The end of one year always invites predictions about the next. In the spirit of the season, we asked leaders from each of PM Environmental’s service lines to offer their views on the year to come.
Of course, no one at PM has a crystal ball. What we do have is deep knowledge and extensive contacts in the industries we have served for more than 25 years. Ranked the #1 environmental consulting and engineering services company in Michigan and one of the top 20 in the U.S. by EDR ScoreKeeper™, PM continues to grow and expand to meet the evolving needs of our customers.
The Economy and the Business Climate
The outlook for 2020 remains positive for the manufacturers, petroleum retailers, real estate developers and lenders PM serves. These segments of the economy are still creating opportunities to invest, expand, develop and redevelop.
Along with those opportunities, we anticipate plenty of competition for commercial financing and environmental incentives. To stay competitive and hedge against an unforeseen bump in the economic road, we also expect the trend toward consolidation, mergers and acquisitions to continue.
Hot Topics in Environmental Regulation
Much of the regulatory conversation continues to focus on the environmental impact of perfluoroalkyl and polyfluoroalkyl substances, or PFAS.
Science, politics, information and speculation continue to swirl around PFAS, which is categorized as an emerging contaminate. That term is somewhat misleading. For decades PFAS was widely used (and in some cases required) in multiple industrial applications. What’s still emerging or evolving is the science needed to quantify the health risks of PFAS.
The current EPA guidelines recommend a maximum PFAS level in drinking water of 70 parts per trillion – a remarkably strict standard compared to just five parts per billion for another established carcinogen, benzyne. The EPA acknowledges that the current recommendation could overestimate or underestimate the lifetime risk of PFAS exposure by a factor of 90,000. More definitive toxicology studies are underway, but results are still years away.
Until the science catches up, regulators will do their best to protect public health and safety, and businesses and municipalities – with the help of PM Environmental – will do their best to comply with a patchwork of differing state programs enforcing the current guidelines.
Like PFAS, vapor intrusion regulations vary by region. Rust belt states, with a longer history of dealing with vapor issues, generally have more established programs. Other states tend to defer to the EPA for enforcement. PM is engaging with clients and regulators around the country, sharing our experiences to improve protocols and compliance.
ASTM E1527 Standard
The American Society for Testing and Materials (ASTM) E1527 is the Standard Practice for the completion of Phase I Environmental Site Assessments (ESAs). The current E1527 Phase I ESA standard is up for renewal and is being evaluated by the ASTM E1527 task group, which includes environmental professionals, attorneys, bankers and other related industry professionals. The task group has been meeting regularly since 2018 to strengthen the current standard, which is due to be published in January 2021. Expected updates will clarify requirements and provide further guidance to environmental professionals improving the Phase I ESA process. Stay tuned for more information in 2020.
The EPA brownfield cleanup program always merits attention. While no changes are anticipated in 2020, a sustained effort is needed to make Congress aware of the program’s many success stories to ensure that grant funding continues.
Underground Fuel Storage Tank Maintenance
An issue of growing concern in the retail petroleum industry is the skyrocketing cost of maintaining underground fuel storage tanks.
The problem stems from chemical properties of fuel alternatives like ethanol and ultra-low sulfur diesel (ULSD), developed to meet emission standards of the Clean Air Act. On a molecular level, ethanol is an oxygenate that attracts water, allowing bacteria to grow. Bacterial growth creates an acidic condition that accelerates the development of rust in the tank system. The lower sulfur content of ULSD also promotes bacterial growth, even breaking down fiberglass tanks.
Gas station owner/operators currently bear the entire cost burden of maintenance, which can be significant. One large east coast chain estimates that their tank maintenance volume has grown from four tanks per year to 40 per quarter.
The industry is now documenting the problem as a first step in driving a response. PM is keeping a close watch on this emerging issue.
Your Best Moves for 2020 – and How We Can Help
Think ahead. The market for environmental grant funding is competitive – get in early. Even if your construction project has a 2021 start date, it’s not too soon to talk to us about environmental incentives.
You may have no plan to sell a business or property, but in a good economy an unsolicited offer may come your way. Let us update your environmental compliance status so you’ll be ready with answers if opportunity knocks.
Dive deeper. If you’re considering purchasing a property, don’t just kick the tires. Partner with PM to look under the hood. Environmental compliance issues are more complex and interrelated than ever. With experts in every discipline, we don’t stop with identifying issues. We can assemble custom teams to design, engineer and implement comprehensive solutions across service lines.
Get creative. In today’s competitive financing market, creative solutions win the day. That includes working with multiple lenders and taking advantage of every available incentive – even non-environmental incentives like new market tax credits and opportunity zones. In 2019, PM helped clients access more than $100 million in incentives. We can help you.
It also pays to think out of the box about due diligence. Some clients assume a Phase 1 ESA is required in every circumstance. But for situations like refinancing an existing property, we may be able to offer other tools that can get you across the finish line sooner.
Happy Holidays and Happy New Year from PM Environmental. Call on us for comprehensive service and innovative solutions for whatever challenges 2020 brings.
PM Environmental contributors to this article include Jon Balsamo, Jessica DeBone, Kristin Gable, John Hargraves, Mike Kulka, Adam Patton, Steve Price, Beth Sexton and Greg Stephenson.