Alternate: Road Trip III: A Path to The Road Less Traveled

The Washington Suburban Sanitary Commission's (WSSC) Bioenergy Program is developing a $271 million regionalized solids handling facility at the Piscataway Wastewater Treatment Plant (WWTP) in Accokeek, Maryland. WSSC is a water and wastewater utility that serves approximately 1.8 million residents of Prince George's County and Montgomery County, Maryland. The facility will receive biosolids from multiple WSSC facilities in order to consolidate treatment and produce Class-A biosolids using the thermal hydrolysis process (THP) and new anaerobic digesters. The project is being implemented through a progressive design-build delivery that is in construction, with startup expected in mid-2023. The program includes the production of renewable natural gas (RNG) from biogas and injection of RNG to the Washington Gas Light (WGL) pipeline system. WSSC's approach to its RNG program is self-implemented. By comparison, other utilities have pursued RNG programs with varying levels of public-private partnership (P3) for some combination of ownership/operation of RNG production facilities, contracting with end user(s) for the use of RNG in vehicle fleets, sales of the environmental attributes for RNG use in vehicles, and/or ongoing verification and management for the program. A guiding principle behind WSSC's approach is to accept risks associated with RNG sales and renewable identification number (RIN) markets, recognizing that the benefits from managing its program can be greater by allowing risk rather than seeking pricing certainty for RNG production and renewable credits. Components of WSSC's approach include the following: RNG production. A water wash scrubbing system is being installed for conversion of biogas to RNG. WSSC staff will operate and maintain the gas treatment system at the Piscataway WWTP. WSSC could elect to pursue contract maintenance of the gas treatment equipment based on its experience following startup of the facilities. Daily RNG enrollment to the WGL pipeline based on production will be by WSSC. The anticipated RNG production is 3.4 million therms over the first four years of production. Energy utility. Where WGL is the natural gas (NG) infrastructure utility for the Piscataway WWTP, in Maryland's deregulated NG framework, an energy utility sources and supplies NG to end users. WSSC has registered as an energy utility for the Maryland market and will use this approach to deliver RNG to an in-state end user. In addition, WSSC will source NG for use at its facilities, including a 4.5 megawatt cogeneration system at the Piscataway WWTP which is part of the Bioenergy Program to provide power, steam for THP, and other process heat. An alternate approach would be to utilize an existing energy utility as an intermediary for the transfer of produced RNG and purchase of pipeline NG. However, this approach would involve the sale of the RNG fuel value to that utility and likely some portion of the environmental attributes. If WSSC sold its gas to an out-of-state end user, the step of becoming an energy utility likely could be bypassed, but an intermediary might be required to use WSSC as the RNG source and to source additional NG supply for the end user. RNG sales. To generate RINs from RNG, the fuel must be utilized in vehicles. From early in the development of the Bioenergy Program, WSSC identified the local transit agency in Montgomery County, Maryland, the utility's service area, as an end user for RNG. WSSC plans to become the sole provider of NG to the County, sourcing pipeline NG to supplement its RNG production to meet the transit fleet's fuel needs, as well as NG use at other county facilities. For the RNG, the environmental attributes will remain with WSSC. Montgomery County may pursue electrification of its transit fleet over the longer term. In this event, WSSC can seek another end user for RNG or consider the development of RNG-fueled power production for the transit fleet and the production of eRINs for electric vehicle charging. Program verification. Key parts of establishing a RNG program are the initial producer registration with USEPA, third party engineering review, and ongoing outside auditing for RIN verification. WSSC issued a request for proposals (RFP) for this work and ultimately contracted with Weaver LLC to perform these functions. The initial data collection regarding the facilities has occurred so that Weaver will be positioned to perform its engineering review and enroll the facilities with USEPA as they come online. RIN sales. WSSC has developed a sales solicitation for RINs from the program and will issue it for response in early 2023 in anticipation of starting production later in the year. Multiple entities are potential purchasers for RINs. Under the Renewable Fuel Standard (RFS), a group of obligated parties, typically fuel refiners, are required to use renewable fuels or purchase RINs as credit against their use. This generates the market for RINs. In addition to these companies, brokers also serve as intermediaries to bundle RIN credits for sale to the obligated parties. Ultimately, the solicitation is structured to select based on qualifications as well as the buyer providing the highest percentage of the Oil Price Information Service (OPIS) index price for D3 RINs (a cellulosic fuel category associated with RNG production from municipal wastewater) to WSSC as compensation for the credits. Ongoing program management. Because of its size, WSSC has a dedicated energy management team. This team has been instrumental in developing the self-implemented approach for the RNG program. In addition to its in-house staff, WSSC has used specialty consultants in addition to the program verification consultant for assistance in establishing itself as an energy utility. As the program moves from establishment to execution, WSSC will have the flexibility to maintain program functions in house or to bundle functions into outside contracts that it will manage going forward. The RNG portion of the Bioenergy Program is anticipated to generate a net revenue of approximately $9.6 million in the first four years of operation.