June, 2020
No. 536

CORONAVIRUS

·         The World is One Large Coronavirus Cleanroom Market

·         Should We Invest in HEPA Filters and Efficient Masks for the Public?

FOUNDRIES

·         ITK Envifront AB has been Awarded a Major Order by Skeppsviken to Deliver Turnkey Process Ventilation for Volvo Foundry

PAPER MILL

·         Valmet to Supply a Complete Steam Boiler Plant to Norske Skog in Austria

CO₂

·         Silver Membrane Developed to Separate CO₂

COMPANY NEWS

·         Donaldson’s Third Quarter Sales Decline

·         CECO Environmental Acquires UK-Based Environmental Integrated Solutions Limited

·         Siemens Energy Will Be Independent Company

·         Donaldson Company Announces the Termination of the Purchase Offer for its Exhaust and Emissions Business

REGULATIONS

·         EPA Rules That It Is Not Appropriate to Regulate HAP Emissions

·         Court Rules U.S. Environment Agency Must Protect States from Upwind Air Pollutions

·         Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process

·         U.S. Coal Company Launches Legal Action to Overturn Mercury Pollution Limits

CORONAVIRUS

The World is One Large Coronavirus Cleanroom Market

We live in a world where the coronavirus plays a major role now and for the foreseeable future. What we are finding is that this virus can travel in small droplets released by the lungs or on small particles of which there is no shortage. We breath in and exhale millions of tiny particles every hour. With this new finding we need to turn to the cleanroom experts who have been focused on eliminating small particles from the air for 60 years.

These experts and the products and services they offer provide an essential resource for mitigating the virus. McIlvaine is assisting by providing the suppliers with forecasts of the market opportunities in the broader vision of the world as one big coronavirus cleanroom market.

World Cleanroom Markets forecasts the revenues of rooms, components, masks and other consumables for all industries including biopharmaceuticals and hospitals. http://home.mcilvainecompany.com/index.php/markets/other/n6f-world-cleanroom-markets

Cleanroom Technology Solutions with daily alerts and webinars analyzes the masks, filters and various other hardware and consumables which will allow a safe return to near normal life and work.  http://home.mcilvainecompany.com/index.php/markets/air/82ai-coronavirus-market-intelligence

Coronavirus Pharmaceutical Solutions tracks the progress to develop vaccines, therapeutics and diagnostics. Bi-weekly Alerts are accompanied by detailed profiles of the developers and contract manufacturers who make mitigation possible. June 3 Alert , Gilead Profile

All three of these services are being offered as a package and included with the World Cleanroom Markets report at no extra charge.

A supplier needs all three of these services to fully understand the opportunities and challenges created by COVID.

A cleanroom is defined in the ISO standard 14644-1 as:

“A room in which the concentration of airborne particles is controlled, and which is constructed and used in a manner to minimize the introduction, generation, and retention of particles inside the room and in which other relevant parameters, e.g. temperature, humidity, and pressure, are controlled as necessary”

6.2 million people have contracted COVID 19 in the last six months.  380,000 have died. With a problem of this magnitude caused in large part by an airborne virus we have to be thinking of the world as one big facility which needs to adopt cleanroom technology. The same strategy can be applied as would be applied to a pharmaceutical complex.

In a pharmaceutical facility there is likely to be a progression of clean spaces.

Ambient air in a typical city contains 500,000 or less particles 0.3 microns in diameter in each cubic foot. It also contains millions of smaller particles. An individual inhales the air with the particles and then exhales the CO2 and sends the particles back into the environment. A super spreader can be generating thousands of virus aerosols per minute. Some will be in small droplets caused by lung splashes. They may travel hundreds of yards. Those which attach to small particles can drift over a whole region, e.g., Lombardy, Italy. There is no knowledge as to what percentage is inactivated by distance traveled and what percentage is just dormant and ready to be revived in lung moisture.

There is research which indicates that the disease can be transmitted by as few as 10 virus particles. On the other hand, experts say that most is contracted through contact with large numbers of particles. As long as some of the COVID transmission is through aerosols there will be no fool proof way to prevent COVID transmission. A mitigation program has to therefore accept some risk and minimize the transmission as much as is economically possible. 

This is the same strategy used in a pharmaceutical facility. Many pharmaceutical operations take place in space where the number of 0.3micron particles is limited to 100 or less. Within that space there may be isolators where there is less than one 0.3micron particle per cubic foot. When one leaves a less clean space and enters a cleaner area there are possibly air showers, garment changing and other procedures.

The decision on how clean to make each space is a function of risk and cost. The same principle applies to dealing with COVID. The protection effort needed on a crowded subway is much greater than a sparsely inhabited park. Suppliers have products to address varying levels of risk and reduction.

An advantage of the packaging of the three services is to determine the impact of one on the others. The massive effort to create vaccines, therapeutics, and diagnostics for COVID means that there will be reduced cleanroom revenues for cancer and other biopharmaceuticals.

For more details on this package contact Bob McIlvaine at 847.226.2391 or email him at 847.226.2391.

Should We Invest in HEPA Filters and Efficient Masks for the Public?

The Coronavirus Technology Solutions proposed for the U.S. will cost tens of billion dollars per year. If 200 million people wear N95 quality masks this cost alone could be $20 billion per year. HEPA filtration and laminar air flow, decontamination of spaces and other technology could raise annual costs to $100 billion per year. If these measures save 30,000 lives per year the investment would be justified. EPA uses $10 million per life in determining the value of regulations. So, on this basis the cost saved would be $300 billion per year. 

In an earlier webinar, McIlvaine analyzed the cost of COVID to include not only the deaths but the hospitalizations and impact on the economy and arrived at $50 million per death. So, with this cost an investment of $1.5 trillion per year could be justified.

It is desirable to see how much is spent to reduce other risks.

The population motor-vehicle death rate reached its peak in 1937 with 30.8 deaths per 100,000 population. The current rate is 12.0 per 100,000, representing a 61 percent improvement. With 150,000 deaths from COVID in 2020 the U.S. would reach 50 deaths per thousand. If we revert to the safety standards of the 1930s there would be at least 120,000 deaths in the U.S. We appear willing to deal with an extra 10,000 deaths per year for the time saved to travel at 65 mph.

There is no assurance that a vaccine will be in place and be effective in the next two years. There are predictions without vaccines as much as 60 percent of the population will contract the disease. By year end there are likely to be 3 million cases registered in the U.S. but possibly there are ten times that number who are unreported. This means that only a maximum of ten percent of the population will be have been exposed to the disease at the end of 2020. There could be six more years with 150,000 deaths per year before herd immunity is achieved.

Public water in the U.S is quite reliable. However, the experience in Flint Michigan shows what happens if we lower the standards. Billions of dollars are spent for bottled water but there is little evidence that lives are saved.

Air pollution deaths in the U.S due to air pollution are pegged at over 100,000 per year. However, these are mainly older people. Therefore, the life years per death lost is less than from COVID or from automobile accidents. Nevertheless, the numbers are significant. They are much more significant in many Asian countries where air pollution levels are many times greater than in the average U.S. city.

An advantage of N95 masks for everyone would be a reduction in air pollution deaths as well as from COVID. There are close to 100,000 hospital acquired infection deaths per year in the U.S.   It is likely that several thousand lives per year could be saved if visitors and personnel wear N95 masks.

The graph shows that COVID and air pollution have the biggest potential for death reduction. COVID represents a risk far greater than the annual flu or even driving at 65 mph. The Coronavirus Technology Solutions will therefore be both important cost effective.

For more information on Coronavirus Technology Solutions click on http://home.mcilvainecompany.com/index.php/markets/air/82ai-coronavirus-market-intelligence.

Bob McIlvaine can answer your questions at rmcilvaine@mcilvainecompany.com and 847.226.2391.

FOUNDRIES

ITK Envifront AB has been Awarded a Major Order by Skeppsviken to Deliver Turnkey Process Ventilation for Volvo Foundry

Volvo AB invests approximately 1600 million SEK in a new foundry located in Skövde, Sweden. The new building, approx. 11,000 m², is located on the existing premises and will be fully integrated in the existing factory. ITK Envifront has been awarded the complete turn-key scope for delivery of the process ventilation. The scope of supply includes amongst others suction points, ducting, bag filters, heat exchangers, fans and two chimneys. One of these is 100 meters tall and a landmark at the south entry to Skövde.

We are very pleased to have been selected as a partner to Skeppsviken, who is the main EPC supplier for the new factory including ventilation. The project duration is more than 3 years.

ITK Envifront has supplied many bag filters to the Volvo foundry in Skövde since the late 1960-ies. This project, with a total worth of approximately 60 million SEK, consists of six complete bag filter systems including installation and commissioning.

Volvo makes the investment in order to future-proof the production, create more flexibility but also to reduce the environmental footprint with a reduced usage of non-recyclable materials. Skeppsviken, being the contract partner to ITK Envifront, is a long-term collaboration partner to Volvo in Skövde. ITK Envifront brings its vast experience and knowledge to deliver filter solutions to foundries world-wide.

ITK Envifront is pleased to be selected as partner to this project and look forward to delivering a design to order solution improving the environmental footprint of the new foundry. 

PAPER MILL

Valmet to Supply a Complete Steam Boiler Plant to Norske Skog in Austria

Valmet will supply a complete steam boiler plant to Norske Skog’s paper mill in Bruck an der Mur, Austria.

The order was included in Valmet’s orders received of the 1^st quarter 2020. The value of the order is approximately €40 million. The boiler plant will be handed over to the customer in 2022.

The investment will improve the mill’s cost competitiveness, reduce its carbon footprint and create new business beyond publication paper by generating revenue from the combustion of refuse-derived fuels (RDF).

With a fuel power of 56 megawatts, the new boiler will run mainly on RDF, pulper rejects and sludge with natural gas as a secondary fuel. It will partly replace the steam production of existing natural-gas-fired boilers as well as supply heat to the paper mill and local district heating network in Bruck, resulting in lower CO₂ emissions.

Valmet’s turnkey delivery includes Valmet’s BFB boiler plant that utilizes bubbling fluidized bed technology. It features a robust and integrated concept consisting of a gas-fired superheater for final steam superheating, baghouse filter for primary pollution control, SCR system for NO_x reduction, combustion air humidifier as well as a condensing scrubber for heat production and final emission reduction. Additionally, the delivery includes the construction of new buildings for the equipment, an upgrade of an existing Valmet DNA Automation System and Valmet Industrial Internet (VII solutions with DNA Combustion Manager and DNA Boiler Soot-blowing Manager solutions and VII cloud services.

CO₂ 

Silver Membrane Developed to Separate CO₂

Scientists have developed a new self-assembling silver membrane that is capable of capturing Carbon Dioxide (CO₂). The membrane can be utilized to filter out the greenhouse gas from emissions before it has a chance to escape into the atmosphere. The membrane utilizes a method that has never been used before. The gas separating membrane has been seeded with a tiny deposit of the valuable metal, which prompts the use of CO₂ flow to grow tiny silver crystals or dendrites in the membrane. This outgrowth of the crystals or dendrites is more economical as it allows much larger amounts of CO₂ and oxygen to flow through. This increases the efficiency of such a membrane by a big margin. This also helps bring the cost down significantly as the membrane does not have to be made completely from silver.

COMPANY NEWS

Donaldson’s Third Quarter Sales Decline

Donaldson Company, Inc. has reported 3^rd quarter 2020 net earnings of $63.4 million, or $0.50 per share, compared with 3^rd quarter 2019 net earnings of $75.2 million, or $0.58 per share.

We are pleased with the volume at the end of April, which resulted in 3^rd quarter sales that were slightly better than we had anticipated, and cost controls throughout the quarter mitigated the profit impact from increasingly soft demand,” said Tod Carpenter, Chairman, President and Chief Executive Officer. “Our teams are acting quickly and decisively to navigate this unprecedented environment, including adjusting production to match demand, adding resources to pursue growth, and maintaining an incredible level of coordination and collaboration within the company and across our valued base of suppliers and customers.

“We are well-positioned to deal with continued unevenness, which will likely extend beyond the end of our fiscal year in July. We have further enhanced our already-strong liquidity position, and we will maintain our historically disciplined approach to capital deployment, giving us necessary flexibility to respond to demand changes while continuing to prioritize investments in long-term capabilities. As we push ahead, our focus remains on the well-being of our employees and meeting the needs of customers in the critical markets we support. Our employees have shown incredible resilience and tireless commitment during these turbulent times, and I want to thank them for their contributions. We are operating as One Donaldson, and I am confident in our long-term ability to deliver on our purpose of Advancing Filtration for a Cleaner World.”

The 3^rd quarter 2020 sales declined 11.7 percent to $629.7 million from $712.8 million in 2019. Excluding the negative impact from currency translation of approximately 2.0 percent, third quarter 2020 sales declined 9.7 percent, reflecting a broad-based global economic slowdown that is due in large part to the COVID-19 pandemic.

The 3^rd quarter 2020 sales of Industrial Products (“Industrial”) declined 6.3 percent, or 4.6 percent excluding the impact from currency translation. Sales within Industrial Filtration Solutions (“IFS”) were negatively impacted by lower levels of industrial production, which contributed to declining sales of new equipment and replacement parts for dust collectors. Sales of Process Filtration, which are included in IFS, were approximately flat with the prior year, or up in local currency, due to strong sales of replacement parts for the food and beverage industry. The Gas Turbine Systems sales increase was driven by retrofit projects for existing turbines. The sales increase in Special Applications was driven by higher sales of Disk Drive filters and Integrated Venting Solutions, partially offset by lower sales of Membrane products.

Donaldson’s 3^rd quarter 2020 EBITDA as a rate of sales was flat with the prior year at 17.6 percent. The 3^rd quarter 2020 operating income as a rate of sales (“operating margin”) decreased to 13.4 percent from 14.0 percent in 2019, including an impact of approximately 0.6 percentage points from higher depreciation and amortization expense related to Donaldson’s capacity expansion and supply chain optimization efforts.

The  3^rd quarter 2020 gross margin decreased to 33.2 percent from 33.8 percent in the prior year, reflecting loss of leverage on lower sales, including an impact from higher depreciation expense related to the company’s capacity expansion projects, partially offset by a favorable mix of sales, lower raw materials costs, and benefits from the company’s initiatives related to production, supply chain, procurement and pricing optimization. Donaldson’s 3^rd quarter operating expense as a rate of sales (“expense rate”) increased to 19.8 percent from 19.7 percent last year, reflecting a loss of leverage on lower sales that was largely offset by lower incentive compensation and expense reductions related to the COVID-19 pandemic.

As previously disclosed, Donaldson withdrew its financial targets for fiscal years 2020 and 2021.⁴ While the magnitude and duration of the impact from the COVID-19 pandemic on certain aspects of the company’s financial performance remains uncertain, Donaldson expects:

·         May 2020 sales to be down about 24 percent, reflecting relative outperformance in replacement parts versus new equipment, and, on a regional basis, Asia/Pacific sales are expected to be the strongest while sales in the Americas are expected to be the weakest,

·         To maintain a strong financial position, which was further augmented with an incremental 364-day facility that provides an additional $100 million in liquidity,

·         The pace of capital expenditures will continue to slow as strategic projects related to capacity expansion and research and development capabilities near completion, and

·         Fiscal 2020 share repurchase will total 1.6 percent of outstanding shares, reflecting what has already been completed year-to-date through the 3^rd quarter.

CECO Environmental Acquires UK-Based Environmental Integrated Solutions Limited

CECO Environmental Corp., a leading global air quality and fluid handling technology company, announced that it has completed the acquisition of Environmental Integrated Solutions Limited ("EIS"). Headquartered in Birmingham UK. EIS engineers products that clean air through a variety of technologies including VOC abatement, odor control, and other air pollution control solutions.  This acquisition advances CECO's mission to solve the sustainability challenges that come with the demands of industrial progress.

"We are very excited with the acquisition of EIS and pleased to welcome their team to the CECO family.  EIS further increases CECO's solution capability, application depth, and knowledge expertise as part of our growth strategy.  EIS expands the coverage of our industrial customers across Europe, as well as leverages our current capabilities in North America," said Dennis Sadlowski, Chief Executive Officer of CECO Environmental. "The addition of EIS further elevates our leadership position in solving the most challenging air quality applications around the world.  EIS will serve as a regional hub for CECO's Industrial Solutions segment and is expected to become a catalyst for accelerated growth into the European industrial markets."

Matt Eckl, CECO Environmental's Chief Financial Officer commented, "The acquisition of EIS gives us immediate access to new markets, adds approximately $16 million in annual revenues and provides CECO with incremental market and financial scale. This combination is a win-win as EIS will leverage CECO's supply chain in North America and CECO will gain access to EIS's network of production partners in Europe, further expanding our lucrative asset light business model. From a financial perspective, EIS brings above average EBITDA margins and strong free cash flows.  At a purchase price of approximately $12.2 million, including a targeted earnout, the transaction is anticipated to deliver attractive value for CECO shareholders."

Siemens Energy Will Be Independent Company

“Turning Siemens’ energy business into an independent company is a key milestone in the successful execution of our Vision 2020+ strategy program,” said Joe Kaeser, President and CEO of Siemens AG. “The considerable increase in the value of our healthcare business shows the huge potential we can tap by further sharpening the focus of our company. This applies to both, Siemens Energy and the ‘New Siemens AG,’ which is concentrating on our Industrial Businesses. We’ve now reached a major milestone in the overall realignment that is preparing the Siemens companies for the massive technological transformations that we are anticipating.” 

The planned public listing of Siemens Energy will create a strong, focused, global company with operations spanning the entire energy value chain, including the service business. Thanks to its unique setup, Siemens Energy can react quickly to customer needs and thus help meet the globally rising demand for energy while significantly reducing carbon emissions. In the future, Siemens AG itself will concentrate on Digital Industries, Smart Infrastructure and Siemens Mobility. Siemens Healthineers, the company’s healthcare technology business — which has a sharp focus on diagnostic and therapeutic imaging, laboratory diagnostics, molecular medicine and health services — has been publicly listed as a separately managed company since March 2018.

The new Siemens Energy will have about 91,000 employees worldwide (as of March 31, 2020). Its products will include, among other things, combined cycle turbines, generators, transformers and compressors. In the area of wind turbines, Siemens Energy will be a world-market leader in renewable energies due to its 67 percent stake in Siemens Gamesa Renewable Energy. As of September 30, 2019, Siemens Energy’s order backlog stood at €77 billion. In fiscal 2019, Siemens Energy generated revenue of about €29 billion according to the Combined Financial Statements of Siemens Energy AG as of September 30, 2019, which were prepared on a voluntary basis. If severance charges of around €0.3 billion had been excluded, the adjusted EBITA would have been about €1.3 billion.

At its launch, Siemens Energy will be very solidly financed: the new company will have a large amount of capital and liquidity at its disposal right from the start. The aim is to meet the requirements for a solid investment-grade credit rating. According to the Combined Financial Statements of Siemens Energy AG as of March 31, 2020, which were prepared on a voluntary basis, equity totaled about €17.3 billion (IFRS), corresponding to an equity ratio of 37.8 percent. Siemens Energy has been provided with liquidity equivalent to about €6.2 billion. Of this amount, around €4.1 billion will be used to settle liabilities during the period leading up to the spin-off. In addition, a bank consortium has confirmed a revolving credit facility of €3.0 billion.

After the spin-off, Siemens Energy will be managed separately and independently. A so-called deconsolidation agreement signed with Siemens AG ensures this status. Under the terms of this agreement, Siemens AG has obligated itself to refrain from exercising any direct or indirect controlling influence over the new company. Among other things, the agreement requires that the Supervisory Board of Siemens Energy AG include no more than three representatives of Siemens AG. In addition, voting rights will be limited to the extent that no decisions on certain topics — in particular, on the election of Supervisory Board members — can be implemented unilaterally against the wishes of the other shareholders of Siemens Energy AG. 

Donaldson Company Announces the Termination of the Purchase Offer for its Exhaust and Emissions Business

Donaldson Company, Inc., a leading worldwide provider of innovative filtration products and solutions, today announced that it has reached a mutual agreement with Nelson Global Products, Inc. (“Nelson”) to terminate Nelson’s previously disclosed purchase offer for Donaldson’s Exhaust and Emissions (“E&E”) business.

“While we are disappointed the acquisition of our E&E business by Nelson will not be completed, we remain focused on our employees, customers and suppliers,” said Tod Carpenter, Chairman, President and Chief Executive Officer. “Our E&E business is defined by an incredibly talented team, robust engineering capabilities and strong customer relationships. We remain committed to delivering quality emissions products in parallel with ongoing optimization efforts to ensure our business portfolio creates long-term value for our stakeholders.”

Donaldson announced Nelson’s purchase offer for its Exhaust and Emissions business on February 24, 2020.

REGULATIONS

EPA Rules That It Is Not Appropriate to Regulate HAP Emissions

The U.S. Environmental Protection Agency (EPA) is revising its response to the U.S. Supreme Court decision in Michigan v. EPA, which held that the EPA erred by not considering cost in its determination that regulation under section 112 of the Clean Air Act (CAA) of hazardous air pollutant (HAP) emissions from coal- and oil-fired electric utility steam generating units (EGUs) is appropriate and necessary. After primarily comparing the cost of compliance relative to the benefits of HAP emission reduction from regulation, the EPA finds that it is not ‘‘appropriate and necessary’’ to regulate HAP emissions from coal- and oil-fired EGUs, thereby reversing the Agency’s previous conclusion under CAA Section 112(n)(1)(A) and correcting flaws in the Agency’s prior response to Michigan v. EPA.

We further find that finalizing this new response to Michigan v. EPA will not remove the Coal- and Oil-Fired EGU source category from the CAA Section 112(c) list of sources that must be regulated under CAA Section 112(d) and will not affect the existing CAA Section 112(d) emissions standards that regulate HAP emissions from coal- and oil-fired EGUs. The EPA is also finalizing the residual risk and technology review (RTR) conducted for the Coal- and Oil- Fired EGU source category regulated under national emission standards for hazardous air pollutants (NESHAP), commonly referred to as the Mercury and Air Toxics Standards (MATS). Based on the results of the RTR analyses, the Agency is not promulgating any revisions to the MATS rule.

Federal Register / Vol. 85, No. 100 / Friday, May 22, 2020 / Rules and Regulations

Court Rules U.S. Environment Agency Must Protect States from Upwind Air Pollutions

A federal appeals court ruled that the U.S. Environmental Protection Agency violated the law when it denied a request from Maryland and Delaware to tighten air pollution controls at power plants in upwind neighboring states.

The decision by the three-judge panel of the United States Court of Appeals for the D.C. Circuit could force the EPA to impose new curbs on some coal-fired power plants, even as the administration of President Donald Trump seeks to help the industry by slashing environmental regulations.

The EPA is reviewing the decision, said spokeswoman Enesta Jones.

Maryland and Delaware had filed their petition to the EPA in 2018 asking for tougher pollution limits on some 36 coal-fired power plant units in Indiana, Kentucky, Ohio, Pennsylvania and West Virginia.

The states had argued that those power plants were in violation of the Clean Air Act’s “good neighbor provision” for the release of nitrogen oxides into the air. The majority of Maryland’s ozone pollution originates from upwind states.

The EPA rejected the petition, arguing that requiring upwind power plants to add more pollution controls to protect downwind states was not cost-effective for the plant owners.

Richard Revesz of NYU’s School of Law and director of the Institute for Policy Integrity filed the amicus brief on behalf of Maryland and Delaware. He said the ruling made clear the EPA is obligated to prevent states from harming the air quality of their neighboring states when emissions travel downwind and “can’t cite cost as a reason to ignore the law altogether.”

Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process

The Environmental Protection Agency (EPA) is proposing processes that it would be required to undertake in promulgating regulations under the Clean Air Act (CAA) to ensure that information regarding the benefits and costs of regulatory decisions is provided and considered in a consistent and transparent manner. This proposed rulemaking addresses, among other things, issues raised in the June 13, 2018 advance notice of proposed rulemaking, ‘‘Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process,’’ and proposes how the concepts described in that advance document would be implemented in rulemakings conducted by the EPA using its authorities under the CAA. The EPA is proposing to establish procedural requirements governing the development and presentation of benefit-cost analyses (BCA), including risk assessments used in the BCA, for significant rulemakings conducted under the CAA. Together, these requirements would help ensure that the EPA implements its statutory obligations under the CAA, and describes its work in implementing those obligations, in a way that is consistent and transparent.

Federal Register / Vol. 85, No. 113 / Thursday June 11, 2020 / Proposed Rules

U.S. Coal Company Launches Legal Action to Overturn Mercury Pollution Limits

Westmoreland Mining has launched a legal challenge against the Environmental Protection Agency’s (EPA) Mercury and Air Toxics Standards (MATS) rule. In April the EPA Administrator, Andrew Wheeler, a former coal industry lobbyist, issued the final MATS rule but altered the cost-benefit analysis to state it would only result in a benefit of between US$4 million and US$6 million. Environmental groups warned at the time that the change to the cost-benefit analysis was aimed at opening the door to a legal challenge to the rule. Westmoreland Mining, which only emerged from bankruptcy protection in March 2019, operates six coal mines in the US, where demand for thermal coal is collapsing, and a further six mines in Canada.

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