Seasonal Wind Speed Drops, Solar Generation Drops, and Low Hydro Output Lead to Rise in Natural Gas Share of Power in Germany

      Germany is currently burning natural gas at 2019 rates of 19% of the total share of electricity due to seasonal reductions in wind speeds, seasonal solar reductions, and low hydro output. The low wind output is the main issue since solar reductions are more certain and easier to account for. Germany’s wind plus hydro output together dropped 7% from last year’s January to October period. For the same period, natural gas use climbed 15%. Irina Slav for Oil Price US notes that the drop in wind output is despite new wind projects coming online earlier in the year. A July article in Clean Energy Wire notes that new wind additions consisted of:

 “…409 newly constructed turbines with a combined capacity of 2.2 gigawatts (GW).”

     In the same period last year, wind and hydro accounted for 34% of the generation share, but this year it is down to 31%. Coal output is also up by 4%. Energy by source is shown below for the 10-month period.

     The next graph shows the power generation mix by output and percentage, respectively, from 2022 to the present. One can see the phase-out of nuclear, the continued prevalence of coal, mostly high-emissions lignite coal, which hit 30% of total grid power last winter, and the relatively small contribution of hydro.

     Below is shown the last four seasons of the combined output of wind plus hydro generation.

     Germany has had to diversify away from pipelined Russian gas at a huge financial cost. The country’s gamble to deal with Putin failed them. They now must import LNG at much higher prices than they would have gotten the Russian gas. However, they put in place the means to do that.

     Germany hosts about 25% of Europe’s gas storage capacity. The increased natural gas use has cut into the country's gas storage inventories, which are now at 75.24% of capacity, according to data from Gas Infrastructure Europe, as reported by Slav. ( I think the 86% on the graph below may have to due with a storage capacity of greater than 100% used for calculation, but I don't know why). Europe as a whole is 13.5% lower in gas storage than the average for this time of year. One concern is that Germany and the EU will be exposed to power price volatility when winter hits.

     Germany’s near-term wind forecasts suggest that the wind output will remain low for the rest of the month, then increase back to normal output for the remainder of the winter.

 

References:

 

Germany Burns More Gas as Renewables Falter Ahead of Winter. Irina Slav. Oil Price US. November 5, 2025. Germany Burns More Gas as Renewables Falter Ahead of Winter

Germany's higher gas use hampers Europe's stockpiling drive. Gavin Maguire. Reuters. November 5, 2025. Germany's higher gas use hampers Europe's stockpiling drive | Reuters

Renewables share slightly down in Germany in first half of 2025, but wind expansion gains steam. Benjamin Wehrmann. Clean energy Wire. July 15, 2025. Renewables share slightly down in Germany in first half of 2025, but wind expansion gains steam | Clean Energy Wire

 

 

 

The EU Corporate Sustainability Due Diligence Directive and the Carbon Border Adjustment Mechanism (CBAM): The Good, the Bad, and the Ugly

     EU regulatory control is once again leading to companies threatening to pull out of doing business with the union. One might see the disruptive effect somewhat similar to that of Trump’s tariff wars. I am referring to the EU Corporate Sustainability Due Diligence Directive (CSDDD). This rule makes it much harder for some foreign companies to do business in the EU. It essentially puts a tariff or tax on emissions and on behavior regarding environmental, labor, and human rights issues.

     This post is mainly about the CSDDD but also about the EU’s overly ambitious decarbonization regulations, which include CBAM. Thus, I will focus briefly first on CBAM.  

 

Carbon Border Adjustment Mechanism (CBAM)

     CBAM has been in effect since 2023, when its Transitional Phase began, requiring importers of certain carbon-intensive industries, such as steel and cement, to report emissions. Beginning on January 1, 2026, is the Definitive Phase, which will require importers to purchase CBAM certificates, which will be utilized in the EU Emissions Trading System (ETS). While importers pay for the certificates, those costs are passed to the exporters by requiring low-carbon and decarbonized products, which entail extra costs to produce. Thus, the degree to which a product is decarbonized relative to the non-decarbonized version is one parameter in emissions mitigated, the metric for which is usually CO2equivalent. The EU has done this with natural gas with the EU Methane Regulation (MER), effective August 2024, by requiring exporting companies to report upstream and midstream methane emissions, the biggest source of emissions of natural gas before combustion. Importers are expected to comply with Monitoring, Reporting, and Verification (MRV) requirements. I believe most of the natural gas in the U.S. and an even larger amount of U.S. LNG exports meet those requirements. The rule is sure to meet with some challenges when the Definitive Phase goes into effect in less than 2 months. CBAM is designed to ensure that all production, exports, and imports are subject to some sort of carbon price that they can then exchange on the ETS.  

 

The EU Corporate Sustainability Due Diligence Directive

     This rule, or directive, is designed to initiate the practice of human rights, social, and environmental due diligence. It is considered to be an ESG directive, though really more of an ES directive that seeks to have companies collect and report policies, emissions data, and other parameters. The intentions of the directive seem to be simply to ensure that countries and companies are doing all they can to be sustainable. However, I think a hierarchical approach to each part: labor rights/human rights, environmental impact, and greenhouse gas emissions, would be better. If an exporter has suspected or documented labor rights or other human rights issues, that is a more immediate potential for harm than greenhouse gas emissions. Thus, it should be more important in such a directive. The U.S. has shown this by sanctioning the Chinese for forcing workers making solar panels and other products at Chinese Uyghur re-education work camps, where workers are essentially enslaved.     

     The due diligence process involves the following six steps:

(1) integrating due diligence into policies and management systems; (2) identifying and assessing adverse human rights and environmental impacts; (3) preventing, ceasing or minimising actual and potential adverse human rights and environmental impacts; (4) monitoring and assessing the effectiveness of measures; (5) communicating and (6) providing remediation.

     It seems that a big part of the directive is the requirement to share information. One question is whether companies have the information at the level of detail required.  

(40) To comply with due diligence obligations, companies need to take appropriate measures with respect to the identification, prevention, bringing to an end, minimisation and remediation of adverse impacts, and the carrying out of meaningful engagement with stakeholders throughout the due diligence process.

     I think that the rule would have better focused on just human/labor rights and environmental impact and excluded climate and greenhouse gas emissions. Many greenhouse gas emissions directives retain a voluntary nature and are considered non-binding. In any case, I think it would have been better addressed separately.

(73) This Directive is an important legislative tool to ensure corporate transition to a sustainable economy, including to reduce the existential harms and costs of climate change, to ensure alignment with ‘global net zero’ by 2050, to avoid any misleading claims regarding such alignment and to stop greenwashing, disinformation and fossil fuels expansion worldwide in order to achieve international and European climate objectives. In order to ensure that this Directive effectively contributes to combating climate change, companies should adopt and put into effect a transition plan for climate change mitigation which aims to ensure, through best efforts, that the business model and strategy of the company are compatible with the transition to a sustainable economy and with the limiting of global warming to 1,5 oC in line with the Paris Agreement and the objective of achieving climate neutrality as established in Regulation (EU) 2021/1119, including its intermediate and 2050 climate neutrality targets.

     One statement of concern is the stated goal to oppose fossil fuel expansion, something Europe is currently doing to replace Russian gas, oil, & coal. Germany also, a few years ago, ramped up coal production and firing for the same reason as well as its de-nuclearization push.

“…to stop greenwashing, disinformation and fossil fuels expansion worldwide in order to achieve international and European climate objectives.”

     There are geopolitical concerns and other human welfare concerns, like affordable energy, reliable energy, competing needs for government money, and permitting expediency for the timely completion of vital projects.

     Looking over the directive, it seems at times unnecessarily complex. Requiring companies to submit detailed energy transition plans is a bit much and notoriously difficult for fossil fuel companies in particular because they don’t know what oil, gas, and coal demand will be in the future. I’m sure they don’t want to write ‘rosy future’ decarbonization plans and then be unable to finance them, while EU regulators are trying to hold them to it. In recent times, Oil Majors have had to pull back chunks of their decarbonization developments due to cost and lack of profitability compared to oil & gas. Requiring Paris Agreement-level (non-binding) commitments for companies is not good as the 1.5 °C scenario is not achievable, and really it never was. The directive calls for time-bound decarbonization pathways, which, again, for fossil fuel companies, are dependent on market demand for their products.

     Really, my main objection to the directive is the inclusion of too detailed emissions-reduction plans that may not be feasible and the penalties for non-compliance, which could be fines of 5% of their annual global revenues. The human rights, labor rights, and environmental issues seem to be generally reasonable.     

 

The U.S. and Qatar are Leading Opposition, but Many Countries Oppose the Directive

     ExxonMobil CEO Darren Woods noted recently that the hefty fines for non-compliance could result in the company ceasing work in the EU. He has strongly criticized the legislation and noted at a conference in Abu Dhabi:

“If we can't be a successful company in Europe, and more importantly, if they start to try to take their harmful legislation and enforce that all around the world where we do business, it becomes impossible to stay there.”

     After pressure from companies around the world, the European Parliament agreed in October to review the regulation. Exxon, the U.S., and Qatar want big changes. Energy Secretary Chris Wright says it may affect the U.S.-EU trade agreement.

     Qatar has taken issue with the Paris Agreement/1.5 °C requirements and has threatened to turn to other markets for its EU-bound LNG exports. Qatar currently supplies 12-14% of the EU’s LNG. They proposed that the CSDDD remove the section mandating climate transition plans. I agree with this. Qatar has also been accused of having an unfair migrant labor system of low-paid workers and has also been accused of human trafficking and slavery. The country’s legal system is based on Sharia law. They should be required to adhere to fair and just labor standards and human rights. The Qataris, however, have only complained about the unfair emissions requirements and the unfair costs of non-compliance.   

The European Commission has proposed simplifications of the directive, including delaying its launch to mid-2028 and reducing supply chain checks.         

 

References:

 

Corporate sustainability due diligence: Fostering sustainable and responsible corporate behaviour for a just transition towards a sustainable economy. EU Commission. July 25, 2024. Corporate sustainability due diligence - European Commission

ExxonMobil Threatens To Leave EU Over Sustainability Rules. Tsvetana Paraskova. OilPrice.com. November 3, 2025. ExxonMobil Threatens To Leave EU Over Sustainability Rules  

DIRECTIVE (EU) 2024/1760 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. of 13 June 2024. on corporate sustainability due diligence and amending Directive (EU) 2019/1937 and Regulation (EU) 2023/2859. (Text with EEA relevance). Official Journal of the European Union. Directive - EU - 2024/1760 - EN - EUR-Lex

Carbon Border Adjustment Mechanism: The EU’s environmental policy tool for fair carbon emissions pricing. European Commission. Carbon Border Adjustment Mechanism - Taxation and Customs Union

EU Methane Regulation and its impact on LNG imports Open Access. Kim Talus, Gunnar Steck, James Atkin. The Journal of World Energy Law & Business, Volume 18, Issue 1, February 2025. Published: 15 October 2024. EU Methane Regulation and its impact on LNG imports | The Journal of World Energy Law & Business | Oxford Academic

Qatar warns of EU gas supply cuts over new sustainability law. Offshore Technology. July 28, 2025.

 

The Growing Freshwater Footprint of Industry: Effects Vary by Location

 

     Industry uses a lot of water. A new study shows growing demand for freshwater in industries producing steel, cement, paper, plastics, and rubber. One might add oil, gas, chemicals, thermal power plants, and many other industries to the list. These industries may stress water balances in areas where water is scarce, and they also produce wastewater of different levels of potential toxicity. Agriculture remains the top user of freshwater, but industrial freshwater use is growing.

“The work assesses the "blue water footprint" (WFblue)—the freshwater drawn from rivers and aquifers—of 16 key metallic and non-metallic materials across 164 countries and regions between 1995 and 2021.”

     The study, by researchers at Reichman University in Israel, focused on the water footprint of materials production, specifically of steel, cement, paper, plastics, and rubber. They found that the global freshwater footprint for producing these materials doubled from 25.1 billion cubic meters in 1995 to 50.7 billion cubic meters in 2021. East and South Asia and Oceania saw the steepest rise, with water footprints surging by 267%. The paper was published in Nature Sustainability.

     The study highlights the need for regions with water scarcity to manage industrial water usage:

“Professor Heming Wang, from the State Environmental Protection Key Laboratory of Eco-Industry, Northeastern University, and a co-author of the study, emphasized the broader environmental and industrial context, stating, "Our analysis shows that managing water efficiently is not only an environmental necessity but also an industrial imperative. In rapidly developing economies, improving water productivity in material manufacturing can deliver both ecological and economic benefits. Integrating water efficiency into industrial planning is now essential to ensure sustainable growth."

     Of the materials assessed, steel production had the highest water usage, accounting for 40%, followed by paper at 18% and plastic at 9%. Aluminum and cement production had lower water footprints. They also found that OECD countries reduced their WFblue by 11%, but East and South Asia and Oceania accounted for more than two-thirds of global use by 2021. China has the highest industrial freshwater use, and it will be imperative for the country to manage it better.

     I will note that freshwater withdrawal is often a regional issue, since water abundance or scarcity varies by region. Regions vary in the availability of both surface water and groundwater. Water quality may also vary by region and conditions particular to a region.  

 

 

References:

 

Global study reveals soaring freshwater demand in material production. by Reichman University. edited by Stephanie Baum, reviewed by Robert Egan. Phys.org. November 3, 2025. Global study reveals soaring freshwater demand in material production

Doubling of the global freshwater footprint of material production over two decades. Yao Wang, Fengmei Ma, Heming Wang, Asaf Tzachor, Meng Jiang, Kai Fang, Sai Liang, Bing Zhu, Edgar G. Hertwich, Manfred Lenzen, Heinz Schandl & Stephan Lutter. Nature Sustainability (October 30, 2025). Doubling of the global freshwater footprint of material production over two decades | Nature Sustainability

 

 

Pipeline Inspectors Working in NYC and Westchester County Charged with Faking Hundreds of Weld Inspections Between 2016 and 2023, Compromising Community Safety

     This post is just a news story about pipeline inspectors faking weld tests. It shows that people working for some companies do not care about what they do, whether it is accurate or not, which is a bit dumbfounding, especially in a safety-oriented job such as inspecting a pipeline. Distribution pipelines leak and lead to explosions, although they are mostly the older and aging ones.

     The two inspectors were arrested and charged with federal wire fraud over the fraudulent inspections, where they simply submitted the same picture for multiple welds, without actually inspecting each weld. The fabrications covered hundreds of inspection reports between 2016 and 2023, where they faked inspections by submitting inaccurate pictures and faked paperwork. 

“The indictment alleges the men engaged in a practice known as “radaring,” in which radiographic images of a single weld were reused and passed off as inspections of additional welds. These falsified tests were submitted as invoices, which the utility paid.”

“Federal prosecutors said the scheme compromised safety by bypassing inspections designed to detect defects that could lead to gas leaks or explosions.”

     The U.S. Attorney’s Office in White Plains, NY, is handling the case with assistance from the New York State Inspector General’s Office.

     It makes me wonder what motivates this kind of work behavior. Easy money, I suppose, is a major factor. Employees in these types of jobs should be made aware of their responsibilities for accuracy and especially of the consequences of fraudulent work. If the practice is widespread enough that it has a name, it seems that there is a very real problem with it. It is fraud, plain and simple, and cannot be justified.

     According to the U.S. Attorney’s Office, Southern District of New York:

“One common form of non-destructive testing of pipeline welds involved radiographs, often referred to as x-rays.  Radiographic testing required a team to radiograph each weld and then examine the films to identify any defects in the welds.  If a defect was identified, then the weld would have to be repaired before the pipeline was put into service.  Failure to repair a defect before a pipeline was put into service could have led to critical failures, including gas leaks or explosions.”

 

 

   

References:

 

Inspectors charged with faking gas pipeline safety tests in New York. Underground Infrastructure. August 29, 2025. Inspectors charged with faking gas pipeline safety tests in New York | Underground Construction

Safety Inspectors Charged With Fabricating Hundreds Of Gas Pipeline Test Results Throughout New York City And Westchester. U.S. Attorney’s Office, Southern District of New York. August 28, 2025. Southern District of New York | Safety Inspectors Charged With Fabricating Hundreds Of Gas Pipeline Test Results Throughout New York City And Westchester | United States Department of Justice

 

Rystad Energy: Executive Summary: Global Energy Scenarios 2025. The next energy era: Summary and Review

     This is the fourth edition of Rystad’s flagship Global Energy Scenarios report. The forward, written by Jarand Rystad, acknowledges that we have moved to a hybrid energy system of renewable and fossil energy sources. He gives the three basic energy transition tasks: 1) decarbonize the power sector; 2) electrify everything possible; and 3) address the residual emissions. Different countries are on different parts of the pathway, some far along, others just beginning. He also notes that countries with endowments like hydropower, such as the Nordic countries and Canada, have a head start on decarbonization. France has a well-developed nuclear sector, which also gives it an advantage. The last mile, which usually refers to decarbonizing the last 20% of the power sector, is the hardest to abate. It will rely on immature technologies like hydrogen, CCS, and biofuels.

     Rystad developed four global decarbonization scenarios. Three of them are degree scenarios to 2100, and one is a nationally determined contribution (NDC) scenario to 2035. These are described as follows: 1) a “Climate first” scenario aiming for 1.6-degrees of warming – (not likely to be realized); 2) a Pragmatic middle-road scenario aiming for 1.9 degrees of warming; 3) a Fossil-first scenario aiming for 2.2 degrees of warming; and 4) “NDC scenario takes on a lens of what the world may look like if country pledges are implemented.” Rystad utilizes its proprietary database to map global energy at asset, company, and country levels. Below are displayed the likely prevailing narratives of energy in the future.

     The next graph compares past energy transitions with the current energy transition.

     The report predicts a peak in global emissions in 2026, which is a little unexpected, I think. Some may well disagree, but Rystad has good data and analysis, so perhaps they are correct.

“Global CO₂ emissions are expected to peak around 2026 before starting a gradual decline, driven by rapid renewable deployment in power and EV adoption in transport. This marks a turning point, showing that the world is moving from growth to decline in emissions.”

     Rystad notes that its “house view” accords with its pragmatic 1.9 degree scenario. I think they are being a bit too optimistic. They acknowledge that the energy transition is not going to be linear and will vary between countries, be affected by geopolitics, protectionism, and cost considerations. Below are the scenarios.

     The next two graphs cover energy investments. The first, which goes from 2015 to 2030, shows clean energy investments overtaking oil & gas investments beginning in 2022. According to the graph, oil & gas investments will peak in 2028-2029, and grid investments will overtake oil & gas investments sometime in the early-mid 2030s.

     Asia, and particularly China, has dominated solar, wind, and battery deployments in recent years, particularly so far in 2025. Rystad notes that China is in part motivated by energy security as it must import a lot of its oil & gas.

     As the next graphs show, fossil fuels will remain in demand, with natural gas demand expected to keep rising to 2035. They have oil demand peaking from 2025 to 2029. There is much debate about that. Coal, in a demand plateau since the mid-2010s, is expected to drop off strongly beginning around 2029-2030.

     The next graph shows the energy demand mix by scenario. It shows which sources will be required to ramp up or down for each scenario.

     The next section is interesting. Here, they show all the power losses inherent in fuel-based energy sources and the superior efficiency of electrification. Of course, with that increased efficiency also comes lower energy density. They distinguish primary energy, 20% of which is lost in fuel-based sources, including refining, final energy, 30% of which is lost via combustion, and useful energy, which is the energy left over after the aforementioned losses. The increasing efficiency provided by electrification allows useful energy to grow while primary energy stays the same or drops.

     The next section is interesting as well, where they divide emissions reductions into three tasks:

Task 1: Clean up and grow the power sector

Task 2: Electrify almost everything

Task 3: Clean up the residual

     Task 1 has been and will continue to be the main decarbonization driver. Task 2 – electrification – will continue to grow, perhaps at accelerated rates. Task 3 involves steps like CCS and switching to lower-carbon fuels. They seem to think it will be mainly used to abate hard-to-abate sectors. They don’t mention natural gas replacing coal, which has been and continues to be a major decarbonization driver. Below, they calculate the emissions reduction potential for each Task in each scenario. They see overall clean energy deployment being led by Europe and electrification being led by Asia. Task 3 progress has been much slower so far, they note.  

     The next section involves its nationally determined contribution (NDC) scenario to 2035, which is mainly based on the Paris agreement’s 1.7 °C scenario, which is probably unrealistic, so no real need to focus on it. It is close to Rystad’s Climate-first scenario (1.5 °C), between it and its Pragmatic scenario (1.9 °C). Contributions by energy technology and Task for this scenario are given in the second graph.

     They predict that by 2030, renewables will provide nearly 50% of power. I have to wonder, as I often do, how much of these “renewables” is hydropower and how much is biomass. Thus, the graph below likely does not show just wind and solar but hydro and biomass/biofuels as well. Solar, in particular, has grown faster than previous estimates, which can be seen as optimistic for continued solar deployment. Battery and wind deployment are continuing to rise, but solar is leading the charge due to its better economics.

     The next section is interesting. It divides countries into three roles they have been playing in the energy transition and in clean energy deployment. The three roles are The Pathfinders – which points to early deployers setting the pace. The Scalers refers to countries that scale up, in both cases here = China. The Accelerators are countries that later take the mature tech and deploy it to scale quickly. The graph below shows solar PV deployment, with Europe being Pathfinder, China being Scaler, and the Global South being Accelerator.

     They expect power demand to grow by 37% over the next decade, or 3.7% per year. Industry power demand is expected to lead growth by a wide margin, about four times that of data centers and more than twice that of transport and residential power demand growth.

     The next section gets back to the efficiency advantages of electrification and useful energy.

“Electrification lets consumers use less energy for the same service.”

     An EV powered by a power grid powered with PV solar will be just over three times more efficient in using energy than a typical internal combustion engine vehicle.

     The next section gets back to the three Tasks and uses them to track EV growth, where Norway is seen as Pathfinder, China as Scaler, and Thailand, Costa Rica, and Uruguay as Accelerators.

     The next section addresses hard-to-abate sectors. It notes increased demand for industrial products, mainly steel and cement, but also chemical/petrochemical, shipping, and aviation. They note that abating these sectors will take a long time as economics are tough and growth continues.

     They see both hydrogen and CCS taking off in the 2030s, although I think they see too much of the hydrogen being green hydrogen than seems to be economical, at least at present.

“Overall, the market for clean hydrogen and CCUS is shifting from counting announcements to focusing on delivering capacity…”

     The next section involves replacing conventional fuels with biofuels and sustainable aviation fuels for shipping and aviation. There are some uncertainties and contingencies here. One is the International Maritime Organization (IMO)’s possible new rules set for another vote by 2027.    

 

     Overall, this was a great report with some interesting observations, perspectives, and metrics. 

References:

 

Rystad Energy: Executive Summary: Global Energy Scenarios 2025. The next energy era. October 2025. PowerPoint Presentation

Air Pollution Monitors Record Much Higher Pollution Than Estimates for Coke Plants, Chemical Plants, and More: Pro Publica Investigation Reveals Flaws in Estimating Methods and the Need for Monitoring and Fixing Leaks

     In 2023, the EPA required 20 industrial facilities to temporarily install air monitors around their perimeters — known as fence-line monitoring — to assess the accuracy of the companies’ estimates. The fence-line monitoring revealed that all of the companies were underestimating emissions, some by large amounts. Benzene was monitored at 30 times the estimated level at a coke plant near Pittsburgh, and another toxic chemical at a Louisiana chemical plant was found at a concentration 156 times the company's estimates. Clearly, there are problems with these facilities’ toxic emissions estimates, and it shows that relying on those estimates does not give an accurate measure of the pollution levels and the health risks to the local people.

“Despite industry opposition, the EPA took action last year. More than 130 industrial facilities would have to install permanent air monitors, starting as soon as this year. Communities surrounding some of the country’s most notorious polluters would finally get a glimpse of what they were breathing. The monitors would act as a warning system: If pollution levels were to exceed new standards set by the EPA, the facility would have to find the source of the leaks and fix them. In fact, among the 20 plants that were forced to conduct temporary monitoring, half would have violated these standards, ProPublica found.”   

     Of course, with the Trump administration came the initiation of environmental rollbacks, some in the form of extensions to comply and some in the form of delays of new emissions standards. Lisa Song of ProPublica noted that the EPA acknowledged:

“…a “discrepancy” between the self-reported emissions and air monitoring data. “However, we have not determined the cause of the discrepancy. We will explore this as part of the reconsideration” of the rules, the email said.

     One of the polluting facilities is the Clairton Coke Works just south of Pittsburgh, owned by U.S. Steel. It is the largest coke-making facility in the Western Hemisphere, and its ovens have been operating since 1916. The coke ovens utilize high temperatures to convert the coal to coke. Coke plant hazardous emissions include the benzene mentioned earlier, particulate matter (soot), and sulfur compounds. I wrote in more detail in 2023 about coke plant pollution. Temperature inversions in the hilly region sometimes cause the pollutants to accumulate closer to the ground into a hazy smog. Coke is later used to melt iron ore for steelmaking and smelting. The plant had a fire in 2018 that caused poor air quality and a spike in emergency room visits for asthma. 

     More recently, in August 2025, there was an explosion at the plant that killed two workers. It is expected that the plant will be fully back online when the burned section comes fully back online early in 2026. Preliminary investigations indicate the explosion was caused by pressure building inside a gas valve that caused the valve to fail.  

     Song writes that the process for estimating emissions is difficult at the Clairton Works due to the many pipes and valves at the plant:

“Industrial companies are required to report their emissions to the EPA, but it’s not an easy task. Facility staff can take direct measurements of pollutants by sticking a scientific instrument inside a smokestack for several hours, for example. But a sprawling plant like Clairton’s has miles of pipelines and up to thousands of components like valves and fittings that could leak toxic gases. Trying to measure every potential leak would be enormously difficult.”

“So the EPA allows facilities to provide estimates using numbers called emission factors. Each emission factor estimates the leaks produced by a specific industrial process, such as the amount of benzene expected to be released from a “light-oil storage tank” at a coke manufacturing plant.”   

     It is also reported that EPA’s Office of Inspector General has criticized the use of emission factors, especially for certain facilities, including coke plants. The estimation methods have long been criticized. However, the Clairton Works officials say they believed that their modeling estimates were correct before the monitors proved them wrong. Song notes that a decade ago, the Obama administration required oil refineries to install fence-line monitoring for the same reason - that installed monitors exceeded estimates for benzene, a dangerous carcinogen. This requirement led to lower benzene levels near refineries and is considered to be a success. It makes sense to want the same process and outcome for coke plants. The Trump administration is considering the requirement, but has given two-year extensions to some companies.

     In March 2024, five Democratic U.S. Senators, including both Pennsylvania Senators, wrote a letter to the Biden administration arguing that the requirements would be too costly to implement:

“Money spent pursuing marginal increases in air quality – that does nothing to raise the bar for foreign competitors – stands to eliminate the pool of capital needed to invest in workforce, as well as transformational projects that lead to new, more advanced steel grades and needed decarbonization technologies.”

“The Integrated Iron & Steel rule proposes technically unachievable standards, including a radical reduction in opacity limits and a suite of brand-new hazardous air pollutant limits affecting blast furnaces and basic oxygen furnaces in places like Cleveland and Middletown, Ohio; Dearborn, Michigan; the Mon Valley in Pennsylvania and several other locations throughout America’s industrial Midwest. The promulgation of even one of these rules would cause major hardship and financial drain on these companies; the combination of the three will have far-reaching, adverse consequences that will threaten the viability of the two remaining U.S.-based integrated steel companies.”

     They made the argument that upgrading pollution abatement at these facilities would take investment dollars away from upgrading other aspects of modernizing the plants, including decarbonizing them (which could also involve pollution reduction). Preventing real air quality concerns with potential health effects should, of course, trump carbon emissions concerns. They also argued that the high costs to ensure compliance will make the plants less competitive with foreign plants, including Chinese plants.  

     Other facilities with similar discrepancies between observed and estimated pollution levels included several chemical plants and some steel mills. A Dow Chemical facility in Plaquemine, Louisiana, had levels of vinyl chloride 156 times higher and levels of ethylene dichloride 1,033 times higher than EPA estimates based on the plant’s estimates. Another plant had high levels of ethylene oxide at seven times the standard set by the EPA. A plastics plant's ethylene dichloride levels were 69 times higher than estimates.

     Cary Secrest, a former EPA employee who spent 20 years inspecting industrial plants and now works at a company that measures pollution, noted:

“I don’t think that companies are deliberately trying to underestimate emissions. I just think that it’s impossible without actual measurements.”

     One issue that needs to be addressed with chemical plants and coke plants is the pervasive leaks of various gases at the plants. More direct monitoring needs to be done to accurately assess and document the leaks. Monitoring is not too expensive, but replacing all the leaking equipment is a major cost. Often, the issue with these plants is one of maintenance of aging plants. The estimated levels of some plants are at the current EPA limits, so the observable monitors being higher brings most plants out of compliance.

     The Trump EPA is currently evaluating the

  Clairton Works application for a two-year

exemption.      

 

References:

 

The EPA Let Companies Estimate Their Own Pollution Levels. We Discovered Real Emissions Are Far Worse. Lisa Song. ProPublica. October 30, 2025. Air Pollution From Industrial Facilities Is Far Worse Than Estimated — ProPublica

U.S. Steel restarting battery at Clairton plant more than two months after deadly explosion. Mike Darnay and Ricky Sayer, CBS News. Updated on: October 23, 2025. U.S. Steel restarting battery at Clairton plant more than two months after deadly explosion - CBS Pittsburgh

Explosions at U.S. Steel Clairton plant kill 2 and injure at least 10, officials say. Garrett Behanna, Chris Hoffman, Ricky Sayer, and Michael Guise. CBS News. Updated on: August 12, 2025. Explosions at U.S. Steel Clairton plant kill 2 and injure at least 10, officials say - CBS Pittsburgh

March 2024 letter from five Democratic Senators on steel industry rules. March 2024 letter from five Democratic Senators on steel industry rules | DocumentCloud