Climate Change Policy— A World of Varying Approacheshistory of China’s participation in climate...

The Magazine for Environmental Managers July 2020

Climate Change Policy—A World of Varying Approaches

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Features

China Climate Change Policies and Progressby David Heitz and Kevin S. Leahy

Pennsylvania’s Climate Policy Roadmapby Megan Uhler

Understanding and Navigating Climate Change Philosophy in Oklahomaby Ken Senour

The Unpredicted SpeedBump: What Impact WillCOVID-19 Have on GlobalClimate Change Objectivesand Progress?by Michele E. Gehring

Climate Resilient Indiaby Keerthi Palanisamy and S. Rao Chitikela

Waste Management CornerIn this month’s article, MD Sahadat Hossain andMelanie Sattler discuss landfill mining as a means toextend the capacity of existinglandfills.

Landfill Mining: A Step Toward Sustainable Landfillsby MD Sahadat Hossain andMelanie Sattler

em • The Magazine for Environmental Managers • A&WMA • July 2020

Table of Contents

Climate Change PolicyA World of Varying Approachesby Gary M. Bramble

This month, EM considers climate change policy questions,such as what have leading nations such as the United States,China, and India accomplished to date, and what is their climate commitment for the future? And how might futureclimate policy directly affect A&WMA members?Cover photo by Scott Arentsen.

The photo was taken in Iceland in an iceberg-filled lake called Jőkulsárlón, where the icebergs calve from the glacier Breiðamerkurjőkull. The glacier has been melting more quickly in recent years, so that the lake is now the deepest in the country.

ColumnsRegulatory Roundup: Updated Interpretation for NSR Permitting; EPA Cuts Legs Out from Under MATSby William H. Haak

YP Perspective: COVID-19 vs. ClimateChangeby Patrik Eskandari

Thank You to This Month’s Advertisers: • Jacobs• TSI

DepartmentsMessage from the President:Adaptation and Climate Changeby Kim Marcus

Back In Time—A&WMA’s Annual Critical ReviewTurns 50:1995 Annual Critical Review: MeasurementMethods to Determine Compliance with Ambient Air Quality Standards for Suspended Particlesby J.C. Chow

Challenging today.Reinventing tomorrow.

Follow us @JacobsConnects

www.jacobs.com

Combining knowledge and imagination, we are committed to understanding your air quality and waste management challenges so that we can develop and implement innovative, sustainable and cost-effective solutions that maximize operational efficiency and maintain compliance.

We do things right.

We challenge the accepted.

We aim higher.

We live inclusion.


Cover Story by Melanie L. SattlerMessage from the President

I suspect that all of us have become, if not proficient,then better acquainted and comfortable with virtual com-munication and interaction. Certainly, we continue to adaptand adopt different forms of communication as this yearprogresses. Whoever first said “Necessity is the Mother ofInvention” was spot on, and A&WMA and the rest of theworld have embraced this fully.

Moving traditional face-to-face programing to a virtual plat-form—and its evolution in terms of functionality and ease—has occurred at lightning speed. The Association was ableto reschedule some of our spring programs, including theCommunity Wildfire Recovery Conference (www.awma.org/wildfires) and the New Source Review Workshop(www.awma.org/NSRWorkshop), to dates in the fall in the hopes that they can be held face to face. A&WMA’sAnnual Conference & Exhibition (ACE), on the other hand, was neither moved nor cancelled, but quickly transformed to an all-virtual format. This took a major effort by hundreds of people, spearheaded by A&WMAstaff, Councils, Local Host Committee, and Board of Directors. This shift allowed us to honor the work of themany authors, presenters, exhibitors, sponsors, and otherparticipants of the original planned conference andbrought certainty to our signature annual event. VirtualACE 2020 (www.awma.org/ace2020) was a spectacularevent that has shown us that our Association is bothinnovative and adaptable.

Speaking of adapting to change, this month’s EM focuseson climate change policies. The global climate continuallychanges at macroscopic and microscopic levels. The invitedauthors in this issue dig into many aspects of climatechange policy and consider their impacts in the UnitedStates, China, and India, including their ongoing commit-ment to addressing climate change.

COVID-19 has been a scourge for many reasons, but thereare some interesting data coming in related to many environ-mental aspects and climate change resulting from reducedanthropogenic activities (even if temporary): Visibility has improved significantly in many cities to levels that have notbeen experience in many decades; stormwater runoff hasalso improved because of the reduction of vehicle traffic and reductions in industrial discharges; and water quality incities like Venice has improved due to the lack of turbidity. We will be studying this period in history for years to come asat no other time in modern history has there been the abilityor need to slow down our global mobility and industrial activities. Models can be good approximators of what mighthappen in these type events, but empirical data are just that.

Positive climate change may also be enhanced by the evolu-tion of the office workspace. While tragically millions of peo-ple have been laid off, furloughed, or put on reduced workweeks, many others continued to work but stopped or couldnot go into the offices, factories, and business. These workersadapted and many found that there were ways to advancetheir services or products without needing a central officespace from which to work. Working remotely from home andcurtailing commuting by fossil fuel vehicles not only reducesgreenhouse gases but could also radically changes officespace needs. Reducing office space could reduce the needfor building construction. Reducing vehicle traffic could leadto more open space and increase greenspace. We will see theresults once we are on the downhill side of the curve.

One thing is clear as the move to reopen the economy buildsmomentum: humans are predominately social creatures,whether it is for work, pleasure, recreation, or networking purposes. To this end, A&WMA will be active in continuing tocreate a mix of events in both virtual and face-to-face formats,as works best for the needs of our members. em

Kim Marcus » [email protected]

Adaptationand ClimateChange

This month, EM considers climate change policy questions, including what have lead-ing nations such as the United States, China, and India accomplished to date, andwhat is their climate commitment for the future? And how might future climate policydirectly affect A&WMA members?

Climate Change Policy

A World of VaryingApproaches

Photo by Scott Arentsen.

Cover Story by Gary M. Bramble



Cover Story by Gary M. Bramble

The articles that follow explore the climate change policycommitments of the world’s two most populous countries—China and India—and that of two U.S. states—Pennsylvaniaand Oklahoma—as well as keen insights from A&WMA’spresence at the United Nations’ 2019 climate talks in Spain.

In the first article, David Heitz and Kevin S. Leahy discuss thehistory of China’s participation in climate discussions leadingup to its commitments for future years. China submitted itsgoals to the United Nations in June 2015, in which it com-mitted to hit peak carbon dioxide (CO2) emissions by 2030, increase non-fossil fuels in its primary energy mix to 20%,and lower CO2 emissions per unit of GDP by 60–65% from2005 levels. Readers may be impressed to learn that Chinais number one in the world in wind, solar, and new nuclearpower. However, its total CO2 emissions continue to grow,in large part, due to numerous new coal-fired power plants.

In the second article, Keerthi Palanisamy and S. Rao Chitikeladiscuss the low per capita emissions of CO2 from India andIndia’s commitment to always keep per capita emissionslower than the European Union and the United States. Forperspective, the U.S. annual per capita CO2 emissions areapproximately 16 metric tons; China is about 8 metric tons;and India is roughly 2 metric tons. The authors studied inIndia and revisited India while writing this article.

Next, we move our attention to the United States, which has formally announced that it will withdraw from theUnited Nations Paris Climate Accords on November 4,2020. Accordingly, the focus here is not on U.S. federal climate policy, but instead the climate change policy of twoU.S. states, by way of example.

First, Megan Uhler describes the flurry of recent initiativestaken by Pennsylvania to reduce CO2 emissions and to pre-pare for entry in the regional CO2 cap-and-trade program(RGGI). On January 8, 2019, Pennsylvania Governor Tom

Wolf signed Executive Order 2019-01, committing Pennsyl-vania to reducing the state’s net greenhouse gas (GHG)emissions by 26% by 2025 from 2005 levels and to furtherreduce the state’s net GHG emissions by 80% by 2050. Ex-ecutive Order 2019-01 also establishes energy consumptionperformance goals for Pennsylvania’s state agencies, requiresthe replacement of a subset of the state’s passenger car fleetwith battery electric and plug-in electric hybrid cars by 2025,and requires the procurement of renewable energy to offsetat least 40% of the state’s annual electricity use.

Second, Ken Senour describes how a non-coastal energystate, Oklahoma, focuses on resiliency, adaptation, and mitigation of climate change effects. The author notes thatthe City of Norman became the first community in Okla-homa to set a goal to transition to 100% renewable energyin city buildings by 2035 and using 100% renewable energy across the board by 2050. He reports that Oklahoma’s CO2 emissions declined significantly in 2016 and 2017,even though Oklahoma had no written goals, targets, orcommitments to do so.

The final article is by A&WMA Immediate Past-President,Michele Gehring, who has tremendous insights obtained bybeing an A&WMA Observer at the last two U.N. Confer-ences of the Parties (COPs) in Poland (2018) and Spain(2019). As an Official Observer, she was able to garner perspectives from Observers from all over the world. In thisarticle, she shares what she learned about three different CO2-emitting sectors—transportation, energy, and industry—and also ponders how the current COVID-19 pandemicmay affect the ability of countries to proceed on their near-term CO2 reduction plans.

Many thanks to the authors for their invaluable contribu-tions. We invite EM readers to explore this issue and notethe varying approaches to the most challenging air pollutioncontrol issue of our lifetimes. em

Gary M. Bramble is an A&WMA Fellow and a member of the EM Editorial Advisory Committee. Recently retired from a long environmentalcareer in the electric utility and forest products industries, his perspectives were also shaped by four years with the Ohio Environmental Protec-tion Agency and eight years of environmental consulting to a variety of industries. E-mail: [email protected].

Be sure to visit www.awma.orgregularly for the latest importantinformation from A&WMA.

Climate change is a global issue, so it is important to look at greenhouse gas

(GHG) emissions from a global perspective. This article focuses on The People’s

Republic of China, looking at China’s GHG emissions, climate change policies, and

progress toward meeting its climate goals. With a population of 1.4 billion—18.6% of

the world’s population and the highest of any nation—China is the single largest

emitter of GHGs.

China Climate ChangePolicies and Progress

View of a busy city street in the downtown area near Nanjing Road in Shanghai.

Climate Change Policies by David Heitz and Kevin Leahy




China surpassed the United States as the world’s largestemitter of GHGs around 2006. In its most recent inventory(2014) submitted to the United Nations Framework Conven-tion on Climate Change (UNFCCC), China reported totalGHG emissions of 11.185 Million Gg carbon dioxide equiv-alent (CO2e) net emissions/removals, including land use,land-use change and forestry (LULUCF). Gross GHG with-out LULUCF are 12.300 Million Gg CO2e and the net emis-sions/removals by LULUCF is -1.115 Million Gg CO2e. Ofthe gross GHG emissions, 78% came from energy and14% from industrial processes. The three largest sub-sectorsof energy are energy industries (36.3%), manufacturing andconstruction (30.8%), and transportation (7.4%). Breakingdown the GHG emissions by gas, 81.6% is CO2, 10.4% ismethane (CH4), and 6.7% is nitrous oxide (N2O).1

China has experienced tremendous growth in the last 40years. Under the UNFCCC, China is a Non-Annex I party, ora developing nation, yet has grown into the largest emitter ofGHGs. Its economy showed little growth in the 1970s, someimprovement in the 1980s and 1990s, but then skyrocketedshortly after the turn of the century. Comparing China to theUnited States: in 1971, China’s GDP was only 4% the size ofthe United States’ GDP; by 2017, China’s GDP had increasedto nearly 60% of the United States’ GDP; and by 2021, it isprojected to exceed 70%. In 2018, more than one third ofthe global growth in primary energy came from China (seeFigure 12). Because China’s economy has been based prima-rily on heavy industry and low-end manufacturing, there is astrong linkage between China’s economy and its emissionsfrom fuel combustion (see Figure 23).

China and the UNFCCCThe UNFCCC was adopted at the Rio Earth Summit in 1992.China ratified the UNFCCC in 1993 and has participated ineach year’s Conferences of the Parties (COP). China has alwaystaken the position that developed nations should provide fi-nancial and technical support to Non-Annex I parties (i.e., developing nations), who furthermore, should not be subjectto binding emissions limits under the UNFCCC. This positionwas included in the Kyoto Protocol, adopted at the third COPin 1997.

As part of the Paris climate conference (COP-21), UNFCCCParties were to submit nationally determined contributions(NDCs) for addressing climate change. China submitted itsNDCs in June 2015, in which it committed to hit peak CO2

emissions by 2030, increase non-fossil fuels in its primaryenergy mix to 20%, and lower CO2 emissions per unit ofGDP by 60–65% from 2005 levels. China ratified the ParisAgreement on September 3, 2016, in a joint ceremony withthe United States.

China has continued increasing its participation within the UNFCCC, becoming increasingly assertive and exercisingleadership, especially since the United States announced in 2017 it plans to withdraw from the Paris Agreement in November 2020. China further increased its profile and status by voluntarily matching a U.S. pledge of US$3 billion in 2015 to help other developing countries. This garnered further attention when the United States announced in 2017 itwould not pay the final US$2 billion it owed on its US$3-billioncommitment.

National PoliciesSeparate from reports and submis-sions related to the UNFCCC,much of China’s policies regardingclimate change can be found intwo sets of documents: (1) “Five-Year Plans (FYP),” which are ratifiedby the National People’s Congress(NPC); and (2) “China’s Policiesand Actions for Addressing ClimateChange,” published annually bythe National Development andReform Commission (NDRC). The“FYP” covers a variety of areas anddeals with future development forthe next five-year period, whereasthe “Policies and Actions” are specific to climate change andoften provide updates on imple-mentation of climate policies in the current FYP.

Figure 1. Contribution to primary global energy growth in 2018.2



Climate Change AchievementsWith 78% of the gross GHG emissions attributed to the en-ergy sector, evaluating progress in this area is paramount.China’s energy portfolio is becoming increasingly diversethough coal remains the dominant energy source despite aslight decline in absolute numbers in the past decade and adecrease in percentage share as renewables and nucleargain share (see Figure 34).

CoalAs much of the world looked to reduce coal consumption,China more than doubled its coal consumption between2000 and 2010. In 2018, China consumed more coal thanthe rest of the world combined.5 China has now committedto put a cap on coal use and to develop more renewable

energy and there was a decrease incoal consumption in 2014, 2015,and 2016. However, this was re-versed in 2017 and 2018, withsmall increases in coal use.

China is striving to replace older,inefficient, and high-emitting (SO2

and NOx) power plants, which aresome of the more significant con-tributors to the country’s notori-ously bad air quality. This also helpsreduce CO2 emissions slightly asthe greater efficiency of the newerplants allows more electricity outputfor the same amount of fuel con-sumed. In the 13th FYP, China firstestablished a mandatory 2020 tar-get of reducing the share of coalconsumption to 58% of nationalenergy consumption from the his-torical levels of 67–76% in previ-ous decades.6 However, at thesame time, China is attracting un-wanted criticism as it exports newand retired coal plants to develop-ing countries, thereby directly con-tributing to increasing global CO2

emissions even if its own emissions decrease.7

Renewable EnergyChina supports renewable energy,as evidenced by the 13th FYP re-leased in December 2016, whichcalled to increase the percentage ofnon-fossil energy in primary energyconsumption to 15% by 2020 and20% by 2030. Perhaps as a sign ofgrowing confidence in its ability tomeet these goals, the plan was re-

cently revised upward to 35% by 2030.8 Table 1 showsChina’s capacities in renewable energy.9

Nuclear EnergyChina has the third highest nuclear capacity in the world,trailing only the United States and France. From 2013 to2018, China opened 29 nuclear power plants. In 2018,seven of the nine nuclear power plants in the world thatconnected to the grid for the first time were in China androughly 20% of the nuclear power plants under constructionin the world today are in China.10 As of June 2019, Chinahad 46 operational reactors and another 11 under construc-tion. Despite these impressive gains, nuclear power still only provides approximately 4% of China’s electricity. Thecountry plans to deploy up to 150 GW of nuclear power

Figure 2. China’s GDP and GHG emissions from fuel combustion.3

Figure 3. Annual energy consumption per capita in China.4



generation by 2050, far exceeding current U.S. capacity of99 GW.11

Carbon TradingAt least in the eyes of climate policy experts around theworld, one of the most significant moves by China in thepast decade has been the implementation of a domesticCO2 emissions trading market. Efforts began with pilot programs in eight cities and provinces. In December 2017, NDRC released a plan with three phases. Power sector entities emitting more than 26,000 tons per year ofCO2 would be required to participate in the plan. These entities emit approximately 3 Gt per year. This would bethe largest carbon trading market in the world, compared to the European Union’s market of approximately 1.7 Gt per year of CO2.12 While the initial pricing at US$7/ton was modest, a ratcheting up of price each year, as well as a lowering of the cap over time is expected to significantlyreduce emissions. Global policy experts have been especiallyintrigued by the new Chinese carbon market as it opens the possibility of eventually linking with other CO2 markets,which would significantly reduce the total costs of anemerging global climate policy.

TransportationChina’s government has several initiatives intended to reduce the GHG emissions from the transportation sector.Beginning in 2005, all new passenger vehicles were to meetfuel efficiency standards based on weight, and these standards have significantly tightened over the years. Also,vehicle manufacturers must achieve corporate average fuelconsumption (CAFC) targets, which apply to their vehiclefleet as a whole. Gains in fuel efficiency and CAFC targets,however, have had little impact on oil consumption by thecountry due to the tremendous growth in automotive salesin the past 20 years. CO2 emissions from transportationhave subsequently increased from 370 million tons in 2004to 881 million tons in 2017.13 Table 2 shows fuel economyrates in select major car markets.14

In 2017, China announced electric, fuel-celled and plug-inhybrid vehicles would account for at least 20% of the country’s total vehicle sales by 2025. In 2018, 1.1 millionelectric vehicles (EVs) were purchased in China, compared to 358,000 in the United States. Of the 425,000 electricbuses deployed worldwide in 2018, 421,000 were in China, compared to only 300 in the United States.15 Increases have

Added in 2018 China at the end of 2018

Renewable World China China Portion Capacity Portion of Power Total (GW) Total (GW) of World Total (%) (GW) World Total (%)

PV Solar 100 45 45 176 35

Wind Power 51 21.1 41 210 36

Hydropower 20 7.0 35 322 28

Total Renewable* 727 31

Table 1. China’s renewable energy generating capacity.9

*Notes: Total renewable power capacity includes bio-power, geothermal power, hydropower, ocean power, solar PV, concentrating solar thermal power, and wind power.

Country New Light-Duty CO2 Emissions Average Fuel Vehicle Registrations (g CO2/km, WLTP) Consumption (L/100 km, WLTP*)

2005 2017 2005 2017 2005 2017

China 3,738 25,565 201 175 8.7 7.6

India 1,159 3,423 159 135 6.8 5.6

Russia 1,633 1,562 219 192 9.3 8.2

USA 16,105 16,341 258 198 11.1 8.6

Table 2. Fuel economy in select major car markets.14

*Notes: A common international basis for expressing fuel efficiency is liters of gasoline-equivalent per 100 km (WLTP).Using this metric, lower numbers indicate better performance.



been promoted by the Chinese government through subsidiesand tax exemptions that are now being phased out. As Chinaaccelerates production of EVs, it is also leading in the produc-tion of EV batteries, controlling 70% of the global market.

SummaryChina is a populous country with diverse geography andcomplex climate change issues. The power sector has seensignificant improvement in recent years, though much re-mains to be done as it leads the rest of the world in coalconsumption. It may be that as the country’s cap-and-tradeprogram tightens over time, the world will see significant re-ductions from this sector. China should also be recognizedfor its leadership in advancing renewable and nuclear en-ergy. At the same time, the country has opened itself to in-ternational criticism as it continues to export and financiallysupport equipment for coal-fired power plant developmentoverseas, thereby possibly negating the improvements it has

made in its own emissions now and in the coming decades.

Some observers believe that China will meet its goal ofpeaking CO2 emissions by 2030. But from a global perspec-tive, it is clear that China, as the largest emitter of GHGsworldwide, will need to do significantly more if the world isto achieve the long-term temperature goals of the ParisAgreement (well below 2 oC rise).

This article was written during the COVID-19 pandemic.Data and references are generally from the period beforethe beginning of the pandemic. With economies worldwidebeing negatively impacted by the pandemic, global GHGemissions dropped 17% in April 2020, compared to 2019(this level last seen in 2006).16 Over time, a “new normal”will emerge, as economies reset, and policies evolve. Timewill tell what effect, if any, this new normal will have onGHG emissions and climate change. em

References1. United Nations Framework Convention on Climate Change; Greenhouse Gas Inventory Data – Detailed data by Party Data Interface; https://di.unfccc.int/

detailed_data_by_party.2. Statistical Review of the World Energy, 68th edition; BP, 2019, p. 3.3. CO2 Emissions from Fuel Combustion 2019 Highlights; International Energy Agency (IEA), 2019; https://webstore.iea.org/Content/Images/uploaded/

CO2Highlights2019-Excel%20file.XLS.4. Friedlingstein, P., et al. Global Carbon Project (2019) Carbon budget and trends 2019, December 2019; http://folk.uio.no/roberan/img/GCB2019/

PDF/ctry/s22_EnergyLines_wBio_CHN_EJ_percapita.pdf.5. Statistical Review of the World Energy, 68th edition; BP, 2019, p.45.6. Lin, A. “Understanding China’s New Mandatory 58% Coal Cap Target,” NRDC Expert Blog, March 17, 2017; https://www.nrdc.org/experts/alvin-lin/

understanding-chinas-new-mandatory-58-coal-cap-target.7. Inskeep, S.; Westerman, A. Why Is China Placing A Global Bet On Coal?; NPR.org, April 29, 2019; https://www.npr.org/2019/04/29/716347646/

why-is-china-placing-a-global-bet-on-coal.8. Bloomberg News Editors; China Sets New Renewables Target; Renewable Energy World, September 26, 2018; https://www.renewableenergyworld.com/

2018/09/26/china-sets-new-renewables-target-of-35-percent-by-2030/.9. Global Status Report 2019; commissioned by REN21; reference tables; https://www.ren21.net/gsr-2019/tables/overview/overview/.10. Sandalow, D. Guide to Chinese Climate Policy 2019; Columbia SIPA Center on Global Energy Policy, September 2019, p. 76.11. Center for Strategic and International Studies (CSIS); www.CSIS.org.12. Sandalow, D. Guide to Chinese Climate Policy 2019; Columbia SIPA Center on Global Energy Policy, September 2019, p. 50.13. China–Countries; International Energy Agency, 2019; https://www.iea.org/countries/china.14. Fuel Economy in Major Car Markets, Technology and Policy Drivers, 2005–2017, International Energy Agency, 2019; https://www.iea.org/reports/fuel-

economy-in-major-car-markets#country-database.15. Eckhouse, B. The U.S. Has a Fleet of 300 Electric Buses. China Has 421,000; Bloomberg, May 15, 2019; https://www.bloomberg.com/news/articles/

2019-05-15/in-shift-to-electric-bus-it-s-china-ahead-of-u-s-421-000-to-300. 16. Quéré C.L.; Jackson, R.B.; Jones, M.W., et al. Temporary reduction in daily global CO2 emissions during the COVID-19 forced confinement; Nature Climate

Change, May 19, 2020; https://www.nature.com/articles/s41558-020-0797-x.

David Heitz is a project manager with TRC Companies Inc. in Cincinnati, OH. Heitz specializes in the field of air quality, includingwork in conducting greenhouse gas (GHG) inventories, GHG reporting, renewable energy, and renewable fuel. He also serves onTRC’s Sustainability Team. E-mail: [email protected].

Senior review was provided by Kevin S. Leahy, a senior leader in Energy and Environmental Policy for Duke Energy until his retire-ment in 2018. He has extensive experience with climate policy, clean energy standards, and low carbon policies, such as renewableenergy, energy efficiency, and advanced nuclear. He also served as an expert reviewer for the IPCC WGIII Fifth Assessment Report. E-mail: [email protected].

This article describes the environmental legislative actions of the Government of India,

with an emphasis on climate policies, established climate targets, and the ongoing

initiatives to help meet them.

Climate ResilientIndia

India is the fifth largest economy in the world and the fourth largest carbon dioxide emitter.Photo by Muthazhagu Palanisamy.


Climate Resilient India by Keerthi Palanisamy and S. Rao Chitikela


Framework Convention on Climate Change (UNFCCC).

Climate Change ActionIndia has consistently shown leadership on climate policy action(s) since the early 2000s. The launch of the Interna-tional Solar Alliance at the United Nations Climate ChangeConference (UNCCC) in Paris (2015), and the Coalition forDisaster Resilient Infrastructure (CDRI) at the recent UnitedNation Climate Action Summit (UNCAS) in New York(2019), demonstrate India’s active role on climate initiatives.

Greenhouse Gas (GHG) EmissionsIndia is the fourth largest carbon dioxide (CO2) emitter, afterChina, the United States, and the European Union, as of2014.1 The total GHG emissions of India are approximately,2,306 million metric tons of CO2 equivalent (CO2e), includ-ing land use, land-use change and forestry (LULUCF). Thetotal GHG emissions excluding LULUCF are approximately,2,607 million metric tons of CO2e, of which 73.2% of theemissions are contributed by fossil fuel-fired combustionfrom energy and manufacturing industries, transport, and related subsectors; 16% by agriculture through enteric fermentation, agricultural soils, and rice cultivation; 7.8% byindustrial processes and product use (IPPU) mostly compris-ing of mineral, chemical, and metal industries; and 3% bysolid waste disposal sites and handling of wastewater.2

India has a long-term goal of its per-capita emissions neverto exceed those of the developed countries and to be aminor per capita emitter through 2030. Figure 1 shows themetric tons of CO2 emissions per capita recorded between1960 and 2014 for select countries, including the UnitedStates, Germany, and Brazil, Russia, India, China, and SouthAfrica (collectively referred to as BRICS, nations of theemerging economies).3 As shown in Figure 1, India main-tained its CO2 emissions lower than one metric ton per

India is the fifth largest economy in the world. Industrialgrowth, gross domestic potential increase, rapid improve-ments toward clean air and water, waste management, re-silient infrastructure, public health management, per-capitaenergy demand management, and poverty eradication aresome of the focus areas of development pursued by theGovernment of India. India’s proposed 2020–2021 financialbudget focuses on three themes—Aspirational India, Eco-nomic Development For All, and A Caring Society—thatwork toward a clean environment and meeting the nation’sclimate change control commitments.

Environmental LegislationIndia has a rich history of environmental legislation, policy,and associated regulatory undertaking. Since the successfulattendance of the United Nations Conference on HumanEnvironment held in Stockholm (Sweden) in 1972, Indiapromulgated the Water (Prevention and Control of Pollution) Act (1974), the Water (Prevention and Control of Pollution)Cess Act (1977), and the Air (Prevention and Control of Pol-lution) Act (1981) within a decade. Following this, India en-acted The Environment (Protection) Act (1986) to holisticallyaddress and implement prevention, control, and abatementof environmental pollution.

The National Environment Policy (NEP) was developed in2006 to extend the coverage of existing policies and reviewthem from a sustainable development standpoint. The NEPdetails regulatory reform; programs and projects for environ-mental conservation; and economic initiatives, includingfocus areas for research and development, capacity building;and international cooperation. The NEP specifically addresses the issue of climate change and suggests a seriesof pivotal response measures, including voluntary partner-ship with other countries to collaboratively address climatechange consistent with provisions of the United Nations


Figure 1. Select countries and CO2 emissions per capita.



capita until 2003. Since 2014, India has shown its highestrecorded per-capita emissions of 1.73 metric tons of CO2,emitting approximately one nineth of the largest emitter,United States, which is recorded to generate 16.50 metrictons of CO2 emissions per capita.

Climate Policies India’s vulnerability to climate change is reflected in the con-sistent changes to annual monsoon timeframes, melting ofHimalayan glaciers, increased frequency of flooding due toshort-durational and significantly high rainfall/precipitationevents, to name a few. India began its adaptation to climateresiliency policies in the early 2000s, when it first supporteda joint declaration on the significance of global warming atthe 2002 UNFCCC.

In June 2008, India published its first National Action Planon Climate Change (NAPCC), encompassing measures forclimate protection and adaptation, through eight nationalmission priorities:

1. Solar 2. Enhanced Energy Efficiency 3. Sustainable Habitat 4. Water 5. Sustaining the Himalayan Ecosystem 6. Green India 7. Sustainable Agriculture 8. Strategic Knowledge for Climate Change

India also adopted 24 initiatives, encompassing science andresearch, policy development and implementation, interna-tional cooperation, and forestry, to achieve a low-carbonstrategy in all sectors per its Post-Copenhagen Domestic Actions (CDA; 2009) commitment toward reducing GHGsby 20–25% from 2005 levels.

States and Union Territories of India have formulated theState Action Plan on Climate Change (SAPCC) to main-stream climate change challenges in their planning process.The following policies and strategies are in effect supportingthe NAPCC and the SAPCC:4,5

• Bharat Stage (BS) VI Emission Standards (2020), promoting stringent standards on mobile (vehicular) source emissions;• National Wind-Solar Hybrid Policy (2018), promoting grid-connected wind–solar hybrid systems for efficient utilization of transmission infrastructure;• National Policy for Farmers (2007), fostering sustainable agriculture;• Integrated Energy Policy (2006), providing energy policy recommendations that address adverse environmental impacts and security concerns;• National Electricity Policy (2005), focusing on globalizing access to electricity and promoting renewable energy resources;• Energy Conservation Act (2001), supporting energy efficiency; and

• Several mechanisms geared toward energy efficiency and emissions reduction, such as the Clean Development Mechanism (2006), the Perform, Achieve, Trade Scheme (PAT; 2011), and the Zero Defect Zero Effect Model (2016).

Climate TargetsIn 2015, at the UNFCCC COP-21 held in Paris, India made abold commitment as part of its nationally determined contribu-tions (NDCs) to reduce GHG emissions 33–35% (2005 levels)by 2030, by meeting 40% of total energy demand with non-fossil fuel sources and increasing forest cover to 33% from the24% increase as measured in 2013. India set other non-quan-tified goals, such as establishing a sustainable way of living, in-creasing investments at developing the sectors susceptible toclimate change, channeling funds from developed countries tomitigation actions, and joint collaborative research and devel-opment for climate resilient technologies.

Ongoing Initiatives and Accomplishments India’s GHG emissions is estimated to increase with the nation’s economic growth. The Indian government is investingin low-carbon growth strategies that can help break this pat-tern and enable the country to keep on course with its climateaction commitments through 2030. India is aligned to achieveits NDC goals of meeting 40% energy demand through non-fossil fuel resources and reducing GHG emission intensityahead of schedule. With the rapid economic growth and increasing population (1.353 billion in 2018), current policiesare geared toward expanding non-fossil generation capacitythrough wind and solar energy to cater to this fast-growingelectricity market. Solar power generation has increased by65% during the period 2014–2019, and non-fossil fuelpower generation has reached 37%, which places India aheadof schedule in achieving its NDC target of 40% by 2030.

In the industry sector, one of the many ways India sets toachieve energy efficiency is through the PAT mechanism,whereby participating facilities are assigned energy savingstarget and the facilities that exceed their targets sell their energy savings certificates (ESCerts) to facilities that did not,much similar to an emissions’ banking and trading scheme.Similarly, small and medium-size industries follow severalnew market-based emission reduction mechanisms.

Considering that more than 50% of India’s population relies onagriculture, the government has taken measures to curb in-competent power distribution and use of inefficient pump sys-tems and equipment, via disbursing funds to farmers forinfrastructure development, and promoting solar-based powergrid and pumps.

Policy ProjectionsThe initiatives designed to strengthen India’s renewable energy capacity and the current trend of falling renewableenergy prices indicate that India is aligned to achieve itsgoals of meeting 40% energy demand through non-fossilfuel resources and reducing GHG emission intensity ahead



of schedule. Additionally, the Government of India is consid-ering plans to increase its capacity target for renewablesfrom 175 Gigawatt (GW) to 450 GW by 2030.

Furthermore, India, as part of its NDC, has signed on to be “2 °C compatible” by 2030 as per the Copenhagen Agree-ment (2009); however, compatibility with the Paris Agreementis to be reviewed, based on further progress with the ongoingNAPCC. In support of this commitment, during the 2020–2021 budget speech,6 India’s Finance Minister, The HonorableNirmala Sitharaman stated, “India submitted its Nationally Determined Contribution, under the Paris Agreement in 2015on a ‘best effort’ basis, keeping in mind the development im-perative of the country. Its implementation effectively beginson 1st January 2021. Our commitments as action will be executed in various sectors by the Departments/Ministries concerned through the normal budgeting process.”

It will be important to watch for post-COVID-19 economicactions of nations and implications on the collective effort incontrol of global warming in the near future.

SummaryIndia is an environmentally sustainable economy that realizesits vulnerability to climate change and the critical need for en-vironmental protection and emissions control. India’s commit-ment toward climate response has led several legislative andpolicy actions, associated stringent regulatory standards and compliance mechanisms to be put into effect since the seven-ties. The proposals made by India for making progress on theglobal climate change agenda are constructive and tie into itsother key objectives of economic development and povertyeradication.7 With this continued momentum, the nation iswell on its path to realize its climate policy objectives of mitiga-tion and adaptation, becoming a climate resilient India. em

References1. Global Greenhouse Gas Emissions Data; U.S. Environmental Protection Agency. See https://www.epa.gov/ghgemissions/global-greenhouse-gas-emissions-

data (accessed March 26, 2020).2. Technical analysis of the second biennial update report of India submitted on December 31, 2018. See https://undocs.org/FCCC/SBI/ICA/2019/TASR.2/IND

(accessed March 26, 2020). 3. Carbon dioxide emissions (metric tons per capita); The world Bank. See https://data.worldbank.org/indicator/EN.ATM.CO2E.PC (accessed March 29, 2020). 4. National Portal of India. See https://www.india.gov.in/topics/environment-forest (accessed March 25, 2020). 5. Climate policy database: Data & Statistics; International Energy Agency. See https://www.iea.org/policies?country=India&topic=Energy Efficiency&page=2

(accessed March 26, 2020). 6. India Ministry of Finance, 2020. See https://www.finmin.nic.in/ (accessed March 12, 2020). 7. Sustainable Development Goals; Sustainable Development knowledge Platform, United Nations.See https://sustainabledevelopment.un.org/?menu=

1300 (accessed March 31, 2020).

Keerthi Palanisamy, EIT, is an environmental engineer based in Cincinnati, OH, and Dr. Rao Chitikela, P.E., P.Eng., BCEE, is anindependent consultant providing water infrastructure, energy, and environmental services at RC-WEE Solutions in Dublin, OH. E-mail: [email protected]; [email protected].

Now in its 38th year, this conference provides a forum for the discussion of state-of-the-art technical information, regulations, and public policy on thermal treatment technologies and their relationship to air emissions, greenhouse gases, and climate change. Sessions will focus on technology advances, regulatory issues, waste-to-energy applications, greenhouse gas inventories, residuals treatment, climate change, and related topics including how these a�ect public perception and developing governmental policies.

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Pennsylvania’sClimate Policy RoadmapPennsylvania’sClimate Policy RoadmapA look at the groups and strategies that are helping shape Pennsylvania’s climate future.


PA Climate Policy Roadmap by Megan Uhler



Pennsylvania ranks as one of the top five energy-producingstates in the nation, and yet is simultaneously proactivewhen it comes to promoting clean energy generation, reduc-ing energy consumption, achieving phased greenhouse gas(GHG) reduction goals, and encouraging the adoption of climate change adaptation and reduction strategies acrossmultiple sectors. In this article, we will discuss the various fac-tions at the state level that are shaping Pennsylvania’s climatefuture and the formal actions that have been taken to dateby those parties; the Pennsylvania Climate Action Plan andthe state’s GHG emissions reduction goals; the eight sectorswithin Pennsylvania that are currently targeted within the Climate Action Plan as contributing to the state’s GHG emis-sions profile, and the various strategies and actions (bothsector-specific and cross-cutting) those sectors are encour-aged to take to reduce the state’s overall GHG emissions;and the role of the regulated and voluntary carbon marketswith respect to Pennsylvania facilities.

Legislative HistoryPennsylvania Alternative Energy Portfolio StandardsAct (Act 213)In 2004, the state’s first clean energy target was establishedwhen the Pennsylvania Alternative Energy Portfolio Standards Act (Act 213; www.legis.state.pa.us/cfdocs/legis/li/uconsCheck.cfm?yr=2004&sessInd=0&act=213>)was signed into law. Act 213 requires that 18% percent ofthe electricity supplied by Pennsylvania’s electric distributioncompanies (EDCs) and electric generation suppliers (EGSs)come from alternative energy resources by 2021. Althoughinnovative at its inception, Act 213 has proved to be achiev-able over time by the state’s EDCs and EGSs, and state law-makers are looking for more aggressive clean energy targetsmoving forward—as evidenced by PA Senator Jay Costa’sSeptember 2019 proposed “Climate Change Mitigation andEnergy Transition Act” (Senate Bill 15).

Pennsylvania’s Energy Efficiency Law (Act 129)In 2008, the state’s first energy consumption reduction tar-gets were established when Act 129 (www.legis.state.pa.us/cfdocs/legis/li/uconsCheck.cfm?yr=2008&sessInd=0&act=129) was signed into law. Act 129 requires that the Pennsyl-vania Public Utility Commission (PUC) reduce energy con-sumption and peak electric demand through a three-phaseprocess implemented during the period June 1, 2009through May 31, 2021. To fulfill Act 129, the PUC has re-quired the state’s seven largest EDCs to develop, adopt, andimplement energy efficiency and conservation (EE&C) plansand to reduce the amount of electricity consumed by cus-tomers in their service areas. All seven EDCs have met theirmandated energy consumption reduction and demand re-duction targets during Phase I and Phase II of Act 129.Phase III of Act 129 began on June 1, 2016 and will end onMay 31, 2021.

Pennsylvania Climate Change Act (Act 70)Also in 2008, the Pennsylvania Climate Change Act (Act 70;www.legis.state.pa.us/cfdocs/legis/li/uconsCheck.cfm?yr=201

4&sessInd=0&act=70) was also signed into law. Act 70 requires the PA Department of Environmental Protection(PADEP) to prepare a Climate Action Plan and update itevery three years, establish a council that advises PADEP onimplementing Act 70, develop an annual state-wide inven-tory of GHG emissions, and establish a voluntary registry ofGHG emissions for the state. The Pennsylvania ClimateChange Advisory Council (CCAC) was established pursuantto Section 5 of Act 70. The CCAC consists of 21 membersand reflects a diversity of viewpoints on climate change is-sues from the scientific, business and industry, transporta-tion, environmental, social, outdoor, and sporting, labor andother affected communities. Eighteen of the CCAC mem-bers are appointed by either the Governor, Senate, orHouse. Additionally, the Secretary of the Department ofConservation and Natural Resources, the Secretary of Com-munity and Economic Development, and the Chair of thePennsylvania Public Utility Commission (or their designees)serve as ex officio members to the CCAC.

Act 70 required PADEP to establish a voluntary registry ofGHG emissions for the state. The Climate Registry (TCR;www.theclimateregistry.org>)—a non-profit organization governed by multiple U.S. states and Canadian provincesand territories—plays a role in this process by serving as theregistry where Pennsylvania facilities voluntarily measure, report, and verify their carbon dioxide equivalent (CO2e)emissions and reductions. PADEP Secretary Patrick McDonnell currently serves on the TCR Board of Directors.

Executive Order 2019-01On January 8, 2019, Pennsylvania Governor Tom Wolfsigned Executive Order 2019-01, Commonwealth Leader-ship in Addressing Climate Change and Promoting EnergyConservation and Sustainable Governance (www.governor.pa.gov/newsroom/executive-order-2019-01-commonwealth-leadership-in-addressing-climate-change-and-promoting-en-ergy-conservation-and-sustainable-governance/), committingPennsylvania to reducing its net GHG emissions by 26% by2025 from 2005 levels and to further reduce the state’s netGHG emissions by 80% by 2050. Executive Order 2019-01also established energy consumption performance goals forPennsylvania state’s agencies, required the replacement of asubset of the state’s passenger car fleet with battery electricand plug-in electric hybrid cars by 2025, and required theprocurement of renewable energy to offset at least 40% ofthe state’s annual electricity use. Executive Order 2019-01also established the Green Government (GreenGov) Council,which consists of the Secretaries of the Departments of Gen-eral Services, Environmental Protection, and Conservationand Natural Resources and others appointed by these mem-bers, to serve as a central coordinating body in implementingExecutive Order 2019-01.

Pennsylvania Climate Action PlanThe fourth iteration of the Pennsylvania Climate Action Plan (www.depgreenport.state.pa.us/elibrary/GetDocument?docId=1454161&DocName=2018%20PA%20CLIMATE


and costs of doing so, and makes distinctions between in-dustry-specific recommended actions when applicable. Thecost-effectiveness of each strategy is categorized in terms ofnet present value, cost per ton of CO2e, and relevant macro-economic factors (i.e., the impacts on employment, grossstate product, and personal disposable income for common-wealth residents). The published proportions of GHG emis-sions contributed per sector were determined by PADEPaccording to the U.S. Environmental Protection Agency’sInventory of U.S. Greenhouse Gas Emissions and Sinks:1990-2017 (www.epa.gov/sites/production/files/2020-04/documents/us-ghg-inventory-2020-main-text.pdf) (published2019), which is in turn informed by data reported by individual facilities under 40 CFR Part 98 (the MandatoryGHG Reporting Rule).

Leadership opportunities exist for all businesses within thestate to support PA’s emissions reduction goals and adoptstrategies and actions recommended for their sector withinthe Pennsylvania Climate Action Plan. The projects thatachieve GHG emissions reduction goals often have theadded benefit of positive financial return through the generation of CO2e offsets.

Executive Order 2019-07On October 3, 2019, Governor Tom Wolf continued tobuild upon Pennsylvania’s evolving climate goals by signingExecutive Order 2019-07- Commonwealth Leadership inAddressing Climate Change through Electric Sector Emissions Reductions (www.governor.pa.gov/newsroom/executive-order-2019-07-commonwealth-leadership-in-addressing-climate-change-through-electric-sector-emissions-reductions/). Executive Order 2019-07 requires that by nolater July 31, 2020, a rulemaking package be presented to


%20ACTION%20PLAN.PDF%20%20%20%3cspan%20style%3D%22color:blue%3b%22%3e%28NEW%29%3c/span%3e) was published by PADEP in April 2019, with inputand feedback from the CCAC and other stakeholders. Atthe same time, Governor Wolf announced Pennsylvania’smembership in the U.S. Climate Alliance, which serves toimplement strategies that advance the goals of the ParisAgreement, by reducing GHG emissions by at least 26–28% below 2005 levels by 2025. Accordingly, the state’snet GHG emissions reduction goals from Executive Order2019-01 are documented within the plan.

The following eight sectors are identified within the plan asbeing most impactful from a GHG emissions reduction perspective in Pennsylvania:

1. Energy Consumption2. Energy Production3. Agriculture4. Ecosystems and Forestry5. Outdoor Recreation and Tourism6. Waste Management7. Water Resources8. Human Health

Each sector is expanded upon within the plan in terms of itsrelevance within Pennsylvania, its vulnerabilities with respectto climate change, and the opportunities the sector mustadapt and reduce emissions by adopting one or more of thestated strategies (see “PA Climate Strategies” below).

The PA climate plan expands upon the sector-specific actionsthat citizens and businesses can take, respectively, to supporteach of the listed strategies, discusses the associated benefits

PA Climate Strategies• Increase end use energy conservation and efficiency.• Implement sustainable transportation planning and practices.• Develop, promote, and use financing options to encourage energy efficiency.• Increase use of clean, distributed electricity generation resources.• Create a diverse portfolio of clean, utility-scale electricity generation.• Reduce impacts of fossil fuel energy production and distribution.• Increase production and use of alternative fuel.• Use agricultural best practices.• Provide resources and technical assistance to farmers to adapt.• Protect ecosystem resilience, including forest systems where species will shift.• Monitor, identify, and address ecosystem vulnerabilities.• Help the outdoor tourism industry manage shifting climate patterns.• Reduce and use waste sent to landfills.• Use stormwater best management practices.• Promote integrated water resources management and water conservation.• Improve reliability and accessibility of public information about climate-related health risks.• Bolster emergency preparedness and response.• Lead by example in commonwealth and local government practices and assets.• Incorporate historical and projected climate conditions into siting and design decisions for long-term infrastructure.



the Pennsylvania Environmental Quality Board (EQB) that establishes a CO2 budget for Pennsylvania fossil-fuel-firedelectric power generators, that is at least as stringent as thebudget established in other states participating in theRegional Greenhouse Gas Initiative (RGGI), and requires the PADEP and PUC to engage with PJM Interconnection (a regional transmission organization) to promote integrationof the program in a manner that preserves orderly and competitive economic dispatch within PJM, while minimizingemissions leakage.

A preliminary draft (http://files.dep.state.pa.us/Air/AirQual-ity/AQPortalFiles/Advisory Committees/Air Quality TechnicalAdvisory Committee/2020/2-13-20/Draft PRN CO2 BudgetTrading Annex A 1-30-20.pdf) of the proposed CO2 BudgetTrading Program became initially available for review onFebruary 13, 2020. The preliminary draft rule (if finalized as proposed) would apply to 49 fossil-fuel power plants,10 waste coal plants in Pennsylvania, and could also apply to any facility (including, but not limited to, an EGU) that isfossil fuel-fired, has a minimum nameplate capacity of 25megawatt (MW), and transmits power to the grid. Includedin the draft are proposed waste coal set asides unique toPennsylvania and intended to protect the state’s uniquewaste coal industry. However, the draft provisions relating towaste coal set asides are already undergoing scrutiny due toquestions over the environmental benefits of waste coal fuel,and the concern that the allowance market could eventuallybe flooded—and allowances devalued—should waste coalemission rates decrease.

The state’s emissions budget was not included in the February 13 draft, but instead presented by PADEP during aspecial April 23, 2020 meeting with the Air Quality Techni-cal Advisory Committee and the Citizen’s Advisory Council.On May 7, 2020, neither the Air Quality Technical AdvisoryCommittee or the Citizen’s Advisory Council voted in favorof PADEP taking the rule to the EQB for formal rulemaking,with concern expressed that projected modeling shows fu-ture leakage despite Pennsylvania’s history of proactively pre-venting leakage for other states, no change in the proportionof renewables within Pennsylvania’s future generation portfo-lio, with minimal decreases in GHG emissions that somespeculate would happen with or without the proposed rulein place. Despite the May 7, 2020, voting results, it is still anticipated that the formal proposed draft will be presentedby PADEP to EQB by July 31, 2020. If the proposed rule is finalized as proposed, the fossil fuel-fired power sectorwould be the first sector within Pennsylvania to be subject to a regulated carbon market.

ConclusionPennsylvania serves as an important example to those energy producing states that may be less proactive in promoting clean energy generation, reducing energy consumption, and defining phased GHG reduction goals.Pennsylvania has demonstrated over time that it canimplement innovative climate policy that does not strictlyregulate but also empowers the private sector to in turndemonstrate climate leadership, while still retaining its position as a powerful energy producing state. em

Megan Uhler is a consulting scientist with ALL4 LLC. E-mail: [email protected].

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An overview of Oklahoma’s climate change awareness and mitigation efforts.

Understanding and NavigatingClimate Change Philosophy

in Oklahoma


Climate Change Philosophy in Oklahoma by Ken Senour



Formal climate change policies in Oklahoma generally donot exist. Climate change awareness is increasing at certainlevels in the state, but commonly without formal acknowl-edgement. Mitigation efforts exist in several sectors. It is incumbent, therefore, to examine policies, awareness, andpotential mitigation.

Oklahoma is near the geographic center of the UnitedStates and is where all things seem to meet. Located in theSouthern Great Plans, Oklahoma is dramatically landlocked,the target of the dust bowl, and generally wind-swept. Overthe years, mountainous areas surrounding the state, includ-ing Colorado and Arkansas, have dispatched unwanted ma-terial—mud, gravel, clay, and sand—to Oklahoma, whichhave defined the physical geography of the state.

The state hosts large reservoirs of oil and gas provided bythe cauldron of materials left behind by previous geologiceras and the surrounding landscapes. Because of the oil andgas extraction industry,it has become one of the wealthiestplaces on the planet.1

Understanding the climate change mindset in Oklahoma isrelevant. This mindset affects activities undertaken by gov-ernments and industry to address awareness, be preparedfor various events, and mitigate impacts.

Climate PolicyState agencies were identified to obtain their thoughts re-garding climate change policy, including the OklahomaWater Resources Board, the office of the Secretary of Energyand Environment, and the Oklahoma Climatological Survey.Results from this research are included below.

Oklahoma Water Resources BoardThe state’s water resources agency does not have a formalstatement on climate change. The 2012 Oklahoma Compre-hensive Water Plan2 does address climate. It notes that cli-mate change is projected to continue to impact the watercycle across the United States, including the total amount ofannual precipitation, frequency, and intensity of the precipi-tation, and location of precipitation. Recommendationsidenxtified in the referenced study include:

• Oklahoma should assess trends in moisture and temperature using spatial and temporal scales—the state is subjected to severe drought, river floods, flash floods, significant ice storms, and an occasional blizzard;• Oklahoma should provide predictive water management tools; and• Oklahoma should quantify and qualify its water resources.2

Secretary of Energy and EnvironmentThe office of the Secretary of Energy and Environment doesnot have an official policy or statement on climate change.

Oklahoma Climatological SurveyThe Oklahoma Climatological Survey references a recentstudy by U.S. Global Research, involving a climate assess-ment for the Southern Great Plains. That study is summa-rized below.

• The Southern Great Plains, including Oklahoma, experiences dramatic and impactful weather, including hurricanes, flooding, heat waves, and drought. Approximately 34 million people and their local community infrastructures and other systems are stressed by these events.• Adaptation to changing conditions is imperative. Operational and reliability strategies being implemented by the energy industry will be important during traumatic events.• Population could be affected by physical injury and population displacement. As the temperature increases, heat trauma and diseases transmitted through food, water, and insects will increase risk as temperatures rise.• Tribal and indigenous communities in the region (45 entities) will be subjected to economic, political, and infrastructure limitations.3

Climate Change AwarenessWeather in Oklahoma is variable, unpredictable, and can beviolent. Recent trends have reflected that weather extremesare occurring more regularly. Droughts seem to be morefrequent, longer in duration, and interspersed with floodingevents. These events can have an impact on water storage,water resources in general, wildlife, and oil and gas extrac-tion activities.4 Drought conditions in Oklahoma are moni-tored by the U.S Drought Monitor (https://www.drought.gov/drought/data-gallery/us-drought-monitor). Figures 1 and 2reflect the impact of a recent drought in Oklahoma.

In September 2019, the Oklahoma City newspaper, TheOklahoman,5 ran a series of articles regarding climatechange in the state. A review of select articles follows:

• State Reacts to Changing Climate: A drought beginning in 2010 that lasted until spring 2015 created many years of distress and suffering throughout the state. The drought caused hardship on the economy, including crop failure, loss of jobs, and tax receipts, which in turn had an adverse effect on various community activities and resources. During the drought, it was determined the City of Altus was only one year away from becoming water deficient. A comprehensive plan was prepared to address solutions to water access, sourcing, and infrastructure issues. Diversifying water sources through surface and groundwater supplies, pushing for additional water conservation methods, and crafting a drought response plan were the first steps.



Governor Stitt indicates that Oklahoma is an “innovation hub for meeting America’s energydemands of today and the future.”5

Addressing Climate ChangeThe dynamic between climate change and micro-eather/climate systems is still being studied.Addressing and implementing programs tocounter climate change concerns is occurring,whether it is acknowledged publicly or not, at alllevels of government and throughout industry.The Oklahoma Water Resources Board is enacting programs and plans to protect water resources and supplies. The Secretary of Energyand Environment is promoting renewable energythroughout the state (i.e., wind and solar).

Communities throughout the state are preparing in a variety of ways.

Recently, the City of Norman became the first community in Oklahoma to set a goal to transition to 100% renewableenergy in city buildings by 2035 and using 100% renew-able energy across the board by 2050.5 An adjacent neighbor of both Oklahoma City and Norman, the City ofMoore, has been devastated by several severe tornadoes(rated EF 4 and EF 5 on the Enhanced Fujita scale) in the last 20 years.If climate change is a possible cause of theincreased frequency and higher intensity storms, the Moorestory is a posterchild for future concern. Since those torna-does, various programs have been planned and proposedby the City of Moore. One of the primary responses hasbeen to implement wind-resistant construction. Additionally,promoting and building safe rooms and storm shelters hasoccurred.

In 2017, the city adopted a comprehensive plan, entitled theEnvision Moore Plan 2040. All major components of theplan provide “resiliency touchpoints” to be considered. Theplan addresses sustainability and resiliency and identifies aninfrastructure recovery and implementation plan (IRIP) that was prepared to further refine infrastructure-related datadescribed in the City of Moore Disaster Recovery ProgramAction Plan (Action Plan). The city is the first in the UnitedStates to adopt tornado-specific building code wind resist-ance standards.

Oklahoma’s Energy IndustryOklahoma is a major energy producing state, and formally within the state government and the energy producers, does not necessarily recognize climate change.The state landscape is densely populated with oil and gas production facilities, including refineries (five) and wells (tens of thousands). In addition, wind farms and solar panel systems are sprinkled throughout the state,mostly in the western, south-central, and north-central parts of the state.

Public climate change conversation in Oklahoma islimited. Current Oklahoma Water Resources Board Director Julie Cunningham indicated that labels andterminology are not their focus. The agency plans forthe worst: “We’re focused on helping communities bemore resilient in their planning for potential disasters,Cunningham said. We are long-term visionaries.”5

• Climate Change Tornado Link Studied: Oklahoma is in the bullseye (Tornado Alley), from a global perspective regarding tornado activity, frequency, and severity. For tornadoes, there seems to be connectivity to the climate change discussion.

Today, western Texas and Oklahoma appear to be less affected by tornadoes than in the past.

Speculation reflects there may be a shift of averagetornado development to the east, thus potentiallyimpacting communities near the Mississippi River. Climate change could also be influencing drier conditions in the region.

• Climate Change Talk Is Subtle in the State: Predictions that Oklahoma will face hotter temperatures and more extreme weather due to climate change has not created a sense of urgency relating to new policies or legislation at the state government level. In a state tied strongly to the fossil fuel industry, public support of climate change is minimal. Oklahoma has become a leader in renewable wind energy. In a recent publication, Oklahoma was identified as one of just four states that generates enough wind and solar power to cover at least 40% of the state’s electricity needs.5

Ken Wagner, Oklahoma’s Secretary of Energy and Environment, promotes that Oklahoma is rapidlyincreasing its renewable energy output without any“radical” legislative or regulatory actions.

Figure 1. Drought conditions in Cimarron County in May 2014.Photo courtesy of Gary McManus, Oklahoma Climatological Survey.



The Oil and Gas IndustryThe oil and gas industry in Oklahoma is primarily dominated byindependent operators (over 3,000).6 Oklahoma ranks as one ofthe top two locations in the world for oil and gas investment,third in the United States in natural gas production, and fourthin the United States in oil production.6 Within the state, there are63,000 natural gas wells, 114,000 oil wells, and 11,111 injec-tion/disposal wells; and there are 41,000 miles of pipeline.6

Interviews were conducted with representatives from the up-stream industry. The following statements summarizes thosediscussions:

• Climate change is neither publicly recognized nor denied by the industry;• External watchdog organizations (e.g., Sierra Club) continually monitor and apply pressure to the industry through political articles and various media outlets;• The industry is aware of the public relations ramifications regarding pollution responsibilities and controls; and

• Although not openly addressing climate change concerns, the industry is implementing various activities to control emissions, treat wastewater, reuse wastewater, and monitor activities involving air and water contamination.7

The Electric Utility IndustryThe state provides abundant electricity produc-tion opportunities through the electric utility in-dustry—power generation, wind energy, and solarenergy. The state reflects a top 20 ranking in netgeneration in the United States (73.7 gigawatthours), ranks second for installed capacity, andhas the second lowest electricity prices in theUnited States. There are eight electric utility com-panies in the state, four coal-fired power plants,

and 17 gas-fired power plants. Oklahoma has 3,984 windturbines, 8,072 MW of installed capacity, and wind accountsfor 31.83% of Oklahoma’s total energy production. Solar energy is an upward trending activity reflecting 31.2 MW ofinstalled capacity.6

Greenhouse Gas EmissionsCarbon dioxide (CO2) is one of the prime human contribu-tors to climate change. Table 1 shows sources of CO2 inOklahoma, with their accompanying emissions identified inmillion metric tons for 2017 (data released October 23,2019).8 Table 2 identifies CO2 emission trends in Oklahomafrom 2006 to 2017 (million metric tons).8,9 The data repre-sent a 16.2% reduction in CO2 emissions for the 12-yearperiod in Oklahoma. Oklahoma is considered about averagenationwide regarding CO2 reductions. CO2 represents 81%of greenhouse gases in the atmosphere. Methane comprisesabout 10% of greenhouse gas emissions. Methane comesfrom many sources, including the oil and gas industry, whichin the United States emits approximately 28% of totalmethane emissions.10

Figure 2. Dust storm in Cimarron County in January 2014.Photo courtesy of the Cimarron County Conservation District.

Commercial 2.9

Electric Power 30.7

Residential 3.3

Industrial 23.8

Transportation 32.6

TOTAL 93.3

Table 1. Sources of CO2 in Oklahoma, 2017 (million metric tons).8

2006 2007 2006 2009 2010 2011 2012 2013 2014 2015 2016 2017

111.3 110.5 113.3 107.5 107.0 108.7 106.1 104.6 105.9 102.0 97.4 93.3

Table 2. CO2 emission trends in Oklahoma, 2006–2017 (million metric tons).8,9



Final ThoughtsEnergy production is an important component of the Oklahoma economy. Oklahoma exhibits high nationalrankings regarding energy production and energy generat-ing attributes. This production contributes to the carbonfootprint, but the state also is a leader in renewable energysources that include wind power, solar power, and hydropower.Communities continue to develop plans to withstand acuteweather episodes, drought, and many other events.

Climate change is a controversial subject. Oklahoma exhibits a unique “personality” geographically, historically,and physically that complicates naturally occurring events.Within Oklahoma, publicly focused climate change conversation is limited. Addressing climate-related challengeswill be important to Oklahomans in the future regardingadaptation to changing conditions, mitigation of impacts,and resiliency. em

References1. Anderson, S. Boom Town, 2018.2. Oklahoma Water Resources Board. 2012 Oklahoma Comprehensive Water Plan Supplemental Report, Climate Issues & Recommendations. December 2010.3. U.S. Global Research Program. Fourth National Climate Assessment. Chapter 23, Southern Great Plains. 4. Wentz, J. State Impact Oklahoma. What Scientists Say a Warming Climate Might Mean for Oklahoma. December 17, 2017.5. The Oklahoman. Various Articles Addressing Climate Change. September 2019.6. Murphy, D. Oklahoma Corporation Commission Commissioner. The OCC: Taking Care of Business, OIPA/OKOGA Annual Meeting. June 14, 2019.7. Interviews with the Professionals Involved with the Oil & Gas Industry in Oklahoma. November 2019.8. U.S. Energy Information Administration. Energy-Related Carbon Dioxide Emissions by State, 2017. October 2019.9. U.S. Energy Information Administration. Energy-Related Carbon Dioxide Emissions by State, 2005-2016. February 2019.10. Overview of Greenhouse Gases; U.S. Environmental Protection Agency, 2018. See EPA.gov.

Ken Senour, CEP Emeritus, QEP, is a retired environmental/water resources/planning professional. He began his career withthe Ohio EPA and then spent 42 years in the environmental, planning, and engineering consulting industry in Oklahoma. E-mail: [email protected].

Disclaimer: The views expressed in this article are those of the author.

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

Advancements in Vapor Intrusion and Emerging Contaminant Air Quality Issues

September 23-24, 2020 • Chicago, IL

A pre-conference course will also be o�ered on September 22 on Optimizing VI Mitigation System Design.

Make your plans now to sponsor and attend. Learn more at www.awma.org/vapor.

Building o� the momentum gathered during the nine previous meetings, this year’s vapor intrusion specialty conference will bring together internationally-recognized scientists, engineers, regulators, and attorneys to share research and solutions on the latest developments in the investigation and mitigation of the vapor intrusion (VI) pathway, including indicators and tracers, toxicology, risk assessment, sampling and laboratory analysis, as well as the newly-added topic of emerging contaminants.

Technical sessions will cover:

• VI Attenuation Factors

• Innovative VI Investigative Techniques

• VI Modeling and Screening Techniques

• Vapor Intrusion Mitigation

High level panels cover these timely topics:

• The Latest Investigative Tools: Tracers and Indicators

• The Importance of Sewers as Preferential Pathways

• A Regulator’s Perspective

• All Things PFAS

A&WMA Immediate Past-President, Michele Gehring, offers keen insights into global

climate change objectives—and the potential impacts of COVID-19—obtained by being

an Official Observer at the last two United Nations Conferences of the Parties held in

Poland and Spain.

The Unpredicted Speed Bump:What Impact Will COVID-19 Have on GlobalClimate Change Objectives and Progress?

During the recent pandemic, U.S. domestic airline traffic almost came to a halt.

The Unpredicted Speed Bump: COVID-19 by Michele Gehring




As hopefully many of you already know, A&WMA wasgranted official observer status with the United NationsFramework on Climate Change (UNFCC) Conference of the Parties (COP) in 2017. This allowed us to participate atthe COP meetings in Katowice, Poland, in 2018 (COP-24),and again at the COP meetings in Madrid, Spain, in 2019(COP-25). I have had the honor of serving as one ofA&WMA’s delegates at both meetings. Despite the differences that each location brought to the meeting, both meetings were surrounded by the same aura of hopeand ambition as the conferences opened. Both were alsoconcluded with an overall feeling of “we could have donemore.” As we were gearing up to make plans for Glasgowand COP-26 this year, the dialogues regarding increasedambition and the anticipation of countries finalizing their nationally determined contributions (NDCs) were heatingup, and expectations were growing around the potential thatGlasgow provided. Then came COVID-19. I do not imaginethat this global pandemic or the magnitude of it impactcould be predicted by anyone, let alone all of the climate scientists that were trying to find a way to limit warming to1.5 or 2 °C by 2050.

As I look back on the challenges discussed at COP-25, I cannot find a climate action pathway that has not been impacted from this global pandemic. Let us look at a couplethat expressed the highest concerns over their progress atCOP-25, the impacts on that pathway from COVID-19, andthen do some pontificating about what those impacts meanto the eventual conversation we will have in Glasgow in November 2021.

TransportationBy 2050, the transport sector was aiming to achieve com-plete decarbonization through a combination of alternativeenergy vehicles, adaptation, and mitigation techniques. AtCOP-24, the transportation sector was slammed for beingbehind the eight-ball on their climate change plans. And, atCOP-25, the United Nations World Tourism Office (WTO),presented some fairly grim predictions on greenhouse gas(GHG) impacts from the sector with no modification tohabits. (Take a look back at the December 4, 2019, blogupdate from Madrid for hard data from the report;www.awma.org/blog_home.asp?display=81). Everyone atthat talk recognized that progress would only occur if thetransportation sector found significant ambition in a fairlyshort time.

Fast-forward to Spring 2020 and the COVID-19 pandemic.As of April 26, 2020, 45 of the 50 states had eitherstatewide or partial shelter-in-place orders in effect in the United States. According to The New York Times(www.nytimes.com/interactive/2020/us/coronavirus-stay-at-home-order.html), this equates to at least 316 million people in the United States that were staying home (orbeing encouraged to); that is nearly 95% of the U.S. popula-tion not taking public transportation as frequently, not making the morning or afternoon commute on a local highway, or not gearing up for the summer road trip. Withmotor vehicle emissions accounting for nearly 60% of theU.S. transportation sector emissions according to the annualGHG inventory, the impact from this should be significantover the short-term.

In addition, domestic airline travel in the United States hasnearly come to a stop. According to the Transportation andSecurity Administration (TSA; www.tsa.gov/coronavirus/passenger-throughput), the TSA screened approximately 2.5 million passengers every day in 2019; as of April 2020,that number had dropped to approximately 90,000 passengers per day. If you grab your calculator and do somequick math, you will find that is a 96% decrease in the number of people choosing to hop on an airplane in theU.S. alone. Unfortunately, that does not translate directly to a reduction in the number of flights, as some airlines mustkeep flying routes even with empty planes. I, for one, was ona flight back from Indianapolis to Washington in mid-Marchthat had a whopping two passengers on it. However, the decline has still been quite significant. According to a reportfrom Flightradar24.com (www.flightradar24.com/blog/charting-the-decline-in-air-traffic-caused-by-covid-19/) inearly April, domestic airline travel had reduced by about40%, and trans-Atlantic routes had decreased even more.

In 2018, emissions from the transportation sector repre-sented the largest portion of GHG emissions, with a total reported emission of 1,882.56 million metric tons of carbondioxide equivalents (CO2e). Approximately 10% of theseemissions originated from airlines (jet fuel and aviation gasoline). If we average that on a monthly basis, that is approximately 15.69 million metric tons of CO2e per monthfrom airline travel alone. Assuming a 40% reduction lastingat least four months, that should lead to a reduction in airline-related transportation emissions by nearly 40 millionmetric tons of CO2e in 2020.

COVID-19 Impact: India has reported that 3,000 MWof solar and wind energy products face delays as a resultof supply limitation and investment curtailment.

the United Kingdom have all reported drops in consumptionranging from 12% to 25%. Some outlets suggest that theresulting decreased revenue from energy usage will drivethe sector toward an increased use of renewables, as theycan handle small-scale production better than the larger, fossil fuel-based producers. According to a report from theUnited Nations Economic and Social Commission for Asiaand the Pacific (ESCAP), in many national grids, renewableoutputs are dispatched first, and the fossil fuel producers areused to fill the remaining demand. This means the renew-able outputs are essentially operating untethered, while thefossil fuel producers are shutting down units and requestinggovernment subsidies to stay alive.

Looking outside of existing production issues to the genera-tion of new capacity, COVID-19 is also having a significantimpact, albeit an opposite one. While production demandsare fueling the renewables market, resource shortages andfinancial liquidity concerns are restricting generation of newrenewable capacity. China, which is one of the main globalproducers of clean energy products such as solar panels,wind turbines, and batteries, has been hit hard by the coron-avirus and the slowed production of these items demon-strates that. This reduced supply has significantly haltedequipment installation and unit startup.

For example, India has reported that 3,000 megawatts ofsolar and wind energy products face delays as a result ofsupply limitation and investment curtailment. In the UnitedStates, similar trends are being seen. According to a reportfrom The New York Times (www.nytimes.com/2020/04/07/business/energy-environment/coronavirus-oil-wind-solar-energy.html), the Solar Energy Industries Association hasprojected a downgrade in growth by as much as one-thirdand predicts that approximately half of the 250,000 workersin the solar energy market could lose their jobs, even if justtemporarily, from the COVID-19 impacts on the industry.

Turning the conversation to oil production, decreased trans-portation, which I discussed earlier, has also driven a signifi-cant surplus of oil. This surplus has driven oil and gas pricesto levels I, personally, do not remember seeing at the gaspump since the early 1990s. According to the April 2020



While that short-term impact certainly is not enough to turnthe needle, I am curious to see how the periodic downfallimpacts the long-term predictions. I am also curious to seehow this “stay-at-home” mentality affects the attitude towardbusiness travel in the future. Don’t get me wrong, as an elitestatus holder with two different airlines and two differentmajor hotel chains, I do not see myself putting the suitcaseaway anytime soon—in fact, I’ll probably have it packed andready to go when this lockdown ends—but, I do think thatbusinesses will look at “essential” business travel differently.As we have been forced to replace in-person meetings withvideo conferences, will video conferences become the newnormal and the perceived “need” be recognized as a “want”more than a “need”? The report from Glasgow in 2021from the transport sector will be very interesting indeed.How much time or how many fractions of a degree will thetransportation impacts from COVID-19 have bought us?How will the trends of staying at home changed mentalitiesor driven ambition? Will this serve as the industry’s launchpad, or will it just be a speed bump in a turn that we accelerate out of?

EnergyIn the 2019 Yearbook of Global Climate Action (https://un-fccc.int/sites/default/files/resource/GCA_Yearbook2019.pdf),the Energy sector’s goal for 2050 was complete decar-bonization. However, the yearbook reported that thechanges seen were not in line with that target and statedthat ambition would be necessary to accelerate the change,or the target would not be met. Commenters suggestedthat, in some ways, the target for this sector required an almost unimaginable change over a very short period. Perhaps COVID-19 has provided just that, or perhaps eventhat is not enough.

Looking at the energy sector impacts from COVID-19, mostcountries have seen a significant fall in electricity demand.For example, the Ukraine reported an 8% decrease in elec-tricity consumption compared to the same period in 2019.This has caused them to curtail the import of electricity fromBelarus and Russia and delay planned maintenance. Theyhave also limited output from internal producers due to thesignificant surplus of electricity. Likewise, Italy, France, and

From supply chain disruptions to employee outages and decreased demand, there is no doubt that COVID-19 has and will have a significant impact on the industrial sector.



Oil Market Report (www.iea.org/reports/oil-market-report-april-2020) from the International Energy Agency (IEA),global oil demand is expected to fall by 9.3 million barrelsper day this year. The lessened demand is leading to less-ened production, which, in turn will likely impact globalemissions not only from the reduced consumption of oil, butthe reduced operation of the refineries that produce it.

The myriad of sector impacts is interesting and ultimatelymakes it hard to predict where the needle will fall on the energy sector. Will the increased reliance on renewablesdrive the market towards a change at a faster rate thanwould have happened without COVID-19? Will the impacton emissions from decreased oil production have a signifi-cant impact? Or, will the suspension or slowing of renew-ables projects slow the progress that was being seen inrenewable capacity throughout the world?

IndustryDuring COP-25, the report from the industry sector was oneof the most dismal, indicating that only 700 companiesworldwide had established science-based climate-related targets, and only 100 of those were in line with a 1.5 °Cpathway. There was no doubt that an exponential shift inambition was required within the energy sector to drive thechanges necessitated to meet targets. Overall, there was aunified response that industry buy-in was not evident in theclimate action arena. In fact, a representative from Danfoss, a multinational manufacturing company headquartered inDenmark, commented that the greatest roadblock to indus-trial climate action was a successful economy. He predictedthat if industry continued to sell and have profit with currentoperations, the only way to drive change will be throughregulation, which, as we know, is widely varied not only inthe United States, but worldwide.

So, how does COVID-19 alter the industry perspective?First, it is probably necessary to define what the UNFCC includes in the definition of “industry”. The industry thematicarea considers industrial activities over the entire supplychain, from extraction, through manufacturing, to the final

demand for products and services. The largest contributorsto this sector include manufacturers of cement, steel, chemi-cals, and plastics, as well as heavy-goods transport.

From supply chain disruptions to employee outages and de-creased demand, there is no doubt that COVID-19 has andwill have a significant impact on the industrial sector. The National Association of Manufacturers (NAM; www.nam.org/coronasurvey/) conducted a survey of its member companiesto ask about the impacts of the pandemic on their operations.The survey showed that 35% of its members were facing sup-ply chain disruptions, 53% anticipated a change in their opera-tions, and 78% were anticipating a financial impact. Specificconcerns were raised with reduced customer demand,inventory levels, and business continuity. IBISWorld (IBIS;www.ibisworld.com/industry-insider/coronavirus-insights/), a company that provides research reports on thousands of industries throughout the world, evaluated the impact of thepandemic to various sectors, including both mining and manu-facturing, which are some of the leading sources of industrialGHG emissions in the United States. In the mining industry,the expected slowdown on manufacturing that uses the min-ing products has already led to a decline in commodity pricesand experts expect it could also result in a significant disrup-tion in demand as well. This impact is felt across various min-ing industries, whether precious metals, oil, or gas. In the oiland gas sector, the Canadian government predicts loweringdrilling to adjust to lower demand levels, and IBIS reportedthat social distancing requirements are also leading many com-panies to shutter or close mines because they are unable toprovide the worker separation that is required.

In the manufacturing world, many manufacturing facilities either operate factories in China or rely on supplies fromChina. As a result, these facilities are all facing supply shortages, or increasing costs to manufacturing as they seek out alternative sources for supplies. In addition, employee shortages and demand curves are forcing manymanufacturing facilities to significantly curtail their operationsand lay off workers. We have all certainly seen the many advertisements from automobile manufacturers, which are

In Next Month’s Issue…The Changing View of Air ToxicsIn recent years, air pollution regulators have started to see a shift in more public attention on air toxics, those gases, aerosols or particulates that can potentially result in serious health concerns or damage to the environmentunder specific concentrations and/or exposures. With increased public interest, different areas and regions are responding in different ways, resulting in a patchwork of air thresholds and permitting requirements. This issue looks at the changing view of air toxics, and how regulations and guidance are addressing growing public attention.

institutions such as the Centre for Research on Energy and Clear Air (energyandcleanair.org/wp/wp-content/uploads/2020/05/China-air-pollution-rebound-final.pdf), that during the period that China was under lockdown, itsnitrogen oxide emissions declined by 40% and carbon dioxide emissions fell by approximately 25% over a four-week period. But we also know that as China slowly reopened its economy, those emissions started to rise backto normal levels. The European Space Agency’s Sentinel-5Psatellite (www.esa.int/Applications/Observing_the_Earth/Copernicus/Sentinel-5P) has tracked similar reductions inIndia and throughout Europe.

As countries manage reopening of their economies differently, the question remains as to what post-COVID-19emissions look like on a global scale. Will emissions return to pre-COVID-19 levels quickly, will there be a surge above those levels as people make up for travel time lost during the lockdown, or, will our behavior have been permanently altered and will the shifts seen in ourtransportation and energy sectors be the jump start needed to overcome hurdles that previously stood in the way of achieving global climate change objectives?I look forward to following this conversation to COP26 in Glasgow next year and hearing reports from acrossthe globe of how this pandemic has altered their models, predictions, and pathways to their climate objectives.Keep following our COP updates and conversationsthroughout the remainder of 2020 and into 2021 as we journey across the pond to join other observers for the next COP meeting in Glasgow. em



experiencing significant disruptions to their operations, asface-to-face vehicle sales have all but stopped and those consumers buying into virtual car shopping are limited.

In April, Germany reported an 82% drop in automobile salescompared to the same period last year. As a result, nearly allthe German vehicle manufacturers have scaled back produc-tions. While the manufacturing slowdowns are likely leadingto a lowering of emissions, it is important to note that someindustries are seeing a surge in demand, such as suppliers ofnondiscretionary items and medical supplies.

So where does this all lead from an environmental perspec-tive? Decreased production will certainly lead to decreasedemissions, even if just for a short term. And alternative sup-ply solutions may shift to locations that have stricter environ-mental regulations than China, leading to an overall loweremission impact from the supply chain. But the ultimatequestion is how long will the decrease last and what will thatmean to climate change predictions?

Closing ThoughtsIn its 2019 Special Report on Global Warming of 1.5 °C(www.ipcc.ch/sr15/ ), the Intergovernmental Panel on Climate Change (IPCC) indicated that achieving the temper-ature goals on the 1.5 °C pathway would require unprece-dented actions and a combination of technology, behavior,and investment. It may just be that COVID-19 has gone along way in changing behavior, but it could have stalledother efforts in technology development, investment, and installation. In reality, we know, thanks to studies from

Sessions will cover all aspects of PFAS, including:

• Chemistry• Health E�ects• Water Issues• Soils and Biosolids• Land�lls and Leachate• Air

As the concern for per- and poly�uoroalkyl substances (PFAS) increases, A&WMA has developed this conference to bring together scientists, researchers, academics, practitioners, regulators, and the regulated community to discuss the current state of PFAS science and to help develop solutions for the future.

Conference sessions will explore the chemistry, health e�ects, and current regulatory approaches and guidance for PFAS in water, soil, biosolids, land�lls, and air, as well as methods for their measurement, treatment, and destruction.

An EPA Facility Tour will be o�ered Monday, September 14.

The Science of PFAS

September 15-17, 2020 Durham, NC

Stay up-to-date on the latest developments in PFAS research, multimedia measurements, treatment technologies, and environmental policy from experts in the �eld

• Measurement Methods• Treatment Methods

• Federal Regulation, Guidance, and DOD Impacts

• State Activities

Thanks to our sponsors. Opportunities available for your company!

Register now and �nd more conference details at www.awma.org/pfas.

General Sponsors

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Waste Management Corner by MD Sahadat Hossain and Melanie Sattler

The world is moving toward a more urbanized future andthe amount of municipal solid waste (MSW), one of the mostimportant byproducts of an urban lifestyle, is growing evenfaster than the rate of urbanization. Currently, world citiesgenerate about 1.3 billion tons of MSW per year. This volume is expected to increase to 2.2 billion tons by 2025.1

Locally and globally, existing solid waste management and/ormismanagement presents both challenges and opportunities.

In developing countries, poorly managed waste has an enor-mous impact on health, the local environment, and the localeconomy. The collection efficiency of solid waste is less than50% in many developing countries. Uncollected solid wasteor rotting untreated waste helps the spread of malaria,dengue fever, cholera, typhoid, respiratory, and skin diseases.Many times, uncollected solid waste ends up in city drainage

Landfill Mining:A Step Toward Sustainable Landfills

Waste Management CornerEM is expanding its content coverage of waste management issueswith a special section of waste-themed articles in every issue, calledWaste Management Corner. In this month’s article, MD Sahadat Hossain and Melanie Sattler explore landfill mining as part of a sustainable resource management system.

systems, and the resulting clogging causes flooding in developing urban cities. Improperly managed waste usuallyresults in down-stream costs higher than what they wouldhave been to manage the waste properly in the first place.

Traditionally in developing countries, waste is placed in community open dumps, which pose human health andsafety threats by way of disease vectors, water pollution, and explosive conditions. The next typical step, to which most developed countries have progressed, is replacing open dumps with sanitary landfills, which use managementpractices and physical systems such as daily cover, liners, andleachate collection to reduce health/safety threats. However,MSW landfills in developed countries often require largetracts of land in or immediately beyond the urban growthareas. Typical landfills may occupy an area ranging from



several acres to hundreds of acres. Due to rapid growth and urbanization of cities beyond city limits, finding newlandfill spaces within or close to the city limits is becoming a predominant issue for MSW management in developedcountries. Increasing the capacity of existing landfills is becoming a major consideration for state agencies andfederal regulatory bodies.

Over the past few years, interest in landfill mining as a meansto extend the capacity of existing landfills has increased.Landfill mining recovers materials with value, like metals andplastics, from the landfill that had been previously disposedthere. By initiating landfill mining as part of routine landfilloperation, traditional landfills can evolve into a new genera-tion of sustainable landfills, with greater raw material recoveryand longer landfill life. However, landfill mining poses somechallenges, including potential quality of materials recoveredand the need for advanced waste separation technologies.This article considers the benefits and challenges associatedwith landfill mining as a component of sustainable landfills.

Landfill Mining as Sustainable Resource ManagementConventional waste management is an open loop cyclewhere generated products end up in the landfill after beingutilized by consumers.2 Problems associated with traditionallandfills include loss of materials that still have value, air- andwater-quality impacts, climate change impacts, and post-closure monitoring costs. These problems can be minimizedvia a sustainable resource management system (see Figure1), which consists of three main components: (1) material re-covery, (2) landfill operation as a biocell, and (3) landfill min-ing. These components will increase material recovery andreuse of materials like paper, plastic, and metals, and providequicker degradation and renewable energy from non-recov-erable wastes like food and yard waste (via biocell operation,discussed below). Landfills will no longer be long-term

storage facilities, but instead be treatment systems able to be operated perpetually in the same location. This shouldlead to improved public perception and acceptance by thegreater urban community.

Landfill mining refers to the process of excavating previouslydisposed MSW from an existing landfill, for the purpose of re-covering materials of value for re-use. Landfill mining was firstinitiated in Tel Aviv, Israel in 1953 with the primary objectiveto recover the soil amendment from the xcavation.3 This wasthe only initiative reported for several decades. In the early1990s, interest in the landfill mining strategy grew, and severallandfill mining projects were reported around the world.4,5

Through landfill mining as part of the sustainable resourcemanagement system, landfill space (volume) could be reutilized and the waste management operation could beconverted to a “closed loop” system (as presented in Figure2). In the generic closed-loop system in Figure 2, the alterna-tive waste technology refers to an alternative technology totraditional landfilling. Such alternative technologies recovervaluable materials or energy from waste. Those technologiesinclude, for example, materials recovery/recycling facilities,landfill mining to recover recyclable materials, composting offood- and yard waste, and waste-to-energy plants. The majorbenefits of landfill mining in a closed loop system are conser-vation of landfill space and recovery of valuable recyclablematerials.6,7

Feasibility Study in TexasA study was undertaken by the authors to investigate thestate of decomposition of landfilled waste and to evaluate thefeasibility of landfill mining for a closed section of the City ofDenton Landfill in Texas. The study evaluated the state of decomposition of landfilled organic waste collected from aclosed section of the landfill. A total of nine borings weredone and samples were collected at every 10-ft depth interval (with a maximum depth of boring 80 ft) in 2010,

Figure 1. Waste management: past, present, and future.



2014, and 2015. The study included characterization of the landfilledwaste, potential of material recovery,remaining volatile solids content ofthe landfilled samples, estimated cellulose to lignin ratio, estimatedbiochemical methane potential(BMP), and the estimated calorificvalues of the recovered wastes.

Based on the field and laboratory investigation results, and also fromvisual inspection, it was estimatedthat the retrieved landfilled sampleswere only partially degraded. There-fore, there is tremendous potentialfor resource and space recoveryfrom landfill mining. The value ofrecycling product may change withtime and may not add value to min-ing project. However, the additionalspace gain and avoidance of postclosure and maintenance cost oflandfill operation adds significantvalue to the landfill mining project.Based on the preliminary cost–bene-fit analyses, the project was consid-ered a viable option compared tobuilding a new landfill cell.

Example Concept of Sustainable Resource ManagementFigure 3 presents a new concept ofsustainable waste management andresource recovery through a perpet-ual landfill. For a perpetual/sustain-able landfill with a complete upfrontremoval of plastics, glass, and metal,landfills can be used in one locationin perpetuity to generate renewableenergy, as organic waste completelydegrades. Since nondegradableplastics, glass, and metals were re-moved upfront, all the waste placedin the landfill is degradable. There-fore, potential materials remainingafter degradation are organic in na-ture and can be reprocessed to useas compost, or at the landfill as alter-native daily cover material or backfillsoil during construction. Further-more, the landfill is operated as abio-reactor landfill or biocell, with optimal moisture content being ac-tively maintained to maximize waste

Figure 2. Open loop to closed loop operation of waste managementthrough landfill mining.6

Figure 3. Sustainable waste/resource management incorporatinglandfill mining.6

degradation and methane generation rates.

Since waste will degrade quickly, it is expected that whenwaste is being placed in Cell 4, the waste in Cell 1 should havedegraded, with that organic material then being available forextraction and beneficial use as compost or as landfill dailycover material. Mining would be conducted to retrieve thatmaterial, which also regains the landfill space (consideringlandfill life of 20 years and each cell will be operated for fiveyears). Cell 1 will then be ready for re-use. By the time waste is placed in Cell 1 again, the waste in Cell 2 should have degraded, and a mining operation can start in Cell 2, whichwould be ready for re-use when Cell 1 is filled. Consequently,there will always be about a 15-year period after a cell closesduring which that cell can be mined. This will provide enoughtime for the waste to completely degrade and to generatemethane gas, potentially recoverable as biogas fuel, providedthe landfill has been efficiently operated as a bioreactor landfill.The cells can continue to be re-used in perpetuity, eliminatingthe need to find additional landfill space. This would also elimi-nate the need for final cover design and may extend the life oflandfills more than 200 years.6

Limitations of Landfill MiningOne major limitation of landfill mining is that it can require alot of equipment (which can be expensive) and trained per-sonnel (may not be available). Another key concern is airemissions and odor nuisance that can occur when previouslylandfilled waste is unearthed during landfill mining. Still otherconcerns arise because both landfilling and landfilling miningoperations are ongoing at the same time and at the samesite. Those concerns include increased traffic on roads be-tween the landfill and resource recovery facility; extra mixingand handling of waste at the resource recovery facility; thehandling of additional inert materials; and increased odor,noise, and dust during the operation. However, those concerns can be minimized through proper site manage-ment planning for landfill mining operation.

A lack of knowledge about the nature of waste buried mightbe a concern in terms of safety issues. Other safety issues



include physical injury from rolling stock or rotating equipmentused during landfill mining; exposure to leachate, hazardousmaterials, or pathogens during mining or processing; and subsurface fires and landfill gas emissions. Health risks to thepublic appear to be minimal, although as stated above, odornuisance can be a problem. Also, low values of the recoveredmaterials can be seen, mainly in Europe, as limitations for theexisting landfill mining operations.8 This can be true especiallywhen operators may not be planning to reuse the landfillspace for future waste management operation. However, because of land scarcity resulting from rapid urbanizationglobally, the recovery of landfill space and additional volumepotential will be more valuable for sustainable waste manage-ment operations, both in developing and developed countries.

SummaryAlong with the global trend toward increased urbanization,there is an associated increase in waste generation and,hence, the need for evermore landfill capacity. Yet availableland for new landfills in the urban growth areas is scarce. This makes a compelling case for adopting more sustainablewaste management practices. Today, most materials presentin consumer goods eventually ends up disposed in a landfill.This open-loop consumption/disposal pattern drives a never-ending need to develop new landfill capacity.

This article has described a sustainable resource managementsystem for changing waste management from an open-loopsystem to a closed-loop system. In this system, post-consumermaterials are recovered or beneficially used via recycling, en-ergy recovery, or biological processing such as composting.Landfill mining is proposed as an integral part of the system.In landfill mining, an existing landfill is excavated to removeand recover materials, such as metals, glass, and plastics.When incorporated within a sustainable waste managementsystem, landfill mining can periodically re-establish the avail-able landfill volume/capacity at an existing landfill, enablingthe same landfill to operate in perpetuity. The landfill miningproposal can enhance a global shift toward sustainable wastemanagement for a circular economy, closing the gap between production and waste generation. em

References1. Hoornweg, D.; Bhada-Tata, P. What a Waste: A Global Review of Solid Waste Management; The World Bank: Washington, WA, USA (2012).2. Braungart, M. McDonough, W. Die nächste industrielle Revolution [The cradle to cradle community]; EVA Verlag, Hamburg (2009).3. Savage, G.M.; Golueke, C.G.; Stein, E.L. Landfill mining: past and present; Biocycle 1993, 34; 58-61.4. Dickinson, W. Landfill mining comes of age; Solid Waste Technologies 1995, 46.5. Cossu, R.; Hogland, W.; Salerni, E. Landfill mining in Europe and the USA; ISWA Year Book, 1996, pp. 107-114.6. Hossain, M.S.; Samir, S. Resource Recovery and Sustainable Material Management through Landfill Mining. In Proceedings of ISWA 2014, Dusseldorf,

November 14-15.7. Hossain, M.S.; Sonia, S.; Kemler, V.; Dugger, D. Site Investigation Approach for Landfill Mining. In Proceedings of ISWA Beacon Conference—

The 2nd International Conference on Final Sinks, 16-18 May 2013 in Espoo, Finland.8. Rosendal, R.M. Landfill Mining–Process, Feasibility, Economy, Benefits and Limitations (2009).

MD Sahadat Hossain is Professor of Civil Engineering and Director of the Solid Waste Institute for Sustainability (SWIS) at the Universityof Texas at Arlington, TX. E-mail: [email protected]. Melanie Sattler serves as the Syed Qasim Endowed Professor of Environmental Engineering at the University of Texas at Arlington. E-mail: [email protected].


Regulatory Roundup

Updated Interpretation for NSR Permitting; EPA Cuts Legs Out from Under MATS

Spring 2020 found the U.S. Environmental Protection Agency (EPA) working remotely

like most of the rest of us in the face of COVID-19 stay-at-home orders, but this didn’t

prevent the agency from publishing a draft guidance memorandum proposing a sweeping

change in how it will interpret and enforce the term “begin actual construction” under

the U.S. Clean Air Act’s (CAA) New Source Review (NSR) permitting scheme. EPA

also took final action on revisions to its Mercury and Air Toxics Standards (MATS) rule

that is likely to have sweeping implications on future rulemakings.

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

EPA Revises Longstanding Interpretation of ‘Begin Actual Construction’ for NSRThe 1977 CAA Amendments established the federal NSRpre-construction permitting program. Broadly speaking, NSRrequires the owner or operator of a new “major” source withthe potential to emit 250 tons per year or more of a regu-lated pollutant (the threshold is lowered to 100 tons per

year for certain listed sources) to obtain an NSR constructionpermit prior to beginning actual construction of the newsource. Similarly, owners or operators of existing sourcesthat are “major” for NSR are required to obtain an NSR construction permit prior to beginning actual construction of certain regulated “major modifications” to the existingsource.


Regulatory Roundup

EPA Completes Reconsideration of Its ‘Appropriate and Necessary’ Finding for MATSOn April 16, 2020, EPA announced that it had completed itsreconsideration of the appropriate and necessary finding forthe MATS Rule. In so doing, the agency took action to cor-rect what it deemed “flaws” in EPA’s approach to conductingthe cost–benefit analysis for MATS under the Obama Administration in 2011. These alleged flaws pertain towhether it was proper for EPA to consider so-called “co-benefits” tied to reductions in non-hazardous air pollutant emissions (e.g., PM2.5; both as a particulate and as an ozone precursor). The Trump-era EPA has taken theposition the cost–benefit analysis for MATS should only consider those benefits directly related to hazardous air pollutant emissions reductions attributable to the rule.

EPA’s action consists primarily of an unprecedented after-the-fact finding that it is not “appropriate and necessary” toregulate electric utility steam generating units (EGUs) underCAA Section 112. The revised finding is based upon theagency’s revised cost–benefit analysis, which shows that the direct benefits of MATS totaling US$6 million annuallywere far outweighed by the US$9.6 billion annual cost ofcompliance to affected source categories. Despite this, EPAdid not remove coal- and oil-fired EGUs from the list of affected source categories regulated under MATS, andMATS remains in effect. This tactical move may have (atleast temporarily) cut-off a subset of anticipated legal chal-lenges to the rule—particularly from environmental groups.

Given that the agency has now found the regulation ofEGUs under MATS to be inappropriate and unnecessary,it is highly likely that MATS will be challenged in court by affected members of the regulated community. If EPA wereto mount any defense of the rule at all, its hands wouldlargely be tied in terms of the defense it could mount sinceits own record now reflects that MATS is unnecessary to protect public health and the environment. In a final twist,most of the coal-fired EGUs have already completed thecapital investments necessary to comply with MATS. Now,the undoing of the rule offers no opportunity for theseplants to recover these “sunk” costs. Ironically, some EGUsare concerned that they may face consumer litigation withrespect to MATS-compliance-related rate increases that havenow been retroactively rendered unnecessary. em

EPA promulgated the definition of “begin actual construc-tion” in 1980 at 40 CFR 52.21(b)(11). Since then, the ques-tion of what constitutes “begin actual construction” has beenthe subject of almost constant controversy and confusionwithin the regulated community. Beginning in 1986, EPA is-sued a series of no fewer than four important guidance mem-orandums or letters seeking to clarify what the term “beginactual construction” means. Traditionally, EPA has prohibitedowners and operators from doing anything at a stationarysource that was of a “permanent nature” and/or “costly” priorto receipt of an NSR permit. This prohibition forbade suchthings as entering into irrevocable contracts for equipment,site excavation, blasting, removing rock and soil, backfilling,and installing footings, foundations, permanent structures,pipes, and retaining walls. More particularly, any preparatoryactivities directly related to an emissions unit (e.g., pouring aconcrete pad for a regulated boiler) were strictly prohibited.Allowable pre-permit activities were severely limited, and in-cluded not much beyond site clearing (e.g., the removal oftrees) and rough grading.

EPA changed all this on March 25, 2020, when the agencyissued a memorandum entitled, “Interpretation of ‘Begin Ac-tual Construction’ Under the New Source Review Precon-struction Permitting Regulations”. Therein, EPA announcedthat its nearly 40-year-old interpretation of “begin actualconstruction” was dramatically changing. Going forward, theowner or operator of a source may undertake any physical construction activities that it desires on-site prior to receivingan NSR permit—so long as those activities do not constituteactual physical construction of an emissions unit. Further,preparatory activities in support of an emissions unit (whatEPA calls “accommodating installations”) are allowable priorto permit issuance, if the emissions unit itself is not prema-turely installed before a permit is in hand.

EPA’s July 2020 memorandum includes numerous sharplyworded post-hoc criticisms of prior EPA efforts (under bothDemocratic and Republican presidential administrations) to fur-ther define prohibited pre-permit-issuance activities. The agencyasserts that its new interpretation of “begin actual construction”represents a “better reading of” the regulatory language under-lying the term. Ultimately, whether this interpretation is “better”will be a matter determined by the courts upon what is aninevitable appeal of this new agency guidance.

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


COVID-19 vs. Climate ChangeThe author ponders the similarities between—and varying responses to—the COVID-19 pandemic and climate change.

by Patrik Eskandari

YP Perspective

Events of the past couple of months have presented a series of logistical challenges and moral questions across the entire world. What is necessary for us to peacefully liveour daily lives? What sacrifices are we willing to make whenpresented with threats of a certain scale? At what point doesa clear and present danger become prominent enough towarrant a systematic response? How do you convince onepart of a population with a very low risk of danger to changetheir lives for the safety of others?

These questions have come to the forefront of the global society in the wake of the COVID-19 pandemic, which hascaused disruptions and unease on an unprecedented scale.However, this is not the first time questions such as these

have been asked. In fact, we have asked ourselves thesequestions every year for decades but arrived at a different answer every time.

The similarities between COVID-19 and man-made climatechange are paramount, yet the responses are starkly differ-ent. The physiology of the human race is limited in its abilityto combat either on its own, expensive global efforts are required to effectively respond to both, and no one singleperson amounts to more than a paper tiger in the midst of astorm (almost literally!) when confronted with the totality of the effects from both.

It is true that projections concerning climate change have


YP Perspective

inherent errors in their conclusions, and that the statisticalmodels to produce these projections are subject to revisions.But the scientific community has reached an indisputableconsensus on an overwhelming majority of results. Theworst-case scenario for climate change is, at the end of theday, an inhospitable planet. And the anticipated timeline toreach that is shrinking.

So why was COVID-19 enough to shut down entire nationsand economies? Enough to impose significant changes in citi-zens’ daily lives? Enough to push our global resources towarda systematic threat response? Enough to say, “cease opera-tions because our lives depend on it”? The answer is urgency.

Unlike climate change, COVID-19 is an immediate threat. It isspreading now, and on a far greater scale than the climatechange-induced wildfires that recently swept Australia. Afterwatching the early stages of the virus sweep across China andItaly, the global community saw it as an urgent threat, and re-sponded accordingly.

Climate change—despite its symbolic relationship withCOVID-19—still behaves very differently. It has been an issuefor decades, almost centuries, ever since we began burningfossil fuel, releasing hydrocarbons buried deep below theEarth’s surface into the atmosphere, and developing the firstwave of refrigerants that caused unparalleled damage to ouratmosphere. However, for much of the world, the most se-vere cases are isolated due to their geography. Many simplydo not consider it urgent on a global scale… yet.

Countries all over the world have taken great strides to limitpollution from their activities, and others still have imple-mented highly successful programs for renewable energyand carbon-neutrality. However, the global response hasbeen in the form of agreements, best practices, directions,and long-term goals. Meanwhile, many industrial practices

that contribute to climate change continue to be subsidizedand invested in by governments across the world. We are notaligned in our response, and without alignment we are com-bating this issue with dissent amidst our ranks. If we were touse COVID-19 as a litmus test for climate change, we cantherefore extrapolate that a serious global effort will not occuruntil a clear and present sense of urgency is established.

This presents a problem. Climate change has steadily grown fordecades. Consequently, we are normalized to it. It is a part ofour lives; a known risk we are taking every day. It did not pres-ent itself suddenly and drastically like COVID-19. The problemis that the same response is required for climate change to “go away.”

For a moment, remove the logistical and economic challenges that arise from human behavior (e.g., keepingpeople fed and their utilities running), and view bothCOVID-19 and climate change in a vacuum. For the sake of the discussion, assume every individual can stay in theirhomes during the crisis and has a food stock available to lastthrough the crisis. COVID-19 has an incubation period of approximately 5 days, and a symptomatic period of approxi-mately 14 days, amounting to roughly 3 weeks of infection.In a perfect world, 6 weeks of full lockdown would allow fortwo “rounds” of infection and treatment. The first round forthe infected population, and the second round for the health-care workers who were infected during treatment. Let us adda third round so that healthcare workers can trade off, andimmunized healthcare workers from round two can care forworkers in round three. That is a 9-week period needed for an authoritarian system to stamp out COVID-19. Realisti-cally, this is not possible. Nor would many people enjoy livingunder a system capable of mandating such practices. Thepoint is not that this realistic, the point is that this is possible,in theory. Viruses can be contained, treated, they can bemanaged in short- to mid-term intervals.

If we were to use COVID-19 as a litmus test for climate change, we can extrapolate that a serious global effort will not occur until a clear and present sense of urgency is established.


many unfortunate individuals face against COVID-19, manythousands more are breathing cleaner air, drinking cleanerwater, and are at far less risk of sicknesses and defects thatoccur because of pollution. Data are limited about how thesereductions will affect the pace of climate change, but one thingis for sure: a transition to a sustainable, renewable future willresult in an environment far more conducive to human healthand physiology than the route we are currently on.

Amid the shutdowns and stay-at-home orders, we are facedwith opportunity. Opportunity for a heightened awarenessthat, for the first time in human history, the entirety ofmankind can resolve a global threat. Opportunity for a“green restart,” as many countries are calling for. Opportunityto take a step back and reflect on where we were, and whereit took us, and how to pave a better path forward for all of us. em

YP Perspective

Climate change is not like this. If we wait until climate changeis urgent, if we wait until there is a clear and present dangerfor the global community, what will happen? We have spentdecades terraforming. Countless toxic chemicals and pollu-tants have created a virtually new ecosystem. To condense a“best-case scenario” response into a single paragraph aboveis not possible. Climate is not something you can put into aroom, lock the door, and come back to in a few weeks. Justas it has taken decades for climate change to occur, it wouldtake decades to “reverse” the damage, if at all.

So, what then? If COVID-19 has taught us anything it is thatproactively addressing climate change is much more achiev-able than we have been led to believe. The massive reductionsin travel and industry operations have had resounding effectson pollution and the environment across the world. Air andwater quality are trending better than they have in years. While

Patrik Eskandari is a chemical engineer, environmental consultant, and amateur programmer with a background in the specialty chemi-cal, automotive, and oil & gas industries.

Disclaimer: The views expressed in this article are those of the author and are not necessarily those of the author’s employer and/or A&WMA.

YP Perspective is a semi-regular column organized by A&WMA’s Young Professional Advisory Council (YPAC; www.awma.org/yp). YPAC strives to effectively engage professionals within the Associa-tion by developing services and activities to meet the needs of today’s young professionals (YPs). A YPis defined by the Association as being 35 years of age or younger. Each YP is encouraged to get in-volved with the Association, whether within their local Chapter or Section or within the Association’sfour Councils—Education Council, Technical Council, Sections and Chapters Council, and YPAC. YPs interested in getting involved may contact YPAC for more information on current volunteer and leadership opportunities. Call for Submissions: If you have a topic you would like to see YPs discuss in EM, e-mail: Kerry Weichsel ([email protected]).


This year, we celebrate 50 years of A&WMA’s AnnualCritical Review. For half a century, A&WMA has solicited and published in the Journal of the Air &Waste Management Association (JA&WMA) an Annual Critical Review on a topic of critical importanceto the air and waste management fields. Each year, the review author presents the Annual Critical Reviewat a special session held during A&WMA’s Annual Conference & Exhibition. Each month in this space, we will take a moment to look back at a singular review of critical significance from the past 50 years.

Back In Time

This month, we spotlight the 1995 Critical Review authoredby long-time A&WMA member and Past Critical ReviewCommittee Chair, Dr. Judith C. Chow. The publication of this review marked the 25th Anniversary of the A&WMAAnnual Critical Review Program.

In his introduction to the 1995 Critical Review, Dr. John G.Watson detailed the history of the program up to that pointand highlighted its great success. The review itself, entitled“Measurement Methods to Determine Compliance with Ambient Air Quality Standards for Suspended Particles,”would build on earlier reviews of air quality measurementsby W.C.L. Hemeon and M. Katz (“Regulations for the Control of Particulate Emissions,” 1973 and “Advances inthe Analysis of Air Contaminants,” 1980, respectively). Dr. Chow’s review identified issues related to measurementmethods used to determine compliance with standards, described current and future measurement methods andtheir limitations, and determined the extent to which existingtechnology can meet short-term and long-term needs formeasuring compliance.

After reviewing more than 1,000 citations, Dr. Chow

determined that compliance monitoring is used for morethan identifying standard violations. The data are also usedto develop control strategies, to monitor the effectiveness ofthose strategies, and to determine the effects of air qualityon public health. Flexibility in measurement methods wasneeded to accomplish some or all these objectives. Her review of sampler comparison studies also showed that a design specification does not necessarily guarantee measure-ment equivalence, owing to differences in sampling andanalysis that are not specified in the design. Dr. Chow con-cluded from her review that while differences in samplerinlet characteristics were the major cause of discrepanciesamong measurements of PM10, particle volatilization is likely to be the major cause of discrepancies among massmeasurements made on PM2.5 samples.

At the time of publication, Dr. Chow was a Research Professor in the Energy and Environmental EngineeringCenter (EEEC) at the Desert Research Institute (DRI), where she directed DRI’s Environmental Analysis Facility,which specialized in the development and application of advanced sampling and analysis methods for visibility,source apportionment, and health studies. em

‘Those who ignore history are bound to repeat it.’

Past Critical ReviewsA complete list of A&WMA’s past Critical Reviews is available online at http://pubs.awma.org/journal/A&WMA%20Critical%20Reviews.pdf. To read and download any of the past Critical Reviews, log onto JA&WMA Online atwww.tandfonline.com/loi/uawm.

1995 Annual Critical Review: Measurement Methods to Determine Compliance with Ambient Air Quality Standards for Suspended Particlesby J.C. Chow


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