impact to meet their sustainability goals.

I invite EM readers to consider the ways in which they canpersonally impact their work, their company’s work, and theircommunity in building a more sustainable world. I hope youenjoy reading this issue. em

Jennifer K. Kelley is a senior environmental expert at GE. She also currently serves as a member of EM’s Editorial Advisory Committee;e-mail: [email protected].


Cover Story by Jennifer K. Kelley

Abstract Deadline for Professional and Student Platforms, Posters and Panels

January 11, 2019 Notification of Acceptance

January 11, 2019 Student Poster Abstracts Due

February 11, 2019 Author Notification of Presentation Format

March 15, 2019 Drafts Due

April 15, 2019 Final Submissions Due

June 25-28, 2019 ACE2019 in Quebec City

ACE 2019 Technical Program

Timeline

The Air & Waste Management Association’s 112th Annual Conference & Exhibition June 25-28, 2019 • Quebec City Convention Centre, Quebec City, QC, Canada

www.awma.org/ACE2019

CACCALL FOR ABSTCALCALLCALL CALL FCALL FOCALL FORCALL FOR CALL FOR ACALL FOR ABCALL FOR ABSCALL FOR ABSTRACALL FOR ABSTRCALL FOR ABSTRACTS CALL FOR ABSTRACCALL FOR ABSTRACTCALL FOR ABSTRACTSCALL FOR ABSTRACTS

So close, so European, an intellectual and inspirational experience is waiting for you in Quebec City! Be a part of the winds of change and share your work, make key connections, and advance the industry.

Winds of Change — Environment, Energy & Health The world is facing numerous challenges with regard to the environment, energy and health that are considered by many as “the global threat of our time”. In June 2019, the Air & Waste Management Association (A&WMA) will bring the world’s leading experts to Quebec City to develop insights on these important issues and discuss efficacious solutions to bring about needed change.

A&WMA’s Annual Conference is recognized as the premier international conference for the latest information on air, climate change, environmental management, resource conservation, and waste with 300+ platform and poster presentations, 35+ panels, and up to 11 concurrent tracks each day.

Abstracts for platform presentations, posters, and panels due November 30. Many formats are accepted, including full manuscript, extended abstract with technical review, or an outline or PowerPoint presentation with content review. All presenters are required to register and pay to attend. It is a unique opportunity to both share and learn from experts and practitioners.

Papers and presentations delivered at the conference that are properly submitted will be published in an online proceedings.

Proposed Topics

Air Measurements and Monitoring

Air Pollution Control Technologies

Air Emissions Studies

Air Quality Modeling

Bioaerosols and Disease Transmission

Climate Change

Cap and Trade Markets and Protocols

Health and Environmental Effects and Exposure

Odor Sources, Controls, and Regulations

Biogas, Bioenergy, Biofuels and Bioproducts

Environmental Program Administration

Regulatory and Legal Issues

Transportation and Electric Vehicles

Heavy Industry and General Manufacturing

Oil and Gas and Tar Sands

Power Generation and Renewable Energy

Federal, Public Sectors, and Tribal Issues

Sustainability and Resource Conservation

Site Remediation and Clean Up

Waste Processing and Waste-to-Energy

Find the complete Call for Abstracts and details online at www.awma.org/ACE2019.

November 30, 2018

LCA is a science-based methodology that helps identify actionable improvement opportunities.

Operationalizing Sustainabilitywith Life Cycle Thinking

Looking beyond ‘sustainability’ toward a holistic approach of life cycle thinking in

order to inspire organizations to think bigger and act differently.

Life Cycle Thinking by Angela Fisher


Sustainability has been on an accelerating track for morethan a decade. Sophistication and innovation have driven theneed for more, or better yet next-generation sustainability(“beyond sustainability”). For long-term business prosperity, itis no longer acceptable for sustainability to be a supplementalcheck the box add-on exercise or to simply commit to recyclingand reducing emissions in our manufacturing facilities. Stakeholders are all too aware of the possibilities and

importance of doing more and having a positive, meaningful impact on our world. Concepts and global initiatives such as the net positive movement, science-basedtargets, circular economy, the role of technology, transparency,and the United Nations’ Sustainable Development Goals

(SDGs) aim to inspire organizations to think bigger and actdifferently. We are at a stage of maturation where sustain-ability needs to be an integrated part of business—or as thisarticle teases—operationalized. An incredibly valuable approach to leverage is life cycle thinking (LCT), a systems-based philosophy/approach to taking in the big picture toidentify, weigh, and compare, between options. It allows formore informed decisions and considers economic, social, andenvironmental considerations (Figure 1). It expands thinking

beyond one’s four walls or operations or function within thecompany, a holistic approach that looks upstream and downstream and into nearby systems as well. A key ambitionof an LCT approach is to enable business to thrive throughbetter products, better value proposition for the customer,]better market share, better line of sight to environmental risksand opportunities, better positioning with respect to policytrends, enhanced brand image, and more.

A robust, quantitative tool that employs this life cycle perspective is life cycle assessment (LCA). LCA is a stan-dardized, science-based methodology that assesses the environmental aspects and potential impacts of a product orservice throughout its lifetime, including raw materialextraction, preprocessing, manufacturing, transportation,use, and end of life (Figure 2). LCA can be a valuable toolfor evaluating challenging sustainability issues or for determiningmeaningful areas for improvement along the value chain. Itcan also be leveraged to develop environmental productdeclarations (EPDs) to earn credits within green buildingschemes such as LEED v4.

In addition to looking across the various stages of the lifecycle, another strength of LCA is that it is a multi-attribute assessment tool. Typical environmental impact categoriesinclude greenhouse gas emissions, biodiversity impacts,water consumption, human toxicity, metal depletion, landuse, particulate emissions, ecotoxicity, energy use, materialsscarcity, eutrophication, acidification, and a variety of others.When performed by experienced sustainability practitioners,LCA can be supplemented with complementary analyses,such as life cycle costing (LCC); social LCA; environmentalimpact assessment; and other established tools to ensure atriple bottom line, comprehensive evaluation is undertaken.

As described by the International Organization for Standardization (ISO) in ISO 14040, an LCA study consistsof four consecutive and iterative phases (Figure 3):

• Phase 1 – Goal and Scope Definition – sets out the context of the study and explains how and to whom the results will be communicated. It includes elements as such as defining the functional unit, establishing the sys tem boundary, stating the assumptions, limitations and



Figure 1. Sustainable development considers the triplebottom line of economics, society, and the environment.

Figure 2. Diagram of the typical life cycle stages evaluated in a life cycle assessment.

allocation methods to be used, and the impact categories chosen.• Phase 2 – Inventory Analysis (LCI) – is where the environmental inputs and outputs associated with a product or service are compiled. It includes inputs of water, energy, and raw materials, and emissions to air, land, and water from across the entire value chain of the product or service. • Phase 3 – Impact Assessment (LCIA) – involves the evaluation of the significance of potential environmental impacts based on the LCI flow results modeled in phase 2. • Phase 4 – Interpretation – summarizes the conclusions and recommendations for the study. It includes the identification of significant issues detected in the results of

the LCI and LCIA stages; consideration of completeness, sensitivity and consistency checks; determination of data sensitivity; and presentation of results.

LCT and LCAs are sound approaches that demonstrate a commitment to a more sustainable economy. LCA was originally used primarily to assess products or services, but isalso being expanded to evaluate advanced technologies, alter-nate business models, and even entire organizations. Whetheran organization is motivated by customer expectations, theirown sustainability goals, regulations and standards, markettrends, and technology innovation, LCA can be the foundation.Diverse, cross-functional teams throughout an organization canengage with one another—employing a life cycle perspective—to improve resiliency and identify sustainability improvementopportunities (Figure 4). A credible marketing campaign, mate-rials sustainability strategy, product differentiation, thought leadership, customer engagement, supply chain optimization,operational efficiency, and regulatory compliance are all impor-tant processes that can benefit from operationalizing sustain-ability within a company.

Perhaps one of the more advantageous opportunities forLCA, from a product portfolio perspective, is its ability to facilitate innovative thinking during product design and development. LCA, either screening or detailed, can be a keyelement of environmentally conscious product design, offeringinsights into supply chain, materials, packaging, logistics, per-formance, end of life (or the next life), as well as customer



Figure 3. Four iterative phases of a life cycle assessment.

Figure 4. Sustainability improvement opportunities from employing a life cycle perspective.



LCA Case StudyWhile serving as the strategic internal LCA and sustainabilityteam for General Electric (GE), the sustainability experts atAspire Sustainability performed a cradle-to-grave, multi-criteriaLCA of the 2.5-MW onshore wind turbine. The motivation forcommencing the project was two-fold. First, the company’scustomers were increasingly requesting—and in some casesbeginning to require—life cycle environmental profile data forthe products that they were purchasing. Second, the WorldResources Institute (WRI) and the World Business Council forSustainable Development’s (WBCSD) Greenhouse Gas (GHG)

Protocol Initiative Product Life Cycle Accounting and Reporting Standard (https://ghgprotocol.org/product-standard) (Standard) was being developed. By piloting the standard,GE was able to provide feedback to ensure that the standardwas rigorous, yet practical to comply with for any number offuture applications across its diverse product portfolio.

The execution of the detailed LCA included direct engagementwith and collection of primary data from major componentsuppliers (e.g., blades, tower, generator, etc.). The study encouraged the engagement \of cross-functional teamswithin the company, as well as education and relationshipstrengthening across the entire value chain. It also underscoredthe variables within the LCA model that were driving theimpacts across the product life cycle—notably the tower,blades, and the turbine’s distribution and installation activities.

While the life cycle GHG results were featured in accordancewith the reporting requirements in the Standard, a supplemen-tal holistic assessment of 17 environmental impact categorieswas administered to achieve a full detailed LCA aligned withthe LCA ISO standards 14040/44 (Figures 5 and 6). The results indicated that the majority of environmental impactswere in supply chain (materials and components). Energy andcarbon payback times were calculated as a way to emphasizethe life cycle benefits of the technology. When compared to

experience and value proposition. It can provide insights intopracticable, actionable efforts to improve the life cycle foot-print. Energizing efforts are even underway to use LCA tobetter quantify the benefits of the transition to a circulareconomy. This includes calculating benefits and impacts related to eco-design; leasing and sharing business models; andmaterials recovery, reuse, and remanufacturing strategies.

For completeness, it is important to note the limitations of LCAin addition to its strengths. LCA attempts to model complexsupply chains and calculate the potential environmental impacts of these flows. There are a variety of uncertainties associated with these models that must be recognized forLCA to be useful to decision-makers. Additionally, LCA does

not cover all the environmental impacts associated withhuman activities; for example, erosion, invasive species, odor,and noise, are not currently quantified in LCA models becausethe methods have not yet been fully developed or integratedinto commercial software. Lastly, it should be noted that LCAdoes not provide a definitive answer, but is a tool in the decision-making toolkit and should be accompanied by otheranalyses, such as risk assessment, regulatory compliance review, and cost-benefit analysis.

Successful engagement requires a range of strategies in addition to clear and consistent communications. Businessdrivers, project goals, information management capability,sustainability maturation level of the business unit or project

NAAQS Perspectives, Part 2 The December issue picks up where the September issue left off with further insight and discussion of the process for re-viewing U.S. National Ambient Air Quality Standards (NAAQS), including the role of science, particularly health science,and advisory committees such as the Clean Air Science Advisory Committee (CASAC) in setting standards.

In Next Month’s Issue…



Figure 5. Life cycle GHG emissions for 2.5-MW windturbine.

20-year wind turbine lifetime, they illustrated that the benefitsof generating clean energy quickly offset any impacts incurredduring the manufacture, distribution, installation, operation, anddisposal of the wind turbine.

In addition to the standard report and internal LCA documentation, supplemental deliverables were also produced. A custom Microsoft Excel tool was developed thatwas able to vary site-specific inputs to calculate life cycle GHGresults for sales teams to share with customers about theirunique installation. Results of the LCA were also shared withproduct designers and engineers at the GE Wind Center of

Excellence who leveraged the results for eco-design activitiesof blades and towers. Bringing value to the company throughproduct design improvements, reduced environmental impacts, customer satisfaction, enhanced supply chain relationships and many other ways, LCA is an effective andproven approach for advancing sustainability.

Source: Fisher, A.; Flanagan, W.P. Life Cycle GHG Assessmentof a 2.5-MW Wind Turbine: Road Test of the GHG ProtocolInitiative’s Product Life Cycle Accounting and Reporting Standard, LCA X, Portland, OR, November 3, 2010.

Figure 6. Multi-attribute LCA results for 2.5-MW windturbine.

Angela Fisher is Co-founder and Chief Sustainability Strategist of Aspire Sustainability, Breckenridge, CO. E-mail: [email protected].

Fisher delivers a refreshing blend of holistic, life cycle thinking, expert competency, and pure passion for sustainability. For nearly 13years, she has had proven success steering essential corporate and product sustainability programs across diverse, global industry sectors. She also has extensive leadership and collaboration experience and is active across numerous sustainability networks and academic institutions globally. She brings a high level of credibility, quality, and commitment to all her collaborations. She is a certifiedlife cycle assessment professional (LCA CP), an International Society of Sustainability Professionals Sustainability Associate (ISSP-SA), anda LEED Green Associate. For more about her company, Aspire Sustainability, visit aspiresustainability.com.

team, and individual orientation toward sustainability, can allbe key aspects affecting a successful engagement.

LCA is an established methodology that supports actionableaspects of the business strategy and a valuable tool in any sustainability toolkit. There are clear advantages to developingand leveraging expertise that employs LCT and LCA within acompany. Whether the technical expertise is in-house or retained through experienced and certified external profes-sionals, (http://aspiresustainability.com/lca-expertise/) frequentengagement and guidance should be solicited to executeLCT and LCA efforts, develop tools and resources, and educate company personnel, with a focus on aligning sustainability activities with business value.

The legacy “business as usual” case where companies focuson compliance and only damage ecosystems and societieswithin the limits set by regulations has sunset. We are evenpast the time for “green” where we do a little more than wehave to (i.e., by polluting just a little less, using less energyfrom non-renewable sources, etc.). We are on the edge of anew wave—beyond sustainability—where we begin to workon restoring damaged ecosystems and activating a regenerativeeconomy. Investment in a robust product sustainability strategy utilizing a life cycle perspective and the power ofLCA can ensure that your company’s operations are sustainable well into the future, both in terms of environmentalstewardship and business competitiveness. em


Practical Strategies to

Implement ManufacturingEnergy Efficiency Projects

How to overcome common roadblocks encountered by industrial facilities on the

road to improve energy efficiency.

Implementing Energy Efficiency Projects by Michael Grossner



For many years, industrial energy usage has been consistently greater than any other sector (residential, com-mercial, or transportation). In 2017, the industrial sector accounted for nearly one-third of U.S. energy consumption.1

Energy is a key resource required to produce the goodsneeded for our technologically advanced society, but mostenergy generation methods have a significant impact on theplanet through reduction of natural resources and release ofpollutants. More efficient use of energy at manufacturing facilities is a “win-win” proposition: a decrease in bottom-lineutility costs coupled with a reduced environmental footprint.

The immediate cost savings from energy efficiency are typicallysufficient to encourage implementation of projects. This is especially true for industries where energy cost is a significantpercentage of operating expenses (e.g., cement manufacturingor refining). Rigorous energy management programs such asISO-50001 are practiced at numerous energy-intensive industrial locations. However, there are many industrial facilities where energy cost may be less than a few percent oftotal expenses and the potential impact of energy efficiencyprojects does not get enough attention.

This article focuses on facilities in which recent efforts to improve energy efficiency have not been successful for any number of reasons (outlined in the “Common Implementa-tion Roadblocks” sidebar below). Some strategies for over-coming those obstacles will be presented.

Identifying and Quantifying ProjectsEnergy efficiency projects are typically identified through athird-party audit (by an equipment vendor or an independentenergy consultant) or through a self-assessment such as a leanenergy treasure hunt.2 However the projects are identified, it iscritical to calculate clear estimates of the savings as well as implementation costs. This allows you to fit these projects inthe company investment plan.

Strategies to Make It HappenThe roadblocks discussed above can be pushed out of theway. The solutions discussed below all have been proven to accelerate the implementation of energy efficiency projects.

Identify a Management ChampionAn ideal champion is someone who has budget decision-making authority, understands the benefit of efficiency, andwill directly benefit from the project. You should present a polished project summary that you are confident you canimplement and you should share the project success withthat champion. Once you have management support, it willbe easier to implement subsequent projects.

Be Creative with FinancesPerhaps the budget is too small this year. One thing you can do is buy equipment in small quantities as funds are available.For example, a facility leader bought about 20 light fixtureseach year, eventually replacing all of the shop lighting over

Common Implementation RoadblocksThere are several reasons energy efficiency projects are not imple-mented, even when clearly identified with quantified cost savings:

1. Investment criteria not met. Small- to medium-size plant improvementprojects typically have financial criteria of simple payback, and this can beless than one-year in older facilities where immediate cost savings are required. In this situation, it can be difficult to do more than the most basicenergy projects (e.g., fixing copressed air leaks, turning equipment off, etc.).

2. Competition for capital funds. The annual budget is usually fixed, sosituations will arise when you may be faced with the choice of purchasingnew production equipment or investing in an infrastructure project such asa LED lighting retrofit.

3. Lack of resources. Many plants run with a lean staff of maintenance/facility engineers, who focus on keeping the production line operating.Those employees may not have the time to step back and consider energyefficiency or work on implementing capital projects focused on energy.

4. Too many small projects. Some energy improvements are very smallprojects, such as adding controls to a piece of equipment, and consequentlyare overlooked because of the small impact.

5. Culture. Have you ever asked someone at a manufacturing site, “Whydo we do it this way?” The answer may often be “Because that is the waywe do it. We have always done it that way.” The inability to embracechange—a key requirement of the continuous improvement philosophy—can inhibit progress in energy efficiency, especially when it comes toprocess change.



five years. Also, be sure to take advantage of utility rebatesand other programs. Rebates from your first project could be used to fund the next one. Another option is to explore alternative funding schemes such as energy performancecontracting.

Attach to Major ProjectsReplacing a piece of equipment with a more efficient onemay often have a very long payback. However, if you are already spending money on new equipment or a facility expansion, an incremental investment can yield very goodsavings. Work with your sourcing function to build-in energyefficiency requirements for new equipment, clearly outliningthe lifetime cost of operating the equipment, and not just theinitial outlay.

Group ProjectsSmall projects may be overlooked because individually thecost savings seem insignificant. However, when multiple projects are grouped together, the impact becomes more noticeable. Also, those projects with longer paybacks will benefitby being combined in a group with other more immediatepaybacks. In addition, a group of projects could be assignedto a single vendor to implement, perhaps with some discountdue to the scale (versus multiple contracts).

BenchmarkRarely do competitors share information freely with one another, but in the case of energy efficiency, most companiesare willing to discuss how they have improved their own

facilities, especially when energy costs are not a key componentof operating expenses. This is often accomplished though presentations at trade-group meetings and conferences focusing on energy efficiency. Benchmarking is not only useful with competitors, though. Perhaps one section of yourplant or a sister plant in a different location has found an energy efficiency opportunity of which you can also take advantage. You can even learn by looking outside your spe-cific industry segment. Recall that Henry Ford’s assembly linewas partially inspired by the “disassembly” line of Chicagomeat-packing operations.3

Measure and Track It may seem obvious that with measurement and trackingyou can document savings and justify additional projects. But when motivation is important, such as projects involving operational changes and decisions, having measurements ofenergy usage also allows you to do a variety of other thingsto drive changes. One technique is to track separate areas ofthe facility to assign utility costs to specific production units orto encourage friendly competitions between sections of theplant. In some cases, improvements can happen by simplymaking energy use visible on control panels or other screensinside the facility. In addition, with better measurement of energy, you can track energy costs on a per-product basis,which gives you an energy intensity metric as a key perform-ance indicator. Be sure to include sub metering in any proposed electrical infrastructure project such as new transformers, breakers, etc.

Get the latest information from the experts! Workshop presenters include authors of the Manual: • John Evans, Senior Environmental

Consultant, RTP • Eric Hiser, Partner, Jorden Hiser & Joy• Gale Ho�nagle, Senior Vice President

and Technical Director, TRC• Dave Jordan, Partner, ERM • Sean Alteri, Deputy Commissioner,

Energy & Environment, Kentucky DEP

Register and �nd the agenda online at www.awma.org/NSRworkshop.

Based on the best-selling A&WMA NSR Manual, this workshop will provide attendees with a working knowledge and understanding of New Source Review rules and how to apply them in di�erent situations, as well as the recent memoranda issued by the EPA on applicability, project emissions accounting, common control and once in, always in.

Workshop sessions will cover the following topics:

• History and Program Implementation • PSD Applicability (case studies, netting, calculating emissions increases)• BACT (top-down process, modi�cations, examples)• PSD Air Quality Analysis (increments, baseline dates, modeling)• Nonattainment Area NSR (thresholds, LAER, alternative analysis)• Emissions O�sets (applicability, o�sets vs. netting, emission banks)• Permit Appeals, Review and Enforcement • Next Generation Reforms

The NSR Manual is recommended for the Workshop and can be added during the registration process. Member, government and multi-user pricing available.

New Source Review (NSR) Workshop

Learn the Application of PSD Rules, New Sources, and Nonattainment Area NSR

December 11-12, 2018 • Louisville, KY

Held at the Louisville Marriott, 280 W. Je�erson St.


Get the latest information from the experts! Workshop presenters include authors of the Manual: • John Evans, Senior Environmental

Consultant, RTP • Eric Hiser, Partner, Jorden Hiser & Joy• Gale Ho�nagle, Senior Vice President

and Technical Director, TRC• Dave Jordan, Partner, ERM • Sean Alteri, Deputy Commissioner,

Energy & Environment, Kentucky DEP

Register and �nd the agenda online at www.awma.org/NSRworkshop.

Based on the best-selling A&WMA NSR Manual, this workshop will provide attendees with a working knowledge and understanding of New Source Review rules and how to apply them in di�erent situations, as well as the recent memoranda issued by the EPA on applicability, project emissions accounting, common control and once in, always in.

Workshop sessions will cover the following topics:

• History and Program Implementation • PSD Applicability (case studies, netting, calculating emissions increases)• BACT (top-down process, modi�cations, examples)• PSD Air Quality Analysis (increments, baseline dates, modeling)• Nonattainment Area NSR (thresholds, LAER, alternative analysis)• Emissions O�sets (applicability, o�sets vs. netting, emission banks)• Permit Appeals, Review and Enforcement • Next Generation Reforms

The NSR Manual is recommended for the Workshop and can be added during the registration process. Member, government and multi-user pricing available.

New Source Review (NSR) Workshop

Learn the Application of PSD Rules, New Sources, and Nonattainment Area NSR

December 11-12, 2018 • Louisville, KY

Held at the Louisville Marriott, 280 W. Je�erson St.

Vapor Intrusion, Remediation, and Site Closure A Decade of Progress and New Challenges December 5-6, 2018 • Phoenix, AZ

The featured keynote speaker is John Morris, Global Remediation Director at Honeywell.

Lunch speakers are Dr. Michael Dourson, Director of Science, Toxicology Excellence for Risk Assessment, and Henry Schuver, Environmental Scientist, US EPA O�ce of Land and Emergency Management

The conference will include a site tour of the Honeywell facility in Tempe, AZ.

®

Gold sponsors Silver sponsorsPlatinum sponsor Tabletop exhibitors Register now and make your hotel accommodations! Find

complete information at www.awma.org/vapor.

Get the latest information on new guidance, new technology, and new solutions on vapor intrusion!

With nearly half of US states recently releasing new guidance, this conference comes at the perfect time to bring together scientists, engineers, regulators and attorneys to address bringing sites to closure in a technicallydefensible way, while balancing key elements such as risk, sustainability and cost remediation and mitigation solutions as well as toxicology, risk assessment, real estate transactions, and communication.

High level panels will discuss short-term TCE toxicity and site closure solutions.

Sessions will include presentations and discussion on: • New regulatory perspectives on VI • Sampling and analysis • Assessment and data evaluation • VI mitigation and case studies

Introductory and advanced courses on December 4.

Michael Grossner, Ph.D., P.E., is the Greenhouse Gas and Energy Efficiency Manager at General Electric and an Adjunct AssociateProfessor in the Department of Chemical and Biomolecular Engineering at Case Western Reserve University.E-mail: [email protected].


References1. U.S. Energy Information Association. July 2018 Monthly Energy Review; https://www.eia.gov/totalenergy/data/monthly/pdf/mer.pdf (accessed Aug. 12, 2018).2. U.S. Environmental Protection Agency. Energy Treasure Hunt Guide: Simple Steps to FindingEnergy Savings; https://www.energystar.gov/buildings/tools-an dresources/energy-star-treasure-hunt-guide-simple-steps-finding-energy-savings (accessed Aug. 12, 2018).3. Ford, H.; Crowther, S. My Life and Work. Garden City, NY; Garden City Publishing, 1922.

Highlight Additional BenefitsFinally, do not forget to emphasize the other advantages toproposed energy efficiency projects, such as: • Low risk. Compared to other investments at your facility, the calculated return on investment for energy savings is quite certain. For example, you know exactly how much power a new lighting fixture will draw versus the current one. • Production improvement. Some efficiency projects can increase throughput. For instance, upgrading a natural gas curing oven to an infrared system can reduce cycle time, as well as energy usage. • Improved worker comfort. Heating, ventilation, and air conditioning (HVAC) improvements, such directing the ventilation specifically where needed, can provide a more comfortable workspace.

• Light quality improvement. Besides the reduction in energy usage, upgrading from lamps and fixtures with a low color temperature and low color rendering index (CRI) to certain light-emitting diode (LED) solutions will give a marked increase in the ability to see more detail in order to identify defects or complete complex operations.

SummaryAll production environments are unique, but following thestrategies highlighted here can accelerate the adoption of energy efficient practices, reducing expenses, as well as advancing an overall environmental benefit. For more information, the Advanced Manufacturing Office of the U.S.Department of Energy (https://www.energy.gov/eere/amo/advanced-manufacturing-office) has excellent resources on industrial energy efficiency. em


Taking Corporate Social Responsibility to the Floor:

A Case Study fromStanley Black & Decker

This article walks through a case study of how Stanley Black & Decker derives its

Corporate Social Responsibility strategy from its purpose—that is, the reason the

company is in business—then uses that strategy to help drive corporate social

responsibility metrics toward success.

A Stanley Black & Decker Case Study by Gretchen Hancock


As innovation moves the world faster, communications haveincreasing transparency, and every industry faces significantdisruption, investors and consumers are focused on under-standing an organization’s “Why”. Purpose has become a rallying cry for corporate leaders, innovators, and speakersglobally. A company’s purpose—beyond mission or vision castdown from the ivory tower—distills with bold clarity the reasona company is in business. At its best, it both garners images ofa storied past and creates inspiration for an impactful future.

Starting with purpose, this article walks through a case studyof how Stanley Black & Decker (SBD) derived its CorporateSocial Responsibility (CSR) strategy from its purpose, thentakes that to identify measures and tactics within operationsthat drive CSR performance metrics toward success. The article focuses on how to work toward distilling a purpose,connect that to a corporate sustainability strategy, and set targets against which progress can be driven, achieved, andreported.

Establishing a PurposeEstablishing a purpose as the foundation for company actionsand communications is a critical first step toward creating thekind of inspired bold actions required to transform CSR performance. A purpose journey starts with introspection—in-cluding interviews at all levels of the organization—to distillthe culture and mission down to bold actions. It’s equally criticalto look beyond the corporate structure—to partners, suppliers, customers, end users, and the communities in which yourcompany operates to get a clear understanding of their perception of how your business contributes beyond its fourwalls and balance sheet. I note with interest that nongovern-mental organizations (NGOs) have been using purpose as arallying cry for years, whether through graphics such as theWorld Wildlife Foundation’s panda to the globe-shaped icon covered in leaves that represents The Nature Conservancy.For-profit institutions can benefit substantially from an easily-recognizable statement or icon that embodies why they exist.Here at SBD, we are For Those Who Make the World. At 175years young in 2018, the merger of Stanley Works and Blackand Decker in 2010 combined forces of a host of iconicbrands that are widely used to make, build, and create byprofessionals and do-it-yourselfers alike. For employees, thispurpose clearly defines the end user of our products. For investors, it clearly identifies where we have been and are goingin our sector. It’s a rallying cry and a defining statement. Andthe establishment of purpose in 2016/2017 inspired conversations about how to bring that purpose to life.

Instituting a Comprehensive CSR StrategyThere is increasing pressure from the investment communityfor companies to be transparent in their CSR strategy, includingtargets, progress, and tactics that are being used to makeprogress toward those targets. Environmental professionalswidely cite the May–July timeframe as “reporting season,” coming on top of regulatory reporting season, and the work-load doesn’t abate. In fact, more senior leaders are engaging directly with the functions that manage CSR on the need toincrease scores from entities such as the Dow Jones

Sustainability Index (DJSI) and the Carbon Disclosure Project(CDP). Value chains are impacted extensively as customers andpartners require completion of these and other questionnairesby suppliers. In all this noise, it’s critical that a layered process beestablished to both drive ownership of and progress againstsustainability goals.

Activating purpose through a comprehensive CSR strategyhas several benefits: it assures alignment to broader brandmessaging; allows employees, customers, and suppliers toquickly understand why certain priorities or targets have beenestablished; and allows leadership to drive performance thataligns with purpose. This alignment creates authenticity ofmessage, and compels action.

Aligned with SBD’sPurpose For ThoseWho Make TheWorld, SBD's CSRstrategy has threekey elements:

Empower Makers, Innovate Products with Purpose, and Createa More Sustainable World. Dissecting SBD’s Purpose—aboutpeople, products, and planet—leads directly to the CSR strat-egy. Compelling action, however, takes far more thanphrases on PowerPoint charts, or asking people to politelyplay along, particularly in this age of increased transparencyand reporting. A solid strategy needs measurable targets witha way to allocate them to operating units.

For years, SBD has measured each of its operations—manu-facturing facilities, distribution centers, service centers, and offices—against intensity targets to reduce waste, energy, carbon, and water use. Currently, SBD is measuring per-formance against a 20-percent intensity reduction goal by2020 (using a 2015 baseline). Annually, the company reports progress against these targets publicly on its website,through investor communications, and by responding toDJSI and CDP working with cross-functional teams fromacross the enterprise.

These multi-year targets are broken down to straight-line reductions per operating unit so that progress can bemeasured both annually and monthly against the targets.Monthly, each operation—including offices and smallerservice centers, as well as manufacturing facilities and distribution centers—reports its waste generation, water use,and energy use into a system that then measures currentprogress against established intensity targets at the operationallevel. Progress of each plant is reviewed by operational leadership monthly during all-encompassing operational staffmeetings that include not just environment, health, andsafety, but financial, fulfillment, and other performance objec-tives. The integration of these environmental metrics into therhythm of business operations ensures leadership can understand and drive action at the discrete operations level.Annually, awards are given to those operations that hit certain established goals, including these environmental targets.Focused corporate support is provided for those operations that


SBD’s CSR strategy: 1. Empower Makers2. Innovate Products with Purpose3. Create a More Sustainable World

43rd Annual A&WMA Information Exchange December 4-5, 2018 • Marriott at Research Triangle Park, Durham, NC

Get the latest information on research and regulatory issues directly from the experts!

Join A&WMA at one of the best kept secrets in the industry for information exchange, networking, and solutions. This year's program will include presentations from US EPA experts on the proposed Clean Affordable Energy Plan, NAAQS, Once in, Always in policy change, Risk and Technology Review (RTR), wildfire emissions, dispersion modeling, and more.

Speakers from industry, NGOs, and other agencies will cover: power plant emissions, battery and electric vehicles, climate change impacts, NC state air quality, monitoring, and more.

Register now at www.awma.org/infoexchange.



lag against targets. These data go through a quarterly internaland annual external assurance process to support public reporting and target-setting.

With the release of SBD’s 2030 CSR strategy, the goals themselves are bolder, but the tactics to measure progress remain similar, at least at this early stage. Each of SBD’s CSR pillars has a bold overarching numeric goal, including sendingzero waste to landfill, being carbon positive, and not impactingimpaired or scarce watersheds, by 2030. These 2030 publiclystated commitments compel operations to think beyond the intensity targets against which the company has historicallytracked and reported progress, to identify and implement mechanisms to truly transform the net environmental impact ofbusiness operations.

Driving Performance Goals Toward SuccessOne of the key mechanisms that SBD uses to drive progress togoals is the engagement of business leadership from the operations and finance organizations to funnel allowance for investment into projects that drive environmental performance,but are beyond the company’s standard productivity investmentthresholds and return on investment criteria. Since 2017, aquarterly investment process has funded projects that havedriven waste, water, energy, and carbon efficiency. That processwill shift to targeting projects that focus on renewables, wastere-use and circularity, and water reduction in regions determined to face water scarcity and quality issues.

In addition to a measurement system that allows for visibilityto progress at every level of the organization, the CSR strategy is also guided through a governance process thatconnects the strategy to business decision making. Pillarleaders are identified in each business that have roles in theleadership of the organization that can help guide decision-making in a manner that is mindful of the overall CSR strategy. Finding operational leaders that have a passion forthe subject in question—whether environmental footprint reduction, upskilling and retraining to align with Industry4.0, or innovating products that have a purpose and drive acircular economy—is critical. These leaders, who sit beyondthe EHS or CSR function, become compelling voices forchange and have a view of the organization that can reflectthe CSR strategy and its targets forums both inside and outside the company.

While bold, SBD’s CSR goals reflect its purpose, so that action, communication, storytelling, and projects are well-aligned with priorities, messaging, and culture withinthe company. The long-standing tracking systems willmorph to focus from the 2020 goals, to the 2030 targets,using the same accountability and visibility systems thathave resulted in SBD’s strong performance in sustainability.Distilling a purpose into commitment around sustainabilityactions—actions that use embedded accountabilityprocesses—assures SBD will have a strong CSR messageand resultant performance for years to come. em

Gretchen Hancock is Senior Director, EH&S and CSR, at Stanley Black & Decker, Inc. E-mail: [email protected]..


The Critical Link betweenSustainability and Business StrategyThis article, based on the author’s book, Introduction to Sustainability Analytics (CRC

Press, 2018), introduces leaders to the untapped potential of sustainability analytics to

determine which metrics are material, relevant, and actionable to their business.

Sustainability Analytics by Ram Ramanan

Advances in enterprise systems are making it feasible for corporations to track and transform performance to meettheir corporate goals. Business analytics enable organizationsto convert raw data into actionable insights to achieve their corporate performance objectives. In the sustainability context,governments and corporations are facing a plethora of ever-ex-panding management challenges related to issues spanningphysical, financial, geo-political, social, and environmental concerns. The quadruple bottom line of sustainability comprisesof profit, people, planet, and purpose.

Sustainable development “meets the needs of the presentwithout compromising the ability of the future generations tomeet their own needs.”1 Sustainability analytics analyze thedata and provide insights that help transform sustainability information into measures across the value-chain and life-cycleto accomplish their social responsibility and sustainability goals.The materiality of these seemingly noneconomic impacts isthe critical link between corporate sustainability and businessstrategies. Organizations must recognize the strong connec-tions between competitive advantage and sustainability issues.

Profit, People, Planet, and PurposeThe quadruple bottom line of sustainability comprises profit,people, planet, and purpose—a more recent enhancement.The materiality of these seemingly noneconomic impacts isthe critical link between sustainability and business strategy.Leaders need insight into how to determine which sustainability metrics are material to them and relevant to their business.With increasing focus on sustainability factors from the market-place (i.e., regulators, investors, financiers, and consumers), cor-porate sustainability disclosure is shifting from voluntary to vital.Business leaders are challenged now, more than ever, by theglobal sustainability and corporate social responsibility issues.This article aims to introduce leaders to the untapped potentialof sustainability analytics. Beginning with the genesis of corporate social responsibility, the article presents the merit ofsustainability analytics to incorporate them into their corporatestrategy, resource allocation prioritization, and decision-makingprocesses.

Genesis of Corporate Social ResponsibilitySocial responsibility is not a new concept. More than a century ago, Mohandas Karamchand Gandhi (MahatmaGandhi) taught us that, the earth provides enough to satisfyevery man’s needs but not every man’s greed; he was one ofthe first to envision sustainable development and its quadrupledimensions, namely prosperity, planet, people, and purpose.Extreme greed, whether for money or nature’s resources, in-deed has disastrous consequences. In 1930, Gandhi’s friendand contemporary, Albert Einstein’s guidance to scientists andengineers—concern for (hu)man and his/her fate must alwaysform the chief interest of all technical endeavors…. should

never be forgotten amid diagrams and equations—was one of the first calls to scientists and engineers to be socially responsible. More recently, Pope Francis, leader of theCatholic faith, drew the world’s attention to one of the megaissues of sustainability when he called climate change a direthreat that humans have a moral responsibility to address.

New Social Contract and Transformed Business AmbianceCorporation and its contract with society have been debatedfrom Nobel Laureate Milton Friedman’s maximize shareholdervalue, to Edward Freeman’s consider the interests of multiplestakeholders, on to the New Social Contract, defined as “business is one thread in the complex web of interwoven society”.2 Risks of corporate tsunamis in today’s synchronousinteractive connectivity ambiance are enormous, as recentlyexperienced by Facebook. Today, with greater recognition thatthere is a strong connection between competitive advantageand sustainability issues and that shareholders are only one ofmany stakeholders, there is a consistent and continual movefrom shareholder primacy to stakeholder primacy; leadersmust steward under this transforming business ambiance. Inthe sustainability context, governments and corporations arefacing a plethora of ever-expanding management challengesrelated to issues spanning physical, financial, geo-political, social,and environmental concerns.

Evolving Corporate Social Responsibility RegulationsEmerging regulations seeking disclosures emanate from government departments of environment, trade & commerce,and finance & treasury to ensure sustainable development; toprotect equity investors investing in publicly listed stocks and tocollect fair share of taxes. Lenders and institutional investors areincreasingly required to disclose, through integrated reporting,how their investments are channeled into responsible opera-tions from the perspectives of longevity, risk, and reward.Stock exchanges are recognizing the need for transparencyon corporate sustainability strategy. The U.S. Securities andExchange Commission (SEC) and several stock exchangesacross the developed world call for reporting material risksin their operations as part of their annual financial reports.Countries like Australia, China, France, India, and the UnitedKingdom require some form of sustainability disclosure compliance by companies listed on their stock exchange.Investors are turning to integrated reporting for a bettercomprehension of the whole picture. Integrating sustainabilityand financial reporting adds further credibility to sustainability disclosures and helps communicate business value of sustainability using analytics to external stakeholders.

The integrated report meets a range of market needs, includingtransparency, inclusiveness, and more information that is material to modern business.





Ram Ramanan, Ph.D., P.E., C. Eng., BCEE, is an Affiliate Research Professor with Desert Research Institute. E-mail: [email protected].

References1. Brundtland Commission. Report of the World Commission on Environment and Development: Our Common Future. Prepared for the United Nations, 1987.2. Taback, H.; Ramanan, R. Environmental Ethics and Sustainability: A Casebook for Environmental Professionals; CRC Press, 2013.3. Ernst & Young. Using data analytics to improve EHS and sustainability performance; http://www.ey.com/Publication/vwLUAssets/ey-using-data-analytics- to-improve-ehs-and-sustainability-performance/$FILE/ey-using-data-analytics-to-improve-ehs-and-sustainability-performance.pdf (accessed May 2017).4. Mateo, J.R.S.C. Multi-Criteria Analysis in the Renewable Energy Industry; Springer-Verlag, 2012; and Rogers, M.; Bruen, M.; Maystre, L.-Y. ELECTRE and Decision Support, Methods and Applications in Engineering and Infrastructure Investment; Springer Science+Business Media, 2000.

Using Sustainability Analytics to OptimizeResource AllocationErnst & Young states that environment, health, and safety(EHS) and sustainability analytics programs help companiesreduce risks and drive cost savings.3 The first three compo-nents listed by Ernst & Young—summarization, visualization,statistical econometric analysis—are elements of more traditionalanalytics. The next three constituents—comprising of spatial,human driven algorithmic and heuristic machine-learning—rep-resent the more advanced analytics applications today. The untapped potential of sustainability analytics is only now beginning to be recognized.

Environment, Social, and Governance MetricsMetrics, or indicators, are measures that describe the currentprogress level or state of a sustainability aspect (e.g., an operation’s energy consumption or greenhouse gas emission).Metrics are the basic units that go into reporting frameworks aswell as indexes. Indexes are aggregates of metrics, designedand defined by the provider of that index, commonly usedby investors (e.g., Dow Jones Sustainability Index). A frame-work is a disclosure of a structured comprehensive set ofmetrics or indicators of the sustainability performance andimpact of an operation, with a focus on the quadruple bottom-line (e.g., Global Reporting Initiative).

Models for Resource Allocation PrioritizationDespite the potential influence of the non-financial factors onfuture value creation, its integration into decision-making remains a challenge. Environmental and sustainability issuesare tough socio-political choices. Society does not have unlimited natural resources, so it becomes necessary to prioritize and allocate resources in an optimal manner.

Cost–benefit analysis quantifies the value of public or corporatepolicy decisions in monetary terms, including consequences(impacts) on all significant stakeholders. Cost-effectiveness

analysis involves computing life cycle costs of competing alternatives, all expressed in present value terms for a givenamount of benefits. Environmental life cycle assessment addresses the environmental aspects and potential impacts ofa product or service throughout their life cycle. Social andsocio-economic life cycle assessment assesses the social andsocio-economic aspects of products and their potential positive and negative impacts along their life cycle.

Strategic decision models (a) use probability distributions fordecision analysis using decision trees or (b) use priority rankings, such as multiple-criteria decision-making, which canconsider both technical and non-technical attributes. Thesemethods have been successfully applied in a wide range of applications related to energy and sustainability problems.4

ConclusionSustainability analytics has significant untapped potential toidentify material metrics and to prioritize allocation of resources to these material initiatives. The need to garner insight for government or corporate policy decisions has ledto the development and use of statistical or econometricanalysis for decision-making.

The U.S. government has performed complex and intensecost–benefit and risk analysis for significant regulatory efforts, such as the U.S. Clean Air Act. Recent advances inremote sensing and data capture, have propelled applica-tion of analytics to a different stratum. Spatial analysis withreal-time feedback provides granular insight into potentialopportunity and risk for operational improvement. Human-driven algorithmic analysis informs real-time intervention ormulti-criteria decision-making through predictive and preventive analysis of real-time data. However, the widearray of diverse real-time data from global operations withpotential legal ramifications continues to be a governancechallenge. em

Lightning NOx Emissions and theImplications for Surface Air Qualityover the Contiguous United States

As one of the largest natural sources of nitrogen oxides, it is estimated that light-

ning-induced NOx (LNOx) contributes up to 15 percent of the total global NOx

emissions budget. Following on from the focus of last month’s topic, Advances in

Air Quality Modeling, this article considers the impact of LNOx on air quality

through robust LNOx production and distribution schemes in air quality models.

Lightning NOx Emissions by Daiwen Kang and Kenneth Pickering



Ground-level ozone (O3), predominantly formed fromphotochemical reactions in the atmosphere, responds tovarying precursor emissions, meteorology, and climate. Toprotect human health and welfare,1 the National Ambient AirQuality Standards (NAAQS) for O3 (https://www.epa.gov/ozone-pollution/table-historical-ozone-national-ambient-air-quality-standards-naaqs) have been tightened through theyears. In response to the tightened O3 standards, extensivecontrol measures for nitrogen oxides (NOx), one of the crucial precursors in O3 formation, have been implementedacross the United States, and they have led to significant reduction in anthropogenic NOx emissions in the past twodecades.2

Assessments on O3 trends3 have suggested varying O3

responses to NOx reductions during different seasons and indifferent regions in United States. Though O3 mixing ratioshave been generally decreasing with the emission reductions,summertime O3 in the Intermountain West regions duringpollution episodes occasionally exceeds the current 70 partsper billion by volume (ppbv) NAAQS standard with littleoverall trend despite stringent precursor emission controls.The researchers have attributed these summertime anomaliesto the increasing Asian emissions and more frequent occur-rences of hot extremes, but one important component, light-ning-induced NOx (LNOx), is missing in their assessments. As one of the largest natural NOx sources, it is estimated that

Sustainability Analytics by Ram RamananLightning NOx Emissions by Daiwen Kang and Kenneth Pickering

One important component, lightning-

induced NOx (LNOx), has been missing

from most assessments of high ozone

pollution episodes.

LNOx contributes approximately 10 to 15 percent of thetotal global NOx emissions budget.4 Lightning activity andthe associated distribution of LNOx exhibits strong spatialand temporal variations.5 To accurately assess the impact ofLNOx on air quality, the LNOx contributions to the total NOxemissions need to be quantified in space and time, which entails robust LNOx production and distribution schemes in airquality models.

In the Community Multiscale Air Quality (CMAQ)6 model,for retrospective simulations, we have implemented a LNOxproduction scheme based on hourly gridded cloud-to-groundlightning flashes from the National Lightning Detection Network (NLDN)7 and satellite-based climatological intracloudto cloud-to-ground flash ratios8 to estimate gridded hourly totalLNOx across the contiguous United States. However, the relative impact of LNOx on near-surface O3 depends notonly on lightning activity, but also on meteorology and NOxemissions from other sources, such as anthropogenic NOxand soil nitric oxide (NO) emissions.

Using the 2011 National Emissions Inventory (NEI) for anthropogenic NOx emissions and soil NO emissions estimated using CMAQ inline biogenic emission model, wequantify the relative contributions of LNOx to the total NOxemissions budget in time and space for April to September2011 over the contiguous United States. Model simulationswith and without LNOx were assessed against measurementsfrom the U.S. Environmental Protection Agency’s Air QualitySystem (AQS) (https://www.epa.gov/aqs) and ozone-sonde

data collected from the Deriving Information on Surface Conditions from Column and Vertically Resolved ObservationsRelevant to Air Quality (DISCOVER-AQ) 2011 campaign(http://www.nasa.gov/).

LNOx and Its Relative Contributions to Total NOxFigure 1 shows the spatial distribution of NOx from anthropogenic sources: (a) soil NO; (b) LNOx generated byCMAQ using NLDN lightning flash data; and (c) the relativecontribution of LNOx to total NOx (a+b+c) during July2011. Figure 1d indicates that the LNOx ratios are largestover the Rocky Mountains area (see Figure 2a) followed bythe Southeast region; in some limited areas, the LNOx ratioscan reach more than 90 percent of the total NOx emissions,suggesting that LNOx is the primary NOx emissions overthese areas in that specific month.

To help identify the regional and monthly differences inLNOx contributions, Figure 2b presents the monthly LNOxratios from April to September 2011 over the entire domainand for several sub regions. Over the contiguous UnitedStates, the contribution from LNOx emissions to the totalNOx emissions ranges from 10 percent (September) to 22percent (July).

Averaged over the six-month period, the Southeast regionhas the largest LNOx ratios (20%) followed by the RockyMountains area (16%). During July and August, the largestLNOx ratios are observed for the Rocky Mountains region(30% and 28%, respectively). LNOx ratios over Pacific Coast

region are the smallest, contributing less than 3 percentacross all months. Daily LNOx contributions for the South-east and Rocky Mountains regions over six-month period arepresented in Figure 3. In the Southeast region from June


Figure 2. (a) Regions and (b) the monthly ratio of LNOx to the total NOx emissions over the domain and each of the regions.

Figure 1. Total monthly emissions (in 106 moles per grid cell 12 km x 12 km, over 144-km2 area) and the LNOx ratios during July, 2011: (a) anthropogenic NOx, (b) soil NO, (c) LNOx, and (d) the ratio of LNOx to total NOx emissions.

through August, LNOx is frequently a significant contributionto total NOx on a daily basis; the same is true for the RockyMountains region (see Figure 3b), but the time shifted laterfrom the middle of June to the middle of September.



Impact on Air QualityTo evaluate the impact of LNOx on air quality, simulationswith LNOx (U.S. National Lightning Detection Network[NLDN] data) and without LNOx (Base) using CMAQv5.2over 12 km contiguous United States domain were per-formed. Figure 4 shows the gridded daily lightning flash ratefrom NLDN and the corresponding changes (NLDN–Base)of the maximum surface hourly O3 mixing ratios on July 11,2011. The maximum change of hourly O3 mixing ratioranges mostly from 6 ppbv to 30 ppbv in the regions oflightning flashes.

Mean Bias (MB = model–observed) between modeled andobserved daily Maximum 8-hr O3 (DM8HRO3) mixing ratiosfrom Air Quality System (AQS) sites located in the Southeastand Rocky Mountains regions are calculated, and the meandifferences of mean bias (MBDIFF = MBNLDN – MBBASE)between the NLDN and the Base are presented in Figure 5.Although LNOx to total NOx ratios are the largest in boththe Southeast and Rocky Mountains regions among all thesub regions, the impact on surface O3 is very different. InSoutheast region, DM8HRO3 is overestimated in the Base compared to observations, which becomes worse (most oftenby only ~1 ppbv) with the addition of extra LNOx emissionsin the NLDN, resulting in an increase in mean bias for mostdays. The opposite is true for the Rocky Mountains region as DM8HRO3 is underestimated in the Base, so the additionof LNOx in the NLDN results in a reduction in mean bias compared to the Base.

To examine the impact of LNOx on vertical O3 profiles, we utilized ozone-sonde data at Beltsville and Edgewood, Mary-land, measured during the 2011 DISCOVER-AQ campaign ondays when significant lightning impact was observed in themodel simulations at each location. We paired the observedozone-sonde data with model predictions in time and spaceand take the average over all the ozone-sondes (one or twomeasurements per day) on the selected days at each location.As shown in Figure 6, the Base significantly underestimatesO3 aloft, but overestimates O3 near the surface, while withthe addition of LNOx in the NLDN reduces both the under-estimation aloft and the near-surface overestimation. Andwhile the bulk statistics don’t reveal the benefit in model performance from including LNOx emissions over the regions such as Southeast, where surface O3 mixing ratiosare already over predicted by the Base model, the addedvalue is apparent from the improved vertical structure of O3,at least for the two locations presented here. LNOx emissionsrepresent a potentially significant contribution to the totalNOx emissions budget across much of the United Statesduring the warmer months, and therefore it is important toinclude LNOx in regional model simulations to improve theaccuracy of air quality predictions.

SummaryThe CMAQ model (Version 5.2) contains a lightning NOx


Figure 3. The daily ratio of LNOx to the total NOx emissions in (a) Southeast and (b) Rocky Mountains.

Figure 4. The daily NLDN lightning flash rate (a) andthe maximum change (NLDN – Base) of hourly surfaceO3 (b) on July 11, 2011.


Figure 5. Daily mean bias difference (NLDN-Base) for the Southeast and Rocky Mountains regions at the AQS monitoringsites (the number in the parentheses following the region names are the number of AQS sites).

Figure 6. Mean vertical O3 profiles from ozone-sonde observations and model simulations at Beltsville (a) and Edgewood (b)on days when significant lightning impact was observed near each location.




Daiwen Kang is a Physical Scientist with the Computational Exposure Division of the U.S. Environmental Protection Agency’s NationalExposure Research Laboratory. E-mail: [email protected].

Kenneth E. Pickering is a Research Professor in the Department of Atmospheric and Oceanic Science at the University of Maryland,College Park. E-mail: [email protected].

Disclaimer: The views expressed in this article are those of the authors and do not necessarily represent the views or policies of the U.S.Environmental Protection Agency. Mention of trade names or commercial products does not constitute endorsement or recommendationfor use.

References1. Integrated Science Assessment for Ozone and Related Photochemical Oxidants; EPA/600/R-10/076F; U.S. Environmental Protection Agency’s National Center for Environmental Assessment: RTP, NC, 2013.2. Simon, H.; Reff, A.; Wells, B.; Xing, J.; Frank, N. Ozone Trends Across the United States over a Period of Decreasing NOx and VOC Emissions; Environ. Sci. Technol. 2015, 49, 186-195; doi:10.1021/es504514z.3. Lin, M.; Horowitz, L.W.; Payton, R.; Fiore, A.M.; Tonnesen, G. US surface ozone trends and extremes from 1980 to 2014: quantifying the roles of rising Asian emissions, domestic controls, wildfires, and climate; Atmos. Chem. Phys. 2017, 17, 2947-2970; doi:10.5194/acp-17-2943-2017.4. Schumann, U.; Huntrieser, H. The global lightning-induced nitrogen oxides source; Atmos. Chem. Phys. 2007, 7, 3823-3907; doi:10.5194/acp-7-3823-2007.5. Medici, G.; Cummins, K.L.; Cecil, D.J.; Koshak, W.J.; Rudlosky, S.D. The intracloud lightning fraction in the contiguous United States; Mon. Wea. Rev. 2017, 145, 4481-4499; doi:10.1175/MWR-D-16-0426.s1.6. Appel, K.W. et al. Description and evaluation of the Community Multiscale Air Quality (CMAQ) model version 5.1; Geosci. Model Dev. 2017, 10, 1703-1732; doi:10.5194/gmd-1703-2017.7. Orville, R.E.; Huffines, G.R.; Burrows, W.R.; Holle, R.L.; Cummins, K L. The North American Lightning Detection Network (NALDN): first results, 1998-2000; Mon. Wea. Rev. 2002, 130, 2098-2109.8. Boccippio, D.J.; Cummins, K.L.; Christian, H.J.; Goodman, S.J. Combined Satellite- and Surface-Based Estimation of the Intracloud–Cloud-to-Ground Lightning Ratio over the Continental United States; Mon. Weather Rev. 2001, 129, 108-122.

algorithm that uses observed lightning flashes along with anassumed NOx production per flash and a scheme to distribute the NOx in the vertical atmosphere. A CMAQ simulation for summer 2011 shows that the LNOx to totalNOx emission ratio are highest in the Southeast and Rocky

Mountains regions. The addition of lightning NOx emissions reduces the daily CMAQ low bias for maximum 8-hr O3 byas much as 5 ppbv in the Rocky Mountains region. Thelightning source of NOx should be included in regional airquality models. em

EPA Research Highlights

During the summer of 2013, some 60 atmospheric scientistsconverged in Alabama, Tennessee, and North Carolina for oneof the largest air monitoring studies in the region in twodecades. Called the Southern Oxidant and Aerosol Study,the scientists set out to study everything they could about the physical and chemical interactions of many pollutants in theatmosphere. Among other inquiries, they wanted to morefully understand why the region was experiencing elevatedlevels of secondary organic aerosols (SOAs).

SOAs are air pollutants produced from emissions from treesand plants and human-made sources. They are producedthrough a complex interaction of sunlight, air pollutants fromcars or industrial emissions, and other airborne chemicals.SOAs are also a major component in the production of fine particle pollution (PM2.5), which can cause or worsen lungand heart problems and other health effects. Trees provide

many benefits, including natural beauty, shade, support ofecosystems, and absorption of carbon dioxide—a pollutantand greenhouse gas—but they also emit chemicals calledvolatile organic compounds (VOCs). The researchers fromthe U.S. Environmental Protection Agency (EPA), other agencies, and universities found that when VOCs from vegetation interact with human-made pollutants, air qualityproblems can get worse.

Prior research pointed to the mixing of human-made andnaturally-emitted pollutants as a major factor in SOAs creation and therefore fine particle pollution, which is regulated under the National Ambient Air Quality Standards(NAAQS). The study confirmed that chemical interactions ofthese pollutants lead to more PM2.5 in the Southeast UnitedStates, a region that is heavily forested and contains largeurban areas such as Atlanta.

Ann Cornelius Brown

Understanding Air Pollution in the Southeastern United States


The Southern Oxidant and Aerosol Study: Researches took measurements on the ground and at high elevations.


“Results from this study and the umbrella study, Southern Atmosphere Study, provide chemical insight into how currentand planned federal air quality rules regarding human-madenitrogen oxide and sulfur dioxide emissions provide additionalbenefits by also reducing organic fine particle mass (from treesand vegetation),” says Annmarie Carlton, a recipient of a grantfrom EPA’s Science to Achieve Results (STAR) program, who isa lead investigator in the study. “The findings suggest theU.S. Clean Air Act is more successful at safeguarding humanhealth than many assessments suggest.” These results are described in the paper, Additional Benefits of Federal Air-Qual-ity Rules: Model Estimates of Controllable Biogenic SecondaryOrganic Aerosol, by Carlton et al. (Environ. Sci. Technol., 2018,52 (16), DOI: 10.1021/acs.est.8b01869; pubs.acs.org/doi/10.1021/acs. est.8b01869).

Carlton and colleagues applied the chemistry data collectedin the research campaign to EPA’s air quality model, calledthe Community Multiscale Air Quality Modeling System(CMAQ), which is used by states to implement air qualitystandards. They found that human-made pollution helps totransform naturally-emitting VOCs from trees into fine particles.So, when emissions from motor vehicles and industry are reduced by air quality management, the opportunity for interaction with VOCs from trees and plants goes down. Theresult: less production of SOAs and less formation of PM2.5.

The study employed a wide array of sophisticated air monitor-ing instruments not available previously that enabled scientiststo gain greater knowledge of what is occurring when multiplepollutants mix and interact. They took measurements on theground and at high elevations using balloons and aircraft toobtain data on ozone, nitrogen oxides, VOCs, semi-volatileorganic compounds, sulfur dioxide, particulate matter.

EPA participated in the study by supporting 14 STAR grantsawarded to academic institutions. Scientists at the agency alsoused a SOA tracer method they developed, which measuresspecific chemical “marker” compounds to differentiatehuman-made SOA sources from natural sources.

The entire body of research from these studies has made sig-nificant contributions to the understanding of air pollution inthe eastern United States and provided the science neededby decision-makers to further improve air quality in the re-gion. A second paper, Synthesis of the Southeast Atmos-phere Studies: Investigating Fundamental AtmosphericChemistry Questions, by Carlton et al. (Bull. Am. Meteorol.Soc., 2018 99 (3); DOI: 10.1175/BAMS-D-16-0048.1; journals.ametsoc.org/doi/full/10.1175/BAMS-D-16-0048.1),provides a comprehensive synthesis of major findings of thetwo studies.

In the paper, Carlton explains how researchers have gainedinsight into the extent to which airborne particles play a rolein regional temperature trends and how human-made andnatural pollution sources interact and affect air quality and climate. They have learned more about how air chemistrychanges as an air mass ages and is transported across a region; how much SOA comes from various sources (trees,motor vehicles, industry, wildfires, etc.) and whether carbonfound in airborne particles comes from natural sources (treesand other vegetation), or from human-made emissions fromcars, trucks, trains, industry, or coal-fired power plants.

The extensive research has generated more than 111 pub-lished papers, providing a wealth of data and findings that havebeen made available to the public that can be used for furtherresearch and analysis. em

EPA Research Highlights

More Information

The database on the Southern Atmospheric Study (SAS) is available online at https://www.eol.ucar.edu/field_projects/sas.

Other organizations that funded researches or participated in the Southern Oxidant and Aerosol Study include the National Science Foundation (NSF), the National Oceanic and Atmospheric Administration (NOAA), Southern Company, and ElectricPower Research Institute.

For more information about this column, contact Ann Cornelius Brown, U.S. Environmental Protection Agency (EPA), Office of Research and Development, Research Triangle Park, NC; phone: 1-919-541-7818; e-mail: [email protected].

Regulatory Roundup

Affordable Clean Energy Rule Announced as Replacement for Clean Power PlanOn August 21, 2018, EPA revealed that it was proposing a rule to address GHG emissions from coal-fired electric utilitygenerating units and power plants. The Affordable Clean Energy(ACE) rule is the long-awaited replacement for the Obama-eraClean Power Plan (CPP). The Obama EPA put the CPP in placein 2015 as an affirmation of a commitment (at the time) on thepart of the United States to aggressively address GHG emis-sions prior to its entry into the Paris Agreement within theUnited Nations Framework Convention on Climate Change.

The CPP never took effect due to court challenges brought by27 states, 24 trade groups, and 37 rural electric cooperatives.The CPP was stayed by the U.S. Supreme Court in early 2016,pending the resolution of this litigation. The outcome of the

November 2016 presidential election left it highly unlikely thatthe CPP would ever be implemented as enacted. PresidentTrump’s subsequent withdrawal of the United States from theParis Agreement in 2017 removed any remaining doubt as tothe CPP’s ultimate fate. The only lingering question was how—or if—the CPP would be replaced?

EPA’s ACE proposal reflects a dramatically different approachto addressing GHG emissions from the utility sector. Mirroring statements by the White House with respect to EPA’snewly assigned role in spurring the national economy, the ACEemphasizes empowering states to adopt individualized approaches (with certain loosely-imposed EPA restrictions) toreducing GHG emissions, while simultaneously promoting economic growth and job creation. This decentralizationwould allow states with a large number of coal mines and/or

by William H. Haak, Attorney and Consultant, Haak Law LLC

EPA Proposes ACE Rule; MATS Overhaul


In late August, the U.S. Environmental Protection Agency (EPA) announced twonew efforts to relax or replace Obama-era air pollution regulations that targetedemissions of greenhouse gases (GHGs), mercury, and air toxics from coal-firedpower plants. The history of the rules in question, EPA’s current plans, and theagency’s likelihood for success are discussed below.


William H. Haak is an environment, health, and safety attorney and consultant, with over 24 years of experience. E-mail: [email protected].

coal-fired power plants to tailor their regulations to reflect the reality of their respective economies. By potentially reducingthe cost of compliance for coal-fired plants, states could alsocontrol the retail cost of electricity within certain service areas.

From a cost-benefit standpoint, EPA estimates (broadly) thatthe ACE could result in US$3 billion to US$6.5 billion in netbenefits (including avoided compliance costs) compared tothe CPP. In terms of both GHG emissions and the emissionsof criteria pollutants such as sulfur dioxide and nitrogen dioxide, EPA’s analysis acknowledges that the ACE will result inincreased emissions versus what would have been realizedunder the CPP. EPA seemingly dismisses the validity of thiscomparison, however, by assuming arguendo that the CPPwould have been struck down in federal court as exceedingthe agency’s authority under the U.S. Clean Air Act. Theagency, therefore, focuses on the reductions that the ACE will theoretically lead to with “no CPP” as the baseline.

One thing that the ACE is almost certain to have in commonwith the CPP is a long and winding path to implementation.Beyond its initial notice and comment period, the ACE willsurely face multiple legal challenges from both environmentalgroups and the usual cadre of Northeastern states that routinely sues EPA for emissions from upwind states. Opposition from Northeastern states may be especiallyheated given their reduced reliance on electricity generatedfrom coal-fired plants, and their geographic position down-wind of Midwestern states that are heavily reliant upon bothcoal mining and coal-fired power plants.

Even if the ACE survives legal challenges, the rule itself provides lengthy initial periods for states to develop compliance plans (three years), for EPA to review state plansubmittals (one year), and for the agency to implement afederal implementation plan (FIP) in the face of a deficientstate plan (two years). This timeline means that—even absent legal challenges—the ACE may not see implementa-tion in many states until 2023 or later.

Lost in much of the early analysis of the ACE in its contextas a replacement for the CPP is the fact that EPA is also proposing a new applicability test for determining whether a physical change or change in the method of operation ofan electric generating unit is a “modification” under federalNew Source Review (NSR). The proposal seeks to refocus theanalysis on whether any change would result in an increasein hourly emissions (vs. the current NSR focus on emissions ona ton-per-year basis). The proposed approach would comport

NSR with the way that EPA has historically defined “modifica-tion” for New Source Performance Standard purposes, and result in an administrative reversal of the Supreme Court’s decision in Environmental Defense v. Duke Energy Corp., 549U.S. 561 (2007).

EPA Announces Review of the Mercury andAir Toxic Standards RuleEPA also announced in late August that the agency had prepared a draft proposal concerning reconsideration of the2012 Mercury and Air Toxics Standards (MATS) rule. MATSis an Obama-era regulation aimed at reducing emissions ofmercury and air toxics, including arsenic, chromium, andnickel, from coal-fired power plants. Like many otherObama-era regulations directed toward power plants, MATShad been the subject of protracted litigation—culminating in a 2015 Supreme Court decision that left the MATS rule inplace, but directed EPA to reconsider the rule specifically withrespect to the cost of compliance with the rule for impactedelectric generating utilities.

The agency’s announcement of a draft proposal pertaining to MATS left it unclear (at the time of this writing) whetherthe regulation would be overhauled, replaced in its entirety,or simply rescinded. Given the Trump Administration’s concerted efforts to reinvigorate the coal industry throughenvironmental deregulation, each of these options is equallylikely. EPA indicates that the draft proposal will question bothwhether MATS is “appropriate and necessary” and whetherthe emissions control technology-based standards set byMATS are proper.

A cost-benefit analysis conducted by EPA at the time MATSwas promulgated in 2012 found that the health benefits ofthe rule outweighed compliance costs 9 to 1 (with estimatedcompliance costs nearing US$10 billion per year). It is unclearwhat a revised cost-benefit analysis might show if one wereto be conducted today. This is especially true in light of the fact that the vast majority of coal-fired plants have alreadycompleted the capital investments necessary to comply withMATS. An undoing or relaxation of MATS would in no wayallow coal-fired plants to recoup their earlier capital expendi-tures—although it may enable regulated entities to reduce oravoid ongoing expenses related to compliance. Given this, itwould appear that an updated cost-benefit analysis mightweigh heavily in favor of keeping the standards established byMATS in place in order to reap ongoing health benefits at nosubstantial incremental cost of compliance. em

Regulatory Roundup

Last Stop

On this page you will find the company profiles of a randomly selected grouping

of Organizational Members. A&WMA thanks you—and all of our current

Organization Members—for your continued support of this Association.

Locke Lord LLP (lockelord.com) is a national law firm, with a history of working with industry.Home to a team of dedicated environmental practitioners who recognize the many dimensions ofenvironmental law and the different ways these laws affect business, the firm’s nationwide experienceincludes enforcement defense, remediation and regulatory interaction, complex environmental litiga-tion, auditing, emergency response, compliance counseling, permitting, and facility siting. LockeLord represents clients across virtually every industry sector, including energy, exploration andproduction, manufacturing, waste management, mining, metals, chemicals, and property redevel-

opment. In particular, the firm regularly represents industry in high-profile litigation involving enforcement defense, liability allocation, and exposure matters. Locke Lord and many of its environmental lawyers are recognized year after year inChambers USA: America’s Leading Lawyers for Business and The Best Lawyers in America.

Woodard & Curran (woodardcurran.com) is an integrated engineering, science, and operationscompany. Privately held and steadily growing, Woodard & Curran serves public and privateclients nationwide. From its environmental roots to the range of consulting, engineering, and operations expertise the company provides today, Woodard & Curran works for a diverse clientele, including chemical manufacturing, municipalities, the energy industry, food and beverage manufacturers, colleges and universities, and the real estate community. At the heart of the company are the talented people whose commitment and integrity drive results for itsclients each and every day. em

Send Us Your InformationIf you are a current Organizational Member and would like your company profile to be included in a future issue of EM, pleasecontact Lisa Bucher, Managing Editor at [email protected].

Consider Upgrading to Organizational MembershipOrganizational Membership is the perfect solution for organizations with six or more environmental professionals on staff who wantto reduce membership costs and increase their visibility and participation in A&WMA. For more information, go towww.awma.org/join.

The views expressed are those of the individual organizations and do not necessarily represent an official position of the Association. A&WMA does notendorse any company, product, or service appearing on this page.


Air Quality Modeling

Spotlight on Recent Advances

The Magazine for Environmental ManagersOctober 2018

National Ambient

Air Quality Standards

As EPA Goes Back to Basics, State and Regional

Agencies Strive to Continue NAAQS Successes

The Magazine for Environmental Managers

September 2018

Remember EM is available for FREE to all A&WMA membersin digital app, flipbook .pdf, and downloadable .pdf versions.If you haven’t done so already, download the A&WMA Apptoday and don’t miss out on this essential reading.

A&WMA HeadquartersStephanie M. GlyptisExecutive DirectorAir & Waste Management AssociationKoppers Building436 Seventh Ave., Ste. 2100Pittsburgh, PA 152191-412-232-3444; 412-232-3450 (fax)[email protected]

AdvertisingJeff [email protected]

EditorialLisa BucherManaging [email protected]

Editorial Advisory CommitteeJohn D. Kinsman, ChairEdison Electric InstituteTerm Ends: 2019

Teresa Raine, Vice ChairERMTerm Ends: 2020

Robert BaslEHS Technology GroupTerm Ends: 2019

Leiran BitonU.S. Environmental Protection AgencyTerm Ends: 2019

Gary Bramble, P.E.RetiredTerm Ends: 2021

Bryan ComerInternational Council on Clean TransportationTerm Ends: 2020

Prakash Doraiswamy, Ph.D.RTI InternationalTerm Ends: 2020

Ali FarnoudRamboll EnvironTerm Ends: 2020

Steven P. Frysinger, Ph.D.James Madison UniversityTerm Ends: 2021

Keith GaydoshAffinity ConsultantsTerm Ends: 2021

C. Arthur Gray, IIIGivaudan Flavors Corp.Term Ends: 2019

Jennifer K. KelleyGeneral ElectricTerm Ends: 2020

Mingming LuUniversity of CincinnatiTerm Ends: 2019

David H. Minott, QEP, CCMArc5 Environmental ConsultingTerm Ends: 2020

Brian Noel, P.E.Trinity ConsultantsTerm Ends: 2020

Golam SarwarU.S. Environmental Protection AgencyTerm Ends: 2019

Anthony J. Schroeder, CCM, CMTrinity ConsultantsTerm Ends: 2019

Susan S.G. WiermanRetiredTerm Ends: 2021

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EM, a publication of the Air & Waste Management Association, is published monthly with editorial and executive offices at The Koppers Building, 436 Seventh Ave., Ste. 2100, Pittsburgh, PA 15219, USA. ©2018 Air & Waste Management Association(www.awma.org). All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. A&WMA assumes no responsibility for statements and opinions advanced by contributors to this publication. Views expressed in editorials are those of the author and do not necessarily represent an official position of theAssociation. A&WMA does not endorse any company, product, or service appearing in third-party advertising.

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