Recently, Elm posted a piece discussing comments from Kevin Parker, the CEO of Deutsche Asset Management, an investment firm with three-fourths of US$1 trillion under management. We expanded that original post for EHS Journal, who just published it. The expanded … Continue reading →
The Elm Consulting Group International LLC, a specialty health, safety, environmental and sustainability (HSES) management consulting firm, is pleased to announce the addition of Joseph B. Cotier, CPEA as a Director of the firm beginning January 3, 2011. “Joe brings 22 years experience in HSE auditing excellence and client focus to our team” said Patrick Doyle, Elm’s founder and Managing Director. “He is a perfect complement to the firm.” “I have known Joe personally and professionally for close to 20 years and know first hand about his expertise and exemplary qualifications. We are very excited to have him become a part of Elm” said Robert Bray, Elm Co-Founder and Managing Director. Cotier said, “I am happy to be a part of Elm and look forward to continuing to have a positive impact on the HSE auditing field – driving innovation both in the US and across the globe.” Joseph B. Cotier, CPEA, has completed more than 350 EHS audits and management systems consulting projects in more than 35 states and 20 countries. He has experience in a wide range of industries including petroleum refining and chemical manufacturing, electric utilities, breweries and consumer and pharmaceutical products manufacturing. Mr. Cotier is an
Read more →Yesterday, the world’s largest retailer and its cadre of sustainability advisors released the 61-page Walmart Supplier GHG Innovation Program: Guidance Document. Elm has read through this document and provides a brief overview of what we think are several important points. What follows is a combination of excerpts from the document combined with Elm comments. Not all of these points are implementation “how-to’s”. Some of our comments reflect potential problems that should be evaluated by suppliers who are impacted by Walmart’s supplier sustainability initiatives. The program will initially focus on the following product categories: Animal feed, apparel, candy, cheese, frozen food, fruit, grains, household detergents, meat, media, milk, motor oil, pharmaceuticals, produce, sanitary paper products, snacks, soap & shampoo, soft drinks & beverages, televisions, and vegetables. GIVING CREDIT WHERE CREDIT IS DUE (TO WALMART) In past articles, Elm discussed our view there is a true business risk – rather than competitive advantage – to first-mover adoption of GHG reduction programs. We had anticipated that such risk would be rooted in regulatory requirements. While that may still be a concern in the longer term, it appears now that the more significant risk relates to Walmart suppliers. The retailer has specified that no
Read more →NYT reports that Washington has abandoned hope of issuing carbon legislation this year, including cap-and-trade. The inaction is also dragging down regional/state programs as well, including the well-hyped RGGI trading program. This shouldn’t come as a real surprise to anyone. But it does continue to increase the business uncertainty surrounding emissions in the US. Tune in again next year. Or the year after….
Read more →In the wake of EPA Region 6’s recent decision to overturn TCEQ-issued air permits for 40 companies, EPA fired another shot at The Alamo. The EPA is offering Texas companies with the approximately 130 affected air permits the opportunity to have third party audits conducted with a promise of enforcement leniency in exchange. The pre-publication version of the announcement is posted at EPA Region 6 website here, as well as the 30-page agreement that audit participants must execute with EPA. Noteworthy aspects of the agreement include: - Highly prescriptive requirements for third party auditor independence and report certification - Detailed requirements for the scope of the audit - Audit report content, format and submission requirements – including taxonomy for supporting document attachments - Mandates and specifications for emissions-related Community Projects to be entered into by the audit participant and approved by EPA - Separate specifications for the NSR portion of the audit and related report - The model Consent Agreement and Final Order (CAFO) Companies interested in participating in the audit program should conduct a thorough review – with legal counsel – of the language contained in the agreement and CAFO documents. Although we at Elm are not lawyers and
Read more →The Associated Press says that EPA will prevent the Texas Commission on Environmental Quality (TCEQ) from issuing an air emissions permit for the Flint Hills (Koch Industries) Refinery in Corpus Christi. The permit will be issued directly by EPA and is likely to contain substantive differences from the permit proposed by TCEQ. Further, by June 30 EPA will invalidate 39 more air emissions permits affecting 140 plants in Texas as a result of a dispute between EPA Region 6 and the TCEQ. Al Armendariz, [EPA Region 6 Administrator] said the EPA will issue its own permit for the independently owned Flint Hills Corpus Christi East Refinery, and in the coming days begin to do the same for 39 other plants, including facilities owned by Exxon Mobil Corp., Chevron Corp., ConocoPhillips and Dow Chemical Co. The EPA objected to 40 permits issued by Texas late last year, Armendariz said, partly because they included so-called “flexible permits” that the agency says allow the industry to emit more pollutants than allowed under the federal Clean Air Act. Texas created its flexible permit system in 1994, but it was never officially approved by the EPA. AP further stated that at least five years [may be
Read more →Our last entry discussed the concept of “Black Swan” events, a term created by noted author Nassim Nicholas Taleb to describe an event that is (a) so low in probablility that it is unforeseeable and (b) so catastrophic in impact that it changes history. Certainly, risk assessments are predictive in nature and no one can predict the future with complete certainty. But in our view, one of the best tools available for risk assessments is an open mind. This can be a challenge in the EHSS world as we generally have engineering and other technical backgrounds. We have been trained to seek absolutes and eliminate uncertainties. At Elm, we believe that involving external support helps to identify and explore events (and their related exposures) that are relevant but get “technically rationalized” by internal staff. With the BP oil spill and the December 2008 Kingston, Tennessee coal ash pond failure, we began thinking about some of the Black Swan events discussed with clients in the past. Below are a handful of EHSS Black Swan risk events that we have discussed with clients over the past years – and some that are currently on our mind. Radical change in EPA’s regulation of coal
Read more →Bloomberg.com reported that earlier this week, European authorities launched a major investigation of several large companies that are thought to have played a role in a system of fraud and tax evasion that may have impacted 7% of the total CO2 emissions trading market for 2009 in the EU. Prosecutors and tax investigators yesterday searched Deutsche Bank, HVB Group and RWE AG in a raid on 230 offices and homes to investigate 180 million euros ($238 million) of tax evasion. The probe targeted 150 suspects at 50 companies… Yesterday’s raids were the biggest related to a fraud that may have tainted an estimated 7 percent of European Union carbon trades in 2009… About 400 million metric tons of emission trades may have been fraudulent last year, or about 7 percent of the total market, including futures transactions, according to estimates from Bloomberg New Energy Finance. Europe lost about 5 billion euros in revenue for the 18 months ending in 2009 because of value-added tax fraud in the CO2 market, according to Europol, a European law-enforcement agency.
Read more →Last night (April 20, 2010), CNBC aired an hour-long TV segment on the burgeoning industry labeled “carbon hunting”, the practice of finding, aggregating, marketing and selling carbon credits. While the story illustrated successful projects, it also highlighted a myriad of risks in the carbon trading industry. Check your local TV listings for the next airing.
Read more →Sure, there are some business risks that are readily identifiable to conform to the SEC’s Climate Risk Assessment Interpretive Guidance. Things like: Property damage from storms and sea level changes Increased costs related to new pollution controls and fuels Changes in customer procurement requirements. But read about the supply chain constraint that the UK energy company E.ON brought forward in a Reuters report: Lack of investment in the vessels used to build offshore wind farms could hinder Britain’s ambitions to shift to renewable energy, the head of E.ON UK’s Robin Rigg wind project told Reuters at the operations center in Workington, northwest England. Britain aims to install 32 gigawatts (GW) of offshore wind by 2020, enough to meet a quarter of the country’s electricity needs, and although there has been investment in turbines factories and ports, a lack of vessels could curtail targets. “The targets are very ambitious and the supply chain isn’t there for it to materialize. It definitely has to grow,” Ian Johnson, Robin Rigg offshore wind farm project manager said. “Aside from turbines, vessels to install equipment are expensive,” said Johnson adding that a lack of predictability over upcoming wind farm projects in the past had caused
Read more →
Follow Us!