Category: Environmental Defense

By Tom Neltner

Tom Neltner, J.D., is Chemicals Policy Director

Accelerating full replacement of lead service lines (LSL) – the lead pipes that run from the drinking water main under the street to homes – is a priority for EDF. These pipes are the primary source of lead in water and, when disturbed, may release lead particles that expose consumers, without warning, to extremely high levels. As part of the effort to encourage safe and effective removal of LSLs replacement, EDF helped launch a new Lead Service Line Replacement Collaborative with 23 national public health, water utility, environmental, labor, consumer, housing, and state and local governmental organizations to help communities develop and implement voluntary programs to eliminate these pipes.

Today, the Collaborative released an online toolkit to assist communities in lead service line replacement. The online toolkit includes:

• A roadmap for getting started,
• Suggested replacement practices to identify and remove lead service lines in a safe, equitable, and cost-effective manner,
• Policies that federal and state leaders could adopt to support local efforts, and
• Additional resources that may be helpful when developing local programs.

USA Today highlighted the Collaborative and the toolkit in an article also released today.

The toolkit is intended to be a living resource.  Therefore, the Collaborative is seeking communities to pilot and provide feedback on the materials.

The voluntary efforts promoted by the Collaborative are not a substitute for a long-overdue overhaul of the Environmental Protection Agency’s Lead and Copper Rule (LCR).  Even under the best of scenarios, the revised rule will be promulgated in 2018 and go into effect in 2021.  The next administration’s statements about regulations puts even that distant date in doubt.

Instead of waiting for a new rule, the Collaborative’s toolkit leverages from the knowledge and experience of its members and their constituents.  It draws from the successful LSL replacement programs of Madison, WI, Lansing, MI, and the ongoing work of Boston, MA and Washington, DC.  It also learns from programs in Cincinnati, OH, and Milwaukee, WI that are launching comprehensive efforts as well as the states of California, Michigan, Ohio, Washington, and Wisconsin that laid foundations for communities to undertake replacement programs in 2016.

The Collaborative is grounded in the following principles:

• Removal of lead service lines in contact with drinking water provides an opportunity to significantly reduce the risk of exposure to lead from drinking water.
• LSL replacement initiatives must be designed to ensure residents are protected during and after the removal and that the work is done in a cost effective manner.
• LSL replacement initiatives should address barriers to participation so that consumers served by LSLs can benefit equitably, regardless of income, race or ethnicity.
• A collaborative, community-based approach, built on contributions from residents, health officers, utilities, community leaders, local elected officials, can help provide the strong foundation needed for successful action.
• Innovative models are needed to help communities find the tools, strategies and resources needed to replace LSLs based on the latest science and current best practices.
• By providing models for LSL replacement, it is possible to advance support for initiatives at all levels of government and in different types of communities.
• Successful LSL replacement initiatives will take careful planning and time.
• This effort is focused on mechanisms to support local action not on EPA’s efforts to revise the Lead and Copper Rule.

The members of the Collaborative are:

• American Public Health Association
• American Water Works Association
• Association of Metropolitan Water Agencies
• Association of State Drinking Water Administrators
• Blue Green Alliance
• Children’s Environmental Health Network
• Clean Water Action
• Environmental Defense Fund
• Justice and Sustainability Associates
• Learning Disabilities Association of America
• National Center for Healthy Housing
• National Association of County and City Health Officials
• National Association of State Utility Consumer Advocates
• National Association of Water Companies
• National Conference of State Legislatures
• National Environmental Health Association
• National Rural Water Association
• Natural Resources Defense Council
• RESOLVE
• Rural Community Assistance Partnership
• Trust for America’s Health
• United Parents Against Lead
• Water Research Foundation

Of course, this is just part of the solution, but were are very encouraged by the broad interest and participation in getting lead service lines out of use throughout the country.

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By EDF Blogs

By Pam Kiely, senior director, Regulatory Strategy, and co-authored by Charlie Jiang, EDF associate

2016 was a big year for progress in the U.S. power sector. Renewable energy sources provided 16.9 percent of the country’s electricity in the first half of 2016, up from 13.7 percent for all of 2015. The country’s first offshore wind farm opened off the coast of Rhode Island. Most importantly, carbon emissions from the power sector are projected to continue to decline and hit levels not seen since 1992.

Strong leadership by forward-thinking governors, policymakers, and power company executives who recognize the imperative of lower-carbon generation and the promise of clean energy, powerful market forces intensifying the push to lower-carbon resources, and the critical federal regulatory overlay of the Clean Power Plan — which has made clear that unlimited carbon pollution is a thing of the past — have all combined to deepen a trend towards cleaner electricity production at this dynamic moment in time.

Even with any possible political maneuverings in Washington, D.C. to reverse clean energy and climate progress, it is clear that the transition to a low-carbon future is well under way.

States and power companies are surging ahead — and given the favorable economics of clean energy and the urgent need to reduce climate-destabilizing pollution it would be foolish to turn back.

• More than 21 gigawatts of wind and solar power (utility-scale and rooftop) are projected to have been installed in 2016, accounting for 68 percent of new U.S. capacity additions. That’s according to analyses by FERC, SNL Energy, EIA, and SEIA/GTM Research.
• Some of the country’s oldest and least efficient power plants were scheduled to close in 2016, transitioning 5.3 gigawatts of capacity, in no small part due to increasingly favorable economics for low-carbon generation.
• Since 2014, solar installation has created more jobs than oil and gas pipeline construction and crude petroleum and natural gas extraction combined. According to recent reports, there are now more than 400,000 jobs in renewable energy.

Together, these trends indicate the U.S. power sector is well-positioned to continue to reduce carbon pollution at a significant pace. And because of the favorable economics for low-carbon generation and the urgent need to protect against climate risks, hundreds of major corporations are on record supporting the Clean Power Plan and the achievement of emission reduction targets.

Power sector carbon emissions declined to 21 percent below 2005 levels in 2015, and are expected to drop again in 2016, meaning the power sector is already two-thirds of the way towards meeting its 2030 pollution reduction goals under the Clean Power Plan.

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Notably, this de-carbonization of the electric sector has proceeded while the U.S economy has grown. In addition, recent analysis by the Brookings Institution shows that as of 2014, at least 33 individual states have also decoupled their economic growth from carbon pollution — continuing to grow their gross domestic product while significantly slowing their rate of greenhouse gas emissions.

Heading into 2017, companies from coast to coast are well-positioned to secure ongoing reductions in carbon emissions from their fleets – thereby helping the United States to achieve international commitments under the Paris Agreement, delivering greater value to customers and shareholders while ensuring state or municipal policy objectives will be achieved, and sharpening their ability to meet declining emissions limits in accordance with a federal regulatory framework.

Even the vast majority of states litigating against the Clean Power Plan can comply with the CPP targets by optimizing the carbon pollution benefits from already planned investments and compliance with existing state policies. The Clean Power Plan is crucial to making certain that states and companies take advantage of the opportunity to ensure the carbon reduction potential of these investments are fully realized, so they can in fact achieve these reasonable protections.

The shift to a lower-carbon future should continue, as power companies recognize both the imperative to reduce emissions and the benefits of moving in this direction despite changing political winds in Washington.

For example, shortly after the November election, a number of executives from historically coal-intensive companies convincingly reaffirmed their commitment to de-carbonization:

• No matter who occupies the White House, “[coal is] not coming back,” said American Electric Power CEO Nick Akins. “We’re moving to a cleaner-energy economy and we’re still getting pressure from investors to reduce carbon emissions. I don’t see that changing.”
• “It can’t just be, ‘We’re going to get rid of these regulations, and you guys can party until the next administration comes,’” Cloud Peak Energy Vice President Richard Reavey said. “There are serious global concerns about climate emissions. We have to recognize that’s a political reality and work within that framework.”
• “Markets are driving a lot of the behavior,” said Tom Williams, a spokesman for Duke Energy. “[W]e’ll continue to move toward a lower carbon energy mix.”
• “We’ve always had a point of view at Southern that there’s a reasonable trajectory in which to move the portfolio of the United States to a lower carbon future,” said Southern Company CEO Tom Fanning. “There’s a way to transition the fleet now.” In a later interview, Fanning added: “It’s clear that the courts have given the EPA the right to deal with carbon in a certain way.”
• “Regardless of the outcome of the election,” said Frank Prager, Xcel Energy’s Vice President of Policy and Federal Affairs, “Xcel Energy will continue pursuing energy and environmental strategies that appeal to policymakers across the political spectrum because we are focused on renewable and other infrastructure projects that will reduce carbon dioxide emissions without increasing prices or sacrificing reliability.”

Acting on these commitments, many power companies are continuing to expand their renewable investments while phasing out high-carbon generation, putting them in a solid position to comply with robust carbon pollution regulations.

Here are a few recent highlights just from the last months:

• At the end of December, Florida Power & Light (FPL) showed strong leadership when announcing plans to shut down the recently-acquired 250-megawatt Cedar Bay coal plant at the end of the year. “I’m very proud of our employees for proposing this innovative approach that’s environmentally beneficial and saves customers millions of dollars,” said CEO Eric Silagy. FPL plans to replace the retired power with natural gas and solar — the company added 224 megawatts of solar capacity in 2016. FPL also noted that their system is now “cleaner today than the 2030 carbon emissions rate goal for Florida outlined by the Clean Power Plan,” while average residential bills are about 30 percent lower than the national average.
• On December 30, Southern Company announced an agreement with Renewable Energy Systems America to develop 3,000 megawatts of renewable energy scheduled to come online between 2018 and 2020. The agreement comes as Southern Company continued to boost its renewable portfolio with the acquisition of 300 megawatts of wind power in late December, bringing its total to more than 4,000 megawatts of renewable generation added or announced since 2012.
• Duke Energy acquired its first solar project in Colorado on Dec. 8. The purchase advances Duke’s goal of owning more than 6,000 megawatts of renewable energy projects by 2020.

After the election, a number of power companies reiterated their commitment to reducing air pollution and meeting their obligations under the federal Clean Air Act by transitioning aging coal plants.

• PNM Resources spokesman Pahl Shipley said the company has no change in plans for retiring two units at a New Mexico plant, totaling 837 megawatts of capacity, in 2017. PNM will replace the retired capacity with solar and nuclear power.
• The Tennessee Valley Authority is moving forward with plans to retire two coal plants in 2017, as well as a third in 2018.
• Colorado-based electric cooperative Tri-State Generation will move forward with plans to retire its 100-megawatt Nucla coal plant and Unit 1 of the Craig coal plant. “We are moving forward with retirement activities and developing a transition plan for the employees and communities,” said Tri-State spokesman Lee Boughey after the election.

These announcements follow one of the biggest clean energy leadership stories of 2016 – commitments by two midcontinent utilities, Xcel Energy and Berkshire Hathaway Energy, to go big on cost-effective investments in new wind resources.

• This past year, Minnesota regulators approved a plan for Xcel Energy to construct as much as 1,800 megawatts of new wind power and 1,400 megawatts of solar in the state by 2030. Xcel also received approval to build a 600 megawatt wind farm in Colorado.
• Berkshire subsidiary MidAmerican Energy secured approval to construct a massive 2,000 megawatt wind farm in Iowa that will be the “largest wind energy project in US history.” Said CEO Bill Fehrman: “Our customers want more renewable energy, and we couldn’t agree more.”

State policymakers have not stayed on the sidelines, either. 2016 sustained progress as states moved forward with commonsense efforts to reduce emissions of harmful air pollutants. And even with promises to roll back critical clean air, climate, and clean energy progress coming out of Washington, D.C., states made clear after the election that they will not be slowed down by potential federal backsliding:

• On December 7, Illinois enacted a comprehensive new energy bill that will in part double the state’s energy efficiency portfolio and allow for 4,300 megawatts of new solar and wind power while providing for continued operation of zero-emission nuclear facilities. These measures are expected to reduce the state’s carbon emissions 56 percent by 2030.
• On December 15, Michigan lawmakers approved a new bill to increase the state’s renewable portfolio standard to 15 percent by 2021, up from 10 percent. Republican Governor Rick Snyder touted the bill in a statement: “What we’re in is a huge transition in how we get our energy. We’ve got a lot of aging coal plants that are beyond their useful life, and it’s not worth investing in them anymore … We can transition to both natural gas and renewables and let the markets sort of define the balance between those two, so we’re moving away from an old energy source [where] we had to import all of this coal.”
• Also in December, Washington Governor Jay Inslee proposed the state adopt a first-of-its-kind carbon tax of $25 per metric ton of carbon pollution. The proposal supplements the state’s innovative Clean Air Rule, adopted in September, which caps carbon emissions from individual polluters.
• Nine states comprising the Regional Greenhouse Gas Initiative are engaged in a stakeholder process designed to establish new, more protective, standards for climate pollution.
• In Oregon, regulators are evaluating options for a market-based mechanism that could link to the California-Quebec carbon market, releasing a partial draft report on November 21.

• Governors such as Colorado’s John Hickenlooper continue to display strong leadership and a keen understanding of the imperative to move to a low-carbon future. After the election, Hickenlooper said he remains committed to fulfilling the goals of the Clean Power Plan, no matter what happens to the rule.
• In Pennsylvania, a spokesman for Governor Tom Wolf’s Department of Environmental Protection (DEP) noted that: “Pennsylvania’s carbon footprint has been shrinking rapidly due to market based decisions being made in the state’s electric generating sector … It is likely that this trend will continue.” He added that the DEP “will continue to seek ways to continue addressing climate change.”
• In California, Governor Jerry Brown mounted a vigorous defense of California’s climate leadership and the role the state will continue to play in setting the stage for ongoing progress and defending the important progress of the last eight years. “We’ve got the scientists, we’ve got the lawyers and we’re ready to fight. We’re ready to defend,” he said.

The momentum that power companies and states have generated towards achieving a clean energy future is powerful and encouraging.

Looking to 2017 and beyond, market trends are expected to continue to help facilitate de-carbonization of the electric sector, while federal and state policies must continue to provide certainty about the pace and depth of emissions reductions needed to address the threat of climate change. These policies will help companies plan clean energy investments in a way that maximizes benefits for consumers and facilitates optimal deployment of available resources.

The Clean Power Plan remains crucial to achieving these goals. Any disruption in the Clean Power Plan’s implementation could put long-overdue and readily achievable emission reductions at risk.

As we ring in the New Year, EDF will keep working with a diverse set of stakeholders across the country — including many state officials and power companies — to defend these critical environmental safeguards. At the same time, we will work vigorously to ensure that we achieve the reductions in carbon pollution envisioned by the program.

This post originally appeared on our Climate 411 blog.

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By Jenny Ahlen

I spend a lot of time these days thinking about food waste.

Why? First, I’m the mother of a toddler who oscillates between being a bottomless pit, easily cleaning her plate, to being a picky eater who only takes a couple of bites before the bulk of her meal ends up in the trash.

Second, I’m married to a chef who, because he’s a smart businessman, runs his kitchen with the precision of a comptroller: wasted food means lost profit, so every scrap of food is utilized wherever possible.

Finally, I interface almost daily with Walmart, the world’s largest grocer. Walmart recently pledged to root out 1 gigaton of greenhouse gas reductions from its global supply chain, and I’m certain that food waste will play an integral part in reaching that goal.

But before you conclude that I’m an outlier—some sort of obsessive, “food waste weirdo”— a recent study shows that I’m not the only one struggling with this issue:

• American’s waste approximately 80 billion lbs. of food each year;
• 77.22% of those surveyed feel guilty about throwing all that food away.

Now we all know that just because one feels guilty about something doesn’t mean one’s behavior will change.  Cost, however, is a frequent driver of behavior, so consider these numbers:

• Only 42.1% of people surveyed understand that wasted food is also money lost;
• Food waste actually represents $1,350 to $2,275 lost each year to family of four.

In other words, 2.5-4% of the 2015 US median household income is being thrown away! That’s bad news for our wallets—and our planet (NRDC estimates that food rotting in landfills accounts for 16% of U.S. methane emissions).

So it’s a no-brainer that wasting food serves no one’s interests.  What’s not so clear is: what can be done about it?

A business opportunity… with a coveted consumer

This is where I see a real opportunity for grocers—like Walmart—and the food companies that fill their shelves. For the most part, these companies are talking non-stop these days about how to win over the most coveted customer of all, the “millennial mom”.

Inviting millennial moms to be partners on eliminating food waste could be the perfect strategy. They are young (meaning they have years of brand loyalty ahead of them), cost-conscious and environmentally engaged; saving them money while alleviating their food waste guilt is a clear win-win.

I’m not saying this will be easy; that same study reveals that real barriers exist:

• 59.3% of consumers surveyed believe food waste is necessary to make sure meals taste good ;
• 51.2% of those same consumers think it would be difficult to reduce household food waste further.

However, while conceding that it’s difficult (if not downright un-wise) to portray millennial moms as a monolithic group, marketing profiles of these women consistently portray them as, a.) hungry for information about products; and b.) willing to take action on issues… but only if roadblocks or impediments have been removed.

So, grocers and food companies, how can you burnish your brand with millennial moms while making a real dent in food waste?

Step number 1: engage and educate

Run marketing campaigns, both in-store and out, that will inform these coveted customers on:

• Proper handling and storage of their food to minimize spoilage; and
• How to fully utilize their food purchases. In other words, teach them to think like my husband, the chef, so they can make use of scraps and leftovers.

Step number 2: make it easy

Design and implement initiatives that make for fun, easy adoption:

• Clarify date labeling so that perfectly good food isn’t perceived as bad. The USDA just requested that companies switch to “best if used by” language to give consumers more accurate guidance.
• Suggest meals that enable moms to buy just what they need—and use it up. There’s a real business opportunity here: did you know that, as of 4 pm each day, 80% of mom’s don’t know what’s for dinner that night? Suggesting recipes that will be totally consumed will make her life easier!
• Inspire composting (and discount composters)… their garden will thrive because of you! Or help make curbside composting possible like in Boulder, Seattle and San Francisco.
• Be creative… people love to compete! Only 13.5% think that their household wastes more than their average neighbor (study). Help people understand that they may in fact be wasting way more food and money than their friends, family, and neighbors to motivate them to do something about it.

In the meantime, I will carry on, hopeful that while my daughter learns to clean her plate, an array of giant food companies and grocers will take up the mantle of tackling food waste on a massive scale.

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By Richard Denison

Richard Denison, Ph.D., is a Lead Senior Scientist. Lindsay McCormick is a Project Manager.  

Today, EPA issued its long-awaited rule to gather risk-relevant information on nanoscale materials. The new rule will finally allow EPA to obtain basic data on use, exposure, and hazards from those that manufacture or process these materials, which has long been recognized by experts as essential to understand and manage their potential risks.

Nanomaterials – a diverse category of materials defined mainly by their small size – often exhibit unique properties that can allow for novel applications but also have the potential to negatively impact our health and the environment.  Some nanomaterials:  more easily penetrate biological barriers than do their bulk counterparts; exhibit toxic effects on the nervous, cardiovascular, pulmonary, and reproductive systems; or have antibacterial properties that may negatively impact ecosystems or lead to resistance.

Numerous expert bodies have identified the need for the kinds of information on nanomaterials EPA will now be able to collect, including the National Academy of Sciences, the National Nanotechnology Initiative, and EPA’s Office of Research and Development.  The Organization for Economic Cooperation and Development (OECD) published a report last year noting that the number of products containing nanomaterials increased fivefold in the global market between 2006 and 2011, and are being used in hundreds of new products ranging from cosmetics and personal care products to clothing and textiles, solar cells, plastics for the automotive and aircraft industries, and food packaging.

EPA’s new rule institutes a one-time reporting requirement for existing nanomaterials, as well as a standing one-time reporting requirement for new nanomaterials before they are manufactured.  Companies that manufacture, import or process existing nanomaterials, or intend to start doing so for a new nanomaterial, are required to submit the following categories of “reasonably ascertainable” information to EPA:  chemical identity, production volume, methods of manufacture and processing, exposure and release information, and available environmental and health impacts data.  By collecting such data, EPA will finally be able to draw a clearer picture of the nanomaterials in and entering commercial use, and better determine whether action to mitigate risk is needed, on a case-by-case basis.

This basic rule has been a very long time coming.  As illustrated in the graphic above, EPA has been attempting – for over a decade – to issue such a rule to gather even this most basic information on nanomaterials in the U.S. market.  Over the years, we have blogged extensively on EPA’s slow progress, due to opposition from both industry and other parts of the Federal government at every step.

There are a number of notable aspects of what is included – and not included – in the final rule:

• It applies both to nanoscale materials already in commerce and to new nano forms of existing chemicals that companies intend to make or process in the future. (Wholly new nanoscale chemicals would be required to be reviewed under TSCA’s new chemicals provisions.)
• In promulgating the rule, EPA affirmed its broad authority to collect existing information under section 8(a) of TSCA, rejecting industry arguments that such authority was highly constrained.
• EPA removed reporting exemptions it had proposed for nanoclays and zinc oxide, and rejected industry calls to include numerous additional exemptions.

The rule is not perfect and omits reporting EDF and others urged be included.  For example:

• Aggregates of nanoscale particles must fall within the 1-100 nanometer (nm) range to be reportable. We argued that aggregates comprised of nanoparticles between 1-100 nm be reported even if the aggregate is larger, given that such aggregates can often disaggregate in the environment or during use.
• Companies that submitted a pre-manufacture notice (PMN) for a nanoscale material at any time since 2005 do not have to report for that material. Our concern is that this will miss new information on that material that has been developed since the PMN was reviewed.
• Chemical substances “formed at the nanoscale as part of a film on a surface” are exempted from reporting. We argued that such films can break down or erode over time especially if exposed to the elements, potentially releasing the nanoscale materials.

Still, with this rule finally finalized, EPA can at last begin to get basic risk-relevant information needed to make sound decisions about which materials and uses present concerns and which do not.

 

For more detail on the history of this rule, see these earlier blog posts:

• Nano Confessions: EPA all but concedes mandatory reporting and testing are needed (January, 2009)
• Waiting for Godot: 405 days and counting at OMB on EPA’s modest proposal to identify chemicals of concern under TSCA (June, 2011)
• A hint of movement in the Super Slo-Mo that is nanoregulation at EPA under TSCA (October, 2014)
• Why is the nanotech industry so intent on keeping EPA from doing its job? (August, 2015)

 

 

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By Tom Neltner

Tom Neltner, J.D., is Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

Last month, the Food and Drug Administration’s (FDA) scientists published a study showing significant increases in perchlorate contamination in food sampled from 2008 and 2012 compared to levels sampled from 2003 to 2006. The amount of perchlorate in foods infants and toddlers eat went up 34% and 23% respectively. Virtually all types of food had measurable levels of perchlorate, up from 74%. These increases are important because perchlorate threatens fetal and child brain development. As we noted last month, one in five pregnant women are already at great risk from any perchlorate exposure. The FDA study doesn’t explain the increase in perchlorate contamination. Yet, it’s important to note that there is one known factor that did change in this time period: FDA allowed perchlorate to be added to plastic packaging.

Reported perchlorate levels in food varied widely, suggesting that how the food was processed may have made a significant difference. The increase in three foods jumped out to me:

• Bologna: At a shocking 1,557 micrograms of perchlorate per kilogram (µg/kg), this lunchmeat had by far the highest levels. Another sample had the fifth highest levels at 395 µg/kg. Yet a quarter of the other bologna samples had no measurable perchlorate. Previously, FDA reported levels below 10 µg/kg.
• Salami: One sample had 686 µg/kg giving it a third ranking. Other samples showed much lower levels and six of the 20 had no detectable levels of perchlorate. Previously, FDA reported levels below 7 µg/kg.
• Rice Cereal for Babies: Among baby foods, prepared dry rice cereal had the two highest levels with 173 and 98 µg/kg. Yet, 15 of the 20 samples had non-detectable levels of perchlorate. Previously, FDA reported levels less than 1 µg/kg.

The increases are disturbing in light of the threat posed by perchlorate to children’s brain development and the emerging science showing the risk at lower levels is greater than thought a decade ago. The risk is particularly significant for children in those families loyal to those brands with high levels. Unfortunately, FDA’s study does not identify the brand of food tested.

What might explain the increase in perchlorate contamination?

The only action we can document is FDA’s decision in 2005 to allow as much as 12,000 parts per million (ppm) of perchlorate to be added as an anti-static agent to plastic packaging for dry food with no free fat or oil. The packaging can be used for final products or raw materials before or during processing. Even if the final product is a liquid, raw materials such as rice, whey, sugar, starch, or spice may have contacted the perchlorate-laden plastic. The FDA decision was made in late in 2005 and sampling from the first study ended in 2006.

A Freedom of Information Act request by the Natural Resources Defense Council (NRDC) showed that FDA’s decision was based on a flawed and outdated assumption that perchlorate would not migrate into food at significant levels. Tests provided by the manufacturer late in 2015, in response to a food additive petition from NRDC and others, showed that perchlorate did indeed migrate into food, most likely from abrasion as the food flows in and out of the package. The petition asked FDA to reverse its 2005 decision and ban use of perchlorate. When FDA missed the June 2015 statutory deadline for a decision on the petition, NRDC and others sued the agency to force action. The agency told the court that it aims to make a final decision by March 2017.

What does FDA’s analysis say?

For more than 40 years, as part of its Total Diet Study, FDA has collected samples of more than 280 types of food every year from three randomly-selected cities in four regions of the country. It blends the samples from each of the three cities and analyzes the composite sample for various chemicals, such as heavy metals, nutrients, pesticides and other substances. The agency samples more than 50 types of baby food, including three types of infant formula. The agency also tests bottled water but not tap water. The agency does not report the brands sampled.

Periodically, the agency posts the results on its website and publishes studies evaluating its findings. In response to concerns with perchlorate contamination of produce and dairy, FDA published a study in 2008 summarizing the results from samples collected from 2003 to 2006. It provides updates on a webpage dedicated to the chemical.

On December 21, 2016, FDA published its latest article reporting the results for samples collected from 2008 to 2012 and compared them with those collected from 2003 to 2006 using two different statistical methods. The study provides supplementary data that includes the analytical results but does not identify the year or region from which the samples were collected. Neither the article nor the analytical results are yet available on the agency’s webpages dedicated to perchlorate or the Total Diet Study.

FDA estimated dietary intakes for 14 distinct age/sex groups. Infants and toddlers had the highest estimated consumption with 0.36 and 0.43 μg/kg-bw/day respectively.  Infants had a 34% increase in perchlorate exposure compared to the foods purchased before and around the time of FDA’s approval to use perchlorate in food packaging. More than half of the infant exposure came from baby food, including infant formula. Two-year old children’s exposure increased 23%. More than half of their exposure came from dairy products.

What should FDA do?

FDA’s compelling data on the significant increase in perchlorate exposure from the food we feed our children since its approval of perchlorate added to packaging should prompt the agency to act now to ban its use in contact with food. This decision cannot come fast enough. FDA must remedy a problem of its own making, and protect what many of us value the most—our children’s health and their ability to learn and thrive to their fullest potential.

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By Tom Neltner

Tom Neltner, J.D., is Chemicals Policy Director

Transparency is an essential aspect of any successful program to reduce lead in drinking water. Knowing if you have a lead service line (LSL)—the pipe that connects the main under the street to the building—can help you decide whether to use a filter or replace the line. If you are looking for a home to rent or buy, the presence of a LSL can be a factor in your choice. Transparency can also help reassure consumers that their utility is aware of the problem and committed to protecting their health. The challenge for many water suppliers is that they often don’t have perfect information about the presence of LSLs. But incomplete information is not a reason for failing to disclose what is known, what is uncertain, and what is unknown.

In a February 29, 2016 letter to the states, U.S. Environmental Protection Agency (US EPA) asked states to increase transparency by posting on either the state’s website or have it posted on local utilities’ websites:

“the materials inventory that systems were required to complete under the [Lead and Copper Rule] including the locations of lead service lines [LSLs], together with any more updated inventory or map of lead service lines and lead plumbing in the system.”

In response to this letter and systemic issues brought to light about lead in drinking water in the village of Sebring, Ohio and Flint, Michigan, the State of Ohio enacted pragmatic legislation crafted by Governor John Kasich’s administration and the Ohio Environmental Protection Agency (Ohio EPA). Among its supporters was the Ohio Environmental Council. One provision in the law requires community water systems to

“identify and map areas of their system that are known or are likely to contain lead service lines and identify characteristics of buildings served by the system that may contain lead piping, solder, or fixtures . . .”

Utilities must submit the information to Ohio EPA as well as the departments of Health and of Job and Family Services by March 9, 2017 and update this information every five years.

To help utilities comply, Ohio EPA released draft guidance in September 2016 and laid out four resources to identify buildings likely to contain LSLs: 1) code and regulatory changes; 2) historical permit records; 3) maintenance and operation records; and 4) customer self-reporting. It recommended that utilities submit the maps in PDF format and identify areas likely or known to contain LSLs using different colors.

Ohio’s three largest cities, Cincinnati, Cleveland and Columbus, have taken different approaches to LSL transparency. Cincinnati embraced the requirement and took it a step farther.  It provided detailed on-line maps, modeled off Washington DC’s approach, enabling the public to search an address or view a map that tells them whether or not the service line is made of lead or if the material is unknown. The city provides information for both the portion of the service line owned by the utility (referred to as the “public side”) and the line on private property (referred to as the “private side”). It uses the best available information but does not guarantee accuracy.  Users must click on a disclaimer to access the site. Consistent with Ohio EPA guidance, the city invites customers to submit updated information to the utility by email. This level of detail allows any consumer to make informed choices whether they are buying or renting a home, picking a child-care facility, or deciding whether to use a filter.

In contrast, Cleveland has not gone as far as Cincinnati.  It has an on-line address search tool supplemented with static color-coded map. The tool only provides address-specific information on the public side of the service line but not the private side. This risks giving users the false impression that the lack of a LSL on the public side means that there is no LSL when there may still be lead pipe on the private side. However, Cleveland reports that preliminary surveys show that less than 3% of lines on private property as lead pipe.

Cleveland reported to me that it is open to considering an interactive map similar to Cincinnati and providing an option to allow customers to provided updated information.  This interactivity should make it easier for potential renters and homebuyers to scan a neighborhood to identify homes without LSLs.

In response to my inquiry, Columbus reported that it will submit a map similar to Cleveland and make it publicly available within the next month or so.  The map will be a PDF showing areas where their records indicate a home has a publically-owned lead service line. They are evaluating a searchable database as a possible future enhancement.

Replacing lead pipes is one of the best means for reducing the risk of lead exposure from water—a major source of lead after paint. A critical step towards this goal is building an inventory of LSLs, starting with the best available information—what is known and what isn’t known. While it may be a difficult step for a utility to admit it does not know whether the public or private side of a service line is made of lead, it is critical to make this information available in a user-friendly format that allows property owners to update and correct the information. The City of Cincinnati and State of Ohio serve as a model for other communities.

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By Kate Zerrenner

At my household, a new year means a new energy and water-use baseline. By that I mean, every month, I look at how much electricity and water I used in comparison to the same month the previous year – so I can try to be as efficient as possible. But I work in the energy field, and I know that’s not a typical New Year’s tradition. Most people don’t examine the trends of their energy-use or spend much time thinking about how to reduce it.

So, what motivates the “average” person to take action and be more energy-efficient? It depends.

A recent study by the Pacific Institute for Climate Solutions and the American Council for an Energy Efficient Economy (ACEEE) looked at the psychology behind individuals’ energy efficiency behavior, and how that information could be used to design more effective programs.

The study came away with some fascinating findings that show electric utilities need to be strategic in the way they create, as well as communicate about, their efficiency programs. Moreover, it led me to believe showing how energy efficiency relates to water – the quality and availability of which many people care about – could help encourage people to be more mindful about their energy use.

Study takeaways

One false assumption often made when designing an efficiency program is, if you give the customer the information and tell them what to do, they will do it. But information alone will not lead people to change their behavior.

In order to ensure people actually hear and act on the message, utilities should consider:

• Tailoring messaging: Rather than simply talking about saving energy, the program could emphasize improving air quality or saving money, depending on your audience. For example, the study concludes “conservatives are more likely to respond to messages about ‘wasted energy’ or ‘climate change’ than to messaging about ‘global warming’.” But first, utilities have to learn more about their customers to understand the language that will work best.
• The right messenger: People are social animals, and we are more likely to listen to a message from someone we know and trust. The study found that recruiting trusted leaders from a social network, like a neighborhood or church, would be more effective than having the information come from an outsider.
• Giving feedback: Letting people know their actions are saving energy makes it more likely they will continue to engage in that behavior. Plus, “the more frequently personalized feedback is given, the more effective it tends to be.” Other studies have shown real-time energy-use feedback can result in up to 12 percent household savings.
• Using pledges: A commitment to do something – like promising to turn off all appliances when not in use – makes people “more likely to follow through with their planned actions.”

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How water could help make people more energy-efficient
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The energy-water connection

Unless you live near a power plant or in a place with markedly poor air quality, you probably don’t think about how your own energy use can have a direct impact on the environment.

But what if you tied electricity to something more personal, like water?

I live in Austin, and my water comes from the Highland Lakes, a group of manmade reservoirs from the Colorado River just outside the city. I spent every summer as a kid swimming and boating in Lake Travis, part of the Highland group. In the worst year of the Texas drought, the beautiful Lake Travis looked like a mud pit. Businesses and marinas closed because the water no longer made it to what had been the shore. I’ll never forget how that lack of water made me feel, and it still inspires me to use water wisely. 

Connecting water to power could sway more people into thinking about how they use energy. Traditional power resources – like coal, natural gas, and nuclear – require a significant amount of water to produce energy: It takes an average of 21 gallons of water to produce one kilowatt-hour of electricity. The average American uses about 900 kWh per month – that’s nearly 19,000 gallons of water per person per month just for electricity! So, every time you turn your lights on, you might as well be turning on the faucet, too. If electric utilities made that connection to customers or policymakers, it could make the reality of our energy behavior more tangible.

Energy efficiency is a great way to reduce customers’ bills, save water, and lower pollution. But if utilities want people to take advantage of their energy efficiency programs, the new study from Pacific Institute for Climate Solutions and ACEEE suggests they should consider strategic tactics and messengers when delivering the critical details surrounding efficiency. One way to enhance engagement could be by emphasizing the inextricable link between energy and water, and helping people understand where their water comes from.

How you use electricity in your own home is a personal decision, but having a deeper knowledge of the impacts of those choices could lead to less energy and water waste – and healthier air for us all.

Photo source: iStock/nicolas_

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By Daniel Zavala-Araiza

As part of our landmark 16-study series and ongoing work in measuring methane emissions, we previously published a paper that compared and reconciled top-down (airborne-based measurements ) with bottom-up (emissions inventory, using ground-based measurements) emissions.

This paper found that 1% of natural gas production sites accounted for 44% of total emissions from all sites, or 10% of sites 80% of emissions; emission estimates were based on facility-wide (site-based) measurements. Sites or equipment that produce disproportionate shares of total emissions are often called “super-emitters”. A big question that remained was what caused some sites to become a super-emitter; this remained a “black box” without additional knowledge about which components or operational conditions within a site could trigger the high-emissions.

In a paper published today in Nature Communications, we zero-in or “open the black boxes” to understand and characterize super-emitters. We look at the emissions from all the equipment and operations present at production sites, and ask which ones could produce emissions at a magnitude and frequency indicative of the expected super-emitting behavior.

Crucially, this new paper compares site-based emission estimates to component-by-component aggregations of sources of emissions from production sites. We find that this new component-based emissions estimate is significantly lower (one third) than the site-based estimate previously reported in the Barnett synthesis study (where this site-based estimate agreed with the flyover estimate).

It’s important to note that while the study took place in the Barnett because of the rich data sets available, this behavior is expected across the US (and even internationally).

By examining this discrepancy, here are three things we learned about methane waste:

1. Component-based estimates do not explain enough high-emitting sites. From this we learn that some components or activities at production sites are causing wasteful emissions that are not accounted for in current emission inventories. The insufficient contribution from the components or operations that can produce high emission rates when operating “as designed” is indicative of the existence of abnormal process conditions (such as malfunctions or equipment issues) that create pathways for substantial unintended emissions of produced gas.
2. Routine operating conditions do not explain high-emitting sites. We can now hypothesize that not only is gas escaping, but when and from which sites is constantly changing.
3. And frequent, or continuous, site-level monitoring is required to help us find and reduce waste from super-emitters.

Further Discussion

Because our new work tells us that super-emitter sites are characterized by abnormal behavior that is unlikely to persist indefinitely, we expect that different sites will be in the high-emitting group at different points in time. Industry claims that most super-emitters are sites with liquid unloadings or tank flashing, but these routine operating conditions do not explain the number of high emitting sites at any moment in time. Our new work tells us that these emissions are coming from unintended malfunctions throughout natural gas development and production.

Additionally, the EPA’s Inventory, which is based on component-level emissions data, is significantly lower than actual methane emissions, due to the omission of super-emitter data from production sites.

Specific sites could be affected by abnormal conditions resulting in their being a super-emitting site at varying points in time. As a consequence, rather than looking to control emissions from a few sites, minimizing emissions requires monitoring approaches that enable efficient and timely responses to the unpredictable nature of when and where a super-emitter will be located.

Current standards for intermittent methane leak detection and repair will continue to miss many of these super-emitting sites. We must have an effective program to continuously monitor for methane waste.

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By Jonathan Camuzeaux

New Risky Business Report Finds Transitioning to a Clean Energy Economy is both Technologically and Economically Feasible

In the first Risky Business report, a bi-partisan group of experts focused on the economic impacts of climate change at the country, state and regional levels and made the case that in spite of all that we do understand about the science and dangers of climate change, the uncertainty of what we don’t know could present an even more devastating future for the planet and our economy.

The latest report from the Risky Business Project, co-chaired by Michael R. Bloomberg, Henry M. Paulson, Jr., and Thomas F. Steyer, examines how best to tackle the risks posed by climate change and transition to a clean energy economy by 2050, without relying on unprecedented spending or unimagined technology. The report focuses on one pathway that will allow us to reduce carbon emissions by 80 percent by 2050 through the following three shifts:

1. Electrify the economy, replacing the dependence on fossil fuels in the heating and cooling of buildings, vehicles and other sectors. Under the report’s scenario, this would require the share of electricity as a portion of total energy use to more than double, from 23 to 51 percent.
2. Use a mix of low- to zero-carbon fuels to generate electricity. Declining costs for renewable technologies contribute in making this both technologically and economically feasible.
3. Become more energy efficient by lowering the intensity of energy used per unit of GDP by about two thirds.

New Investments Will Yield Cost Savings

Of course, there would be costs associated with achieving the dramatic emissions reductions, but the authors argue that these costs are warranted. The report concludes that substantial upfront capital investments would be offset by lower long-term fuel spending. And even though costs would grow from $220 billion per year in 2020 to $360 billion per year in 2050, they are still likely far less than the costs of unmitigated climate change or the projected spending on fossil fuels. They’re also comparable in scale to recent investments that transformed the American economy. Take the computer and software industry, which saw investments more than double from $33 billion in 1980 to $73 billion in 1985. And those outlays continued to grow exponentially—annual investments topped $400 billion in 2015. All told, the United States has invested $6 trillion in computers and software over the last 20 years.

This shift would also likely boost manufacturing and construction in the United States, and stimulate innovation and new markets. Finally, fewer dollars would go overseas to foreign oil producers, and instead stay in the U.S. economy.

The Impact on American Jobs

The authors also foresee an impact to the U.S. job market. On the plus side, they predict as many as 800,000 new construction, operation and maintenance jobs by 2050 would be required to help retrofit homes with more efficient heating and cooling systems as well as the construction, operation and maintenance of power plants. However, they would be offset by a nearly 34 percent loss in the coal mining and oil and gas sectors, by 2050, mainly concentrated in the Southern and Mountain states. As we continue to grow a cleaner-energy economy, it will be essential to help workers transition from high-carbon to clean jobs and provide them with the training and education to do so.

A Call for Political and Private Sector Leadership

Such a radical shift won’t be easy, and both business and policy makers will need to lead the transition to ensure its success. First and foremost, the report asserts that the U.S. government will need to create the right incentives.  This will be especially important if fossil fuel prices drop, which could result in increased consumption.  Lawmakers would also need to wean industry and individuals off of subsidies that make high-carbon and high-risk activities cheap and easy while removing regulatory and financial barriers to clean-energy projects. They will also need to help those Americans negatively impacted by the transition as well as those who are most vulnerable and less resilient to physical and economic climate impacts.

Businesses also need to step up to the plate by auditing their supply chains for high-carbon activities, build internal capacity to address the impacts of climate change on their businesses and put internal prices on carbon to help reduce risks.

To be sure, this kind of transformation and innovation isn’t easy, but the United States has sparked technological revolutions before that have helped transform our economy—from automobiles to air travel to computer software, and doing so has required collaboration between industry and policymakers.

We are at a critical point in time—we can either accelerate our current path and invest in a clean energy future or succumb to rhetoric that forces us backwards. If we choose to electrify our economy, reduce our reliance on dirty fuels and become more energy efficient, we will not only be at the forefront of the next technological revolution, but we’ll also help lead the world in ensuring a better future for our planet.

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