There are many aspects that need to be considered when planning and developing an RNG project. Consider these topics and discussion points for project stakeholders to bring to the table when working through the project planning and developing process.
By Darrell Thompson and James Fields
As more regions of the globe migrate away from energy derived from fossil fuels to combat greenhouse gas emissions and climate change, energy providers are having to supplement their fossil fuel resources with clean, renewable fuels. Renewable energy mandates, incentives, and tax credits for renewable natural gas (RNG) derived from landfill gas (LFG) are driving the development of RNG projects at landfills nationwide at an aggressive pace.
RNG is a frontrunner as a truly renewable energy alternative for many of today’s energy consumers and corporations seeking to use a clean energy source as part of their operations to reduce their carbon footprint. This article discusses several challenges in developing these projects that warrant considerable attention in the planning phase prior to proceeding with design documents, equipment procurement, and establishing commercial operations milestones.
Building the Right Team
Assembling an effective and cohesive team for the project is instrumental. Whether the project(s) is being developed through a Design-Build or more traditional Engineer-Procure-Contract (EPC) delivery method, team development is crucial for successful project deliveries. The relationship between the energy developer and the resource owner has to be established early on, and each party’s responsibilities should be clearly defined. These partnerships can be established privately and through a public procurement process if the owner is a municipality. Notwithstanding the confirmation of stable and reliable gas resources, the Agreement between the developer and the owner can make or break a successful project and can take several months to negotiate. The process is further complicated by the countless number of considerations and logistical decisions between all the parties involved to reach the final agreement stage of the process, i.e., existing infrastructure, siting consideration for the RNG facility, delivery pipeline alignment and right-of-ways, construction sequencing, delivery, sales gas agreement provisions, compliance responsibilities, and more. Therefore, a focused approach between the RNG developer and the host landfill facility owner plays a vital role in development of RNG projects.
As early as possible, RNG developers should assemble team members and service providers who are familiar with the operations and nuances of constructing and operating a landfill, as well as the design, permitting, and construction of a plant within or adjacent to the confines of the landfill’s operations. Speed to market is a key performance indicator in a project’s success, and with that, team members must be acutely aware of agreed upon schedules and key milestones to meet commercial operations dates.
Permitting Challenges
As with many projects, the focus on appropriate and timely permitting plays a vital role in the project lifecycle. The advice with respect to permitting is to begin the process as early as possible in the initial phases of the project. Project teams should consider implementing the use of a permit matrix for their projects, which can assist teams in identifying all permits required for construction and operation, key submittal dates, regulatory agency review timeframes, and pre-requisite documents. A permit matrix can be constructed to include built-in intelligence that can assist team members in assessing risk windows for early and late permit approvals, allowing the team to effectively communicate and provide status updates to internal and external project stakeholders. Particular attention should be applied to projects that involve a zoning change or change of use in a specified zoning classification. Many municipalities and regions in the U.S. have implemented the use of Unified Development Ordinances (UDO) that provide specific guidelines and recommendations for development projects under their regulatory purview.
Special use permits are another vehicle that regional and municipal regulatory, planning, and zoning agencies use to evaluate projects. Project teams that are adept at navigating those types of permitting scenarios have a distinct advantage over those who struggle in the permitting arena. Use of a Zoning Consistency Determination in the early stages of the air permitting process can often assist project teams with identifying critical zoning review agencies for a project. Zoning changes and variance approvals could take extended periods of time to obtain approvals and could drastically affect a project’s schedule.
In order to obtain land use permits, these applications are typically reviewed by the local government’s planning and building departments and are subject to established project development permitting timelines. Applications may require public notices and will be subject to a defined public comment period. Projects requiring approval by local officials must be placed onto public meeting agendas and reviewed by officials during periodically scheduled meetings. The frequency and timing of the meetings during the local government’s fiscal calendar year can drive application deliverables to be required months in advance of original estimated schedules to obtain construction approvals on time or prior to seasonal weather.
Permitting requirements for the RNG plants and the pipelines can vary greatly depending on the federal, state, and local agencies regulating the project’s development. For example, permitting a pipeline project in Pennsylvania can be vastly different than permitting a project in other states like Ohio, Louisiana, or California due to differences in state and/or local statutes.
Enough cannot be said about the importance of open and transparent discussions with the host landfill’s owner and operator regarding past experiences in permitting projects that have occurred during the landfill’s history and taking advantage of relationships with local agencies. These types of conversations and tactics will enable project teams to gain a better understanding of the audience in a pre-application or technical review meeting with regional regulatory agencies. Therefore, assessing and evaluating a project’s permitting requirements as early as possible has tremendous benefits.
Construction Challenges
Available space within the permitted boundary of an existing landfill is often limited and considered prime real estate to the landowner and to RNG project stakeholders. Site selection plays another important role in the RNG project development process. Without thoughtful consideration of the wants and needs of those involved in the Agreement, undue stress can occur during the design and development of an RNG project if unforeseen circumstances are encountered after the project site is selected. It is recommended that discussions and negotiations involving access during construction and normal operation hours, locations of laydown areas, extensions of connecting infrastructure, locations of borrow/waste areas, and numerous logistical items are considered. Prior to finalization of the site selection, RNG developers should seek input and feedback from their respective project team members to evaluate specific site or soil properties that could impact the project design. Preliminary plans and equipment arrangements should be developed to evaluate effective solutions to providing appropriate equipment support structures and cathodic protection systems for the RNG facility.
Constructability is another important consideration and discussion point for RNG developers. As we saw during the recent pandemic, disruptions in the supply chain resulted in long lead time for materials, electrical components, and other building supplies, and have caused project developers to incorporate contingencies into their build-out schedules by adding storage areas and temporary material laydown areas into their project footprints. In certain market conditions, it may be advantageous to pre-order certain equipment that is akin to all RNG projects or common to certain developers’ preferred LFG conditioning and delivery systems.
Landfills are a microcosm of constant activity, vehicle traffic, and a continuously evolving landscape. As such, consideration must be given to the increase in daily traffic as a result of material deliveries and construction personnel involved with a construction of an RNG facility. Careful selection of the proposed plant location is required to ensure that access to the plant and to LFG supply is maintained during and after construction and not impaired by landfill development.
Where pipelines are to be constructed to deliver RNG to an existing natural gas pipeline, pipeline routes should be deeply investigated to assess challenges in the route due to right-of-ways, land use, presence of water bodies, sensitive habitats, or cultural resource impacts (discussed in the following), presence of existing pipelines, railroad tracks, and other features that may make the project overly difficult or financially infeasible.
Local Utility Connections and Existing Infrastructure
In many cases, landfills are located in remote areas for various reasons and may not have sufficient local utility connections such as electrical power, sanitary sewer, and even potable water. RNG plants require considerable power for cleaning up LFG to natural gas pipeline quality. In some cases, electric service upgrades or a brand-new interconnection to the local electrical grid may be required for the LFG conditioning plant and related processes for delivering RNG to market. Extensions of the existing utility services are often costly and have long lead times depending on the cooperation of the local service provider and location, which could significantly affect overall project costs and schedules. Early outreach to utility companies to identify the appropriate department for coordinating the interconnect and gauging the utility’s willingness to participate in the project are critical pieces of the planning stage. Much of the same can be said for obtaining the RNG delivery interconnect to an existing natural gas pipeline. Although utilities are being required more and more to incorporate renewable fuels into their portfolios, if their annual obligations have been met, or if the project size is not considered worthy of the utility’s time and effort, it can be challenging and costly to obtain an RNG interconnect agreement. Gauging the appetite of the existing natural gas pipeline utility to permit an interconnect should be done before finalizing the alignment of the RNG delivery pipeline from the landfill source to the existing natural gas pipeline and before obtaining right-of-ways for the pipeline, which is an arduous process.
With respect to sanitary sewer service connections, these are typically permitted through state and local health departments. Although RNG projects do not generate considerable wastewaters, if local sanitary sewer is not present, new service may need to be permitted and brought into the site to dispose of condensate and facility wastewater. If bringing the sewer to the project location is not an option, permitting and installing alternatives for wastewater disposal will need to be evaluated and included in the overall development cost and schedule.
An assessment of existing landfill infrastructure critical to the operation of the RNG plant should be conducted during the planning stage of the project. RNG plants will need to tie into the landfill’s existing gas collection and construction system (GCCS) and possibly into the leachate collection and removal system (LCRS) for disposal of wastewater if permitted. Particular attention should be focused on the location and connection requirements to these systems. There may be an instance where the host landfill may have, as part of their future development plans, a third-party vendor working on constructing extensions or modifications to the existing landfill infrastructure. Depending on the extent and proximity of the work to the proposed RNG project location, an added measure of coordination between the project stakeholders may be warranted in order to avoid conflicts, align schedules, and ensure successful completion of the projects.
Environmental, Ecological, and Cultural Resource Challenges
Environmental, ecological, and cultural resource reviews will generally be required for the construction and operation of RNG plants and pipelines, and, in some cases, even when the RNG plant will be constructed within the confines of the existing landfill boundary if the existing permits and prior environmental impact assessment did not include such a facility.
RNG projects should include an environmental and cultural assessment for all areas impacted by the project. Many parts of the U.S. have restrictive measures in place that may limit or affect a project’s development due to the presence of wetlands and streams, sensitive or threatened and endangered species, and cultural resources in the vicinity of the proposed plant or pipeline. Project stakeholders should incorporate, at a minimum and as early as possible, a desktop review for any environmental or cultural indicators that may impact consideration of a potential site and pipeline alignment. Streams and wetlands play a vital role in our ecosystems and particular attention should be given to the proximity of the RNG project components to these features. In certain areas of the U.S., environmental assessments are required to be performed by certified or licensed professionals and often have seasonal restrictions (e.g., growing season). Therefore, it is important to verify regional restrictions prior to developing schedules for RNG projects. With the ever-changing rules regarding the Waters of the U.S. and the increasing costs for stream and wetland mitigation, RNG project developers need to be intimately familiar with the proposed RNG plant location and pipeline routing options. Desktop information is not sufficient, and the entire project footprint should be reviewed in the field by team members prior to the design phase to look for physical barriers to construction or potential environmental and cultural impacts that would need to be mitigated. Overlooking protected species or restricted land uses can severely impact a project’s schedule and costs.
Air quality impacts of an RNG plant, although typically resulting in lowering an overall facility’s emissions, also need to be reviewed, and the emissions from typical RNG plant equipment, such as thermal oxidizers and/or waste gas flares will need to be calculated, modeled, and permitted for the identified location of planned equipment. Once these sources are permitted, any changes in the equipment or their ultimate location will require a permit modification, which will likely impact the project schedule.
Consider All Aspects
There are many aspects that need to be considered when planning and developing an RNG project. While the items mentioned in this article are not comprehensive by any means, it is the intent of the author to provide topics and discussion points for project stakeholders to bring to the table when working through the project planning and developing process. It is an exciting time for the solid waste and renewable energy market sectors and due diligence well in advance of project kickoff is extremely valuable for the ultimate success of these projects.| WA
Darrell Thompson is a Vice President and the RNG Market Lead for Civil & Environmental Consultants, Inc. Based in California, he is responsible for expanding CEC’s RNG market-related business throughout the U.S. reflective of the firm’s nationwide footprint. Darrell has more than 25 years of landfill gas engineering, recovery optimization, operations and maintenance, air quality compliance, and landfill gas use project experience. He can be reached at (619) 837-6540 or e-mail [email protected].
James Fields, P.E., is a Principal in the Civil/Site Practice of Civil & Environmental Consultants, Inc. He has more than 20 years of civil site design, site development, design-build, commercial, and heavy construction experience. He has designed and managed the construction of various types of projects including compressor and meter stations, natural gas well pads, pipelines, and access roads for energy producers. More recently, James has been instrumental in the site design and permitting process for RNG facilities from Oregon to North Carolina. He can be reached at (614) 842-3730 or e-mail [email protected].