On October 15 we held our second session in our science to policy workshop series with the specific goal to narrow and prioritize broad policy themes to form specific actionable policies (Figure 1).
Our second session featured:
- a ⅓ science and ⅔ policy focus
- Themes feedback and additional guest speakers to give context on identified themes
- A future vision gaming exercise and a mini-team exercise backcasting renewable energy futures and identifying actions/elements needed to achieve it
Following the workshop we analyzed the discussion and identified over 90 data points using NVivo. While a significant number, what emerged from subsequent grouping analysis were 10 key policy areas. These are described below in no specific order:
Establish a State water-energy office (or program) to coordinate education, technology support, incentives, system planning, and policy for DER, grid interconnects, and the water-energy nexus
Coordination is a reoccurring theme with successful distributed energy resources (DER) projects. Utilities need to be proactive with their efforts to engage their counterpart energy utility while education, technology and engineering support (evaluating non-market costs and benefits, sharing opportunities, scale integration, water-energy data and analysis) are needed. Water utilities also need a point of contact to advocate for new renewable energy tariffs as well as prioritize actions to modernize and safeguard our water resources and infrastructure while improving energy efficiency and resource recovery.
To meet this need, DER projects would benefit from state level support and coordination. State oversight is also beneficial for interfacing between Federal programs and requirements and on significant water-energy system overlaps (e.g. critical infrastructure, grid/system resiliency) as well as interfacing on local and holistic planning efforts with energy as a strategic focus.
Expand the role of the US Department of Energy to include a permanent program or water office to enable water-energy coordination and securing renewable energy resource recovery from water and WRRF systems.
The US Department of Energy (DOE) has provided significant education and support (to include research and development funding) for renewable energy technology development and implementation to include water related technologies. There is an ongoing need to continue coordination between the water sector and the DOE’s Water Security Grand Challenge. Yet, while over 30 states have some renewable energy portfolio standard, there is limited cohesive sharing of water related energy information (e.g. water sector specific SANKEY diagrams), and no clearinghouse of successful water related DER projects. Water and Water Resources Recovery Facility (WRRF) utilities need support on renewable energy technologies to established demonstration projects using proven technology, laboratory and pilot scale trials, documented success of other utilities implementation, technical and communication documents, and tools to help write better business cases – such as an on-line DER implementation support system.
Expanding the role of the US DOE to include a water related office would benefit water related DER projects and help ensure that technology investment in the sector benefits not only the water sector but renewable energy investments at a national scale.
Consolidate the regulation, permitting, and defining of energy from W/WRRF systems as a resource (across the EPA/Utility Commissions/State Reg offices)
It is noted that there are opportunities to export substantial quantities of gas, however current regulations (arguably aimed at large chemical plants – 10,000 lb was identified as a key threshold) preventing WRRF utilities from exporting gas. There is also a need to develop/clarify exemptions from the Environmental Protection Agency RMP OSHA (Risk Management Plan Occupational Safety and Health Administration) regarding requirements for exporting biogas from WRRF as well as the classification of biogas as a GHG emission source. Previous successful DER projects include requests and receiving exemption from local and state regulators to allow for energy recovery and distribution (both on site and externally). Further, clear interconnection rules, frameworks for addressing renewable energy standards and energy sources, and localities that have defined biogas as an energy resource have enabled natural gas companies take biogas cleaned and delivered to their standards, offsetting non RNG production.
While policies that allow utilities to request exemption from current barriers limiting resource recovery at water utilities have been successful, they require local and state by state exemption processes, and unique permitting and defining of energy sources as a case by case basis. Consolidating these state and local polices to nationally recognize and define energy from water and WRRF utilities as an energy resource rather than an emission source would comprehensively address existing barriers at a federal level.
Establish a Water-Energy Industry Sector Taskforce to drive integration and coordination (AWWA, WEF, WRF, IEEEE, EPRI, NYSERDA, etc.)
Water and WRRF utilities will need to be proactive with their efforts to engage their counterpart energy utility, as was observed in multiple DER case studies. There is also a need to review established demonstration projects using proven technology, laboratory and pilot scale trials, documented success of other utilities’ DER implementation, technical and communication documents that provides tools to help write better business cases. Moreover, there is a need to encourage joint water-energy organizational sharing on opportunities, projects and publications related to DER projects.
Water and WRRF sector organizations such as WEF (Water Environment Federation) and AWWA (American Water Works Association) could establish information and policy exchanges with the comparable organizations in the energy sectors to identify common barriers and to coordinate education of policy officials and the development of a water-energy industry sector taskforce would support cross sector coordination and technology investment and knowledge sharing for the benefit of both sectors.
Require co-sector water/energy coordination on renewable energy projects and programs – Energy utilities assign account manager and coordinate supply and demand for large scale users – Energy utilities are involved with gas storage (partnership)
While there are many linkages between water and energy systems, there are few established communication and management channels between water and energy utilities. Those utilities that have established account managers for large scale users have demonstrated substantial project investments and co-benefits in demand response, energy and water efficiency, and grid system resilience. Water utilities are also not energy producers and therefore they are not classified as such. Because of this classification, water and WRRF utilities often face significant barriers to capture and store energy (for instance water and WRRF utilities cannot store the biogas generated because it is a hazard and current odor and air regulations in many jurisdictions discourage and add cost to bioreactors. These limitations represent a barrier to the recovery of biogas.) New management structures are needed so water and WRRF facilities can contribute to renewable energy futures without increasing the volatility of the electric and natural gas systems or affecting scale and integration investments (as might occur when too much Individual investment in DER in one place). Multi-agency review often occurs, but not always, when there are major capital investments affecting the demand and closer coordination (at the account level) would aid in reviewing micro-grid opportunities to identify where infrastructure could be recognized as critical infrastructure, for policies that require micro-grid development for emergency management, and to improve system resilience.
Requiring co-sector water/energy coordination on renewable energy projects and programs, to include the assignment of an account manager to coordinate large scale energy supply and demand, and active partnerships (e.g. managing the risk and hazard risk concerning biogas generation and storage) would help alleviate these deficiencies and meet the overall need to closely management the impacts of water and energy system investments.
Streamline the application process for funding, permits, incentives (etc.) through a formal W/WRRF renewable energy framework and process reduction actions (Water-Energy Office supports)
One of the main barriers to water specific DER identified is the significant number of requirements to fulfill and paperwork to complete to secure funding, permits, incentives and concessions to install new renewable energy (RE) systems. Water and WRRF utilities are often new to energy projects and do not possess staff and knowledge to start the process of undertaking new RE projects because of the time required and complexity of these processes.
To overcome this barrier, water and WRRF utilities would benefit from the support of a third-party organization or State office to simplify the process of obtaining necessary permits, accessing and requesting funding, accessing incentives, and understanding rules and requirements to RE systems implementation.
Advocate for holistic State/Mayoral level renewable goals/targets, sustainability goals, and broader carbon reduction goals with accompanying institutional support
Renewable energy and sustainable development targets vary across cities, states and countries. How and what targets are set influence how water and WRRF utilities adopt RE projects. RE targets, carbon, and organic regulations, state and city-level renewable portfolio standards have been shown to be influencing factors in DER case studies. However, the multitude of existing targets makes it challenging to plan for RE projects because of how each target affect where water and WRRF RE projects plays a role in the adopted strategy. There is a need for RE targets to include and support holistic state and city level RE development, to include a role for W/WRRF projects. However, setting a target on its own it is not a sufficient strategy by itself to enable the water sector to achieve that target thus appropriate support (e.g. funding separate from energy costs savings and rate revenues, technology support, coordination) should accompany such programs.
To recognize the previous influencing factors state and city level energy and carbon targets and goals have played in RE project development, the water sector should advocate for more holistic energy targets and goals. Targets need to be set clearly at state/major’s office level and a clear roadmap for water and WRRF utilities should be given to enable these utilities to achieve them, and support for how they should do it.
Establish longer-term cost-benefit pricing signals (e.g. fixed cost-benefit return, PPA/PPP, tariff guarantees, long term renewable energy credits and feed-in tariffs, carbon credits)
Uncertainty around the duration of incentive schemes, such as the feed-in tariffs, carbon credits, federal income tax credits, etc., and the volatility of the electricity/energy price are limiting a precise forecast of the return on investments of RE projects. Power Purchase Agreements and Private Public Partnerships seem to provide one means for overcoming this issue, since the involvement of a third party owning the RE projects enables W/WRRF utilities to fix the electricity/energy price for 25+ years. There is a need to advocate to State Regulatory Commissions for new tariffs and ongoing incentives for reduction in energy consumption (kWHs). There is also a need/opportunity to guide utility participation in State-driven regulation of energy costs and tariffs and regulatory proceedings which create tariff and interconnection certainty.
Many water/WRRF utilities are unaware that they could advocate for longer-term tariff stability, fixed loan programs, competitive pricing rules (allowing grid distribution over wholesale rates), and consistent pricing signals. Establishing longer-term cost-benefit pricing signals is a multifaceted policy that could be implemented in many ways. One option might see incentive schemes (feed in tariff, tax rebates, renewable energy certificates) with fixed long term duration (10-20 years). Such schemes would require commitment beyond the pace at which the political environment changes. A second option would be to widely enable the Power Purchase Agreement/Private Public Partnership schemes and facilitate Solar renewable energy certificates (SREC) programs. Finally, broader financial comparison metrics (i.e., net present value, net revenue, and operational savings, triple bottom line assessments) would additionally support longer-term cost-benefit returns providing an alternative assessment to simple cost-revenue frameworks.
Further circular economy policies that support a biogas market (e.g. incentives to increase technology adoption, maximizing recovery of biogas from WRRF, policies that requires or encourage diversion of organics through wastewater streams)
The Water Environment Federation’s position statement on RE generation from wastewater describes wastewater treatment plants as water resource recovery facilities that produce clean water, recover nutrients (such as phosphorus and nitrogen), and produce renewable energy. Yet, WRRF plant managers need a financial incentive and end-market customer for biogas and biofuels to ensure that biogas recovery projects are successful. Mandated renewable energy goals encouraging all DER projects including biogas, and partnership and coordination with electricity/natural gas companies can overcome interconnection difficulties and create a market for excess biogas. Further, policies that reduce organic waste at the source, ban organic sources from waste streams, and 100% resource recovery of food and organic waste (e.g. Ontario Food and Organic Waste Policy) set the stage for a biogas/biofuel market but lack sufficient driving force to alone enable biogas/biofuel DER projects.
To address the overall need for WRRF utilities to prepare for and engage in a biogas/biofuel market, circular economy policies that identify and balance organic flows (to include those through WRRF), maximize biogas yields, and foster technology effectiveness (performance and cost) should be furthered.
We encourage your comments and we look forward to our last session on November 5.
~Steve and Steve