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MWMC MEETING AGENDA
Friday, October 11, 2019 @ 7:30 a.m.
City of Springfield City Hall, Library Meeting Room
225 Fifth St., Springfield, OR 97477
Turn off ceii phones before the meeting begins.
7:30 - 7:35 I. ROLL CALL
7:35 - 7:40 II. CONSENT CALENDAR
a. MWMC 9/13/19 Minutes
Action Requested: By motion, approve the Consent Calendar
7:40 - 7:45 III. PUBLIC COMMENT
Request to speak slips are available at the sign -in desk. Please present request slips to
the MWMC Secretary before the meeting starts.
7:45 - 8:10 IV. RENEWABLE NATURAL GAS (RNG) MARKETING AND SALES AGREEMENT (P80095)
........................................................................ Josh Newman
Action Requested: By motion, move to approve Resolution 19-15
8:10 - 8:25 V. FY 2018-19 ANNUAL FINANCIAL SUMMARY, BUDGET RECONCILIATION
........................................................................Valerie Warner
Action Requested: Informational only
8:25 - 8:55 VI. FY 2017-18 MWMC GREENHOUSE GAS INVENTORY REPORT
................................................................... James McClendon
Action Requested: Informational only
8:55 - 9:15 VII. BUSINESS FROM COMMISSION, GENERAL MANAGER, & WASTEWATER DIRECTOR
9:15 VIII. ADJOURNMENT
The meeting location is wheelchair -accessible. For the hearing-impaired, an interpreter can be provided with 48 -
hours -notice prior to the meeting. To arrange for service, call 541-726-3694. All proceedings before the MWMC are
recorded.
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Metropolitan Wastewater
MANAGEMENT COMMISSION
AMSPRINGFIELD
OREGON
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MWMC MEETING MINUTES
Friday, September 13, 2019 at 7:30 a.m.
City of Springfield City Hall, Library Meeting Room
225 Fifth St., Springfield, OR 97477
Vice -President Pat Farr opened the meeting at 7:30 a.m. Roll call was taken by Kevin Kraaz
ROLL CALL
Commissioners Present: Pat Farr, Joe Pishioneri, and Jennifer Yeh
Conference Phone: Doug Keeler
Commissioners Absent: Bill Inge and Walt Meyer
Nota quorum but Commissioner Ruffier would arrive at 8 AM to make a quorum then.
Staff.- Meg Allocco, Dave Breitenstein, Matthew Hays, John Huberd, Kevin Kraaz, Shawn Krueger, Troy
McAllister, James McClendon, Tom Mendes, Todd Miller, Brian Millington (attorney), Michelle Miranda,
Josh Newman, Matt Stouder, Valerie Warner, and Greg Watkins.
Guest: Wayne Gresh, Carollo Engineers
PUBLIC COMMENT
There was no public comment.
RESILIENCY PLAN UPDATE (P80096) - CRITICAL DEPENDENCIES ASSESSMENT
Josh Newman, Managing Civil Engineer, stated that the resiliency study has major components and part
of it is the assessment of the facility and understanding the interdependencies with other agencies and
with the supply chain. The interdependencies are very complicated and it took thoughtful effort to
narrow it down to the top ten interdependencies. There are many interdependencies and the key ones
will be discussed today.
Mr. Newman introduced Wayne Gresh, from Carollo Engineers. Mr. Gresh is the project manager for the
team doing the Resiliency Plan. He said the Seft Consultant Group was the lead on the
interdependencies assessment and they were supported by Infra -Terra who did the electrical
assessment. Infra -Terra had already worked with the BPA and other utilities on electrical so they had the
information. McMillen Jacobs didn't participate on the interdependencies but they had done the
geotechnical work on setting the standards and ground motions for the mobility assessment.
September 13, 2019 MWMC Meeting Minutes
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Work Progress: Mr. Gresh stated that the critical interdependencies assessment was given additional time
to address disruption of electrical service. He stated the facilities seismic vulnerability assessment was
completed as well as identifying what impact climate change might have on flooding. The
interdependencies and flooding assessment were the last two tasks completed. Draft reports for those
two tasks were given to staff to review. His team is now moving on to look at recommended mitigation
and management measures and the cost for those. His team will be holding a workshop with staff to vet
those and then closing it up with memos and a final report. Mr. Gresh said they are still on schedule for a
late November delivery of the final plan.
The Critical Interdependencies Assessment's Objectives: The objectives were to 1) assess the top 10
dependencies that could substantially affect recovery; and 2) identify mitigation strategies to minimize
potential for cascading failures. For example, if you need fuel, you also need the roads, streets, and
transportation and you need the suppliers and vendors. Any one in that chain that fails, then the whole
system fails.
Mr. Gresh explained it was a collaborative effort in identifying the top ten dependencies. The Carollo
Engineers provided a matrix to help identify and rank dependencies. The staff worked very hard at
identifying and creating a detailed list of vendors. Three internal workshops were held to go through the
list of dependencies and then those were reviewed by Eugene and Springfield Emergency Managers.
Top 10 Dependencies:
1. Employee and Family Preparedness
2. City/Regional Roads
3. Telecommunications
4. Structural Inspection
5. Emergency Operation Plan (EOP) and Continuity of Operation Plan (COOP)
6. Power
7. Data
8. Vendors and their Shipping Services
9. Fuel
10. Mechanical, Electrical, Plumbing, & Equipment Assessments
Seft Consultant Group developed an employee preparedness survey and that was provided to the
MWMC staff. It had 30 questions in four categories: planning, home preparations, supplies, and first
responder readiness. The questions were formulated so that a "yes" response indicated a positive level of
preparedness and a "no" response indicated lack of preparedness. Eighty-two employees responded to
the survey and about 59% of the questions were a "yes" response. By category, the results were as
follows: Planning 47% yes; Home Preparations 71 % yes; Supplies 61 % yes; and First Responder Readiness
58% yes. They were good results. Two questions focused on who could come and would be available to
work at the facility in a post event. One asked if they have to cross a river to get to work and 54% said
they did. The other asked if they have family responsibilities that would prevent them from returning to
work and 52% said they did. When you look at both questions combined, 33% of the workforce would
be available on day one of an event.
Mr. Gresh recommended that staff participate in The Great Oregon Shake Out as an organization. He said
their website has tremendous training materials, checklists, and videos. The MWMC could sponsor
September 13, 2019 MWMC Meeting Minutes
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training activities and competitions in emergency preparedness for employees with rewards (usually
emergency supplies). The Emergency Managers could do some training.
MWMC's Emergency Operation Plan (EOP) and Continuity of Operation Plan (COOP): The emergency
operation plan's structure is based on the National Incident Management System (NIMS). Emergency
Operations Center (EOC) establishes response priorities based on hierarchy of 1) life safety, 2) asset
protection, and 3) environmental protection. Wastewater is not high on the list. In an emergency, the
Emergency Managers' authority is limited by their boundaries. The MWMC will operate under three
EOCs: Eugene, Springfield, and Lane County. Staff will be working according to their City's priorities. If
you are an employee of the City of Eugene, you may be taken to work on life safety issues first and not
on wastewater. For the period of the emergency response, lines of authority would flow through the
Emergency Operations Centers.
Commissioner Pishioneri asked if when the survey asked if an employee would have to cross the river, if
they looked at the geographic location of staff to see if they could be used more efficiently where they
were located, rather than by which City they were employed. Mr. Stouder replied that the Emergency
Managers of each city are looking at that and are trying to come to an agreement that could be put into
place. Mr. Gresh added that the MWMC is not the only organization that has that problem, (for example
the fire departments) so the Emergency Managers will be working on that agreement.
Mitigation Strategies: Mr. Gresh said it is very important for staff to understand emergency management
structure and protocols and the nomenclature. He said that although the plant has a Continuity of
Operation Plan (COOP) in place, it does need to be expanded to include Springfield. Updating the plans
and keeping them updated is very important as well as having staff trained on them. Also, to look at
whether any policies need to be put into place to enable employees to work back and forth (between
the two cities) and how they are to be paid.
City/Regional Roads: What we found out is that Beltline, from highway 15 to 99, is not a priority highway
as well as some critical bridges. The 15 corridor is a high priority (Tier 1). The mitigation strategy is for the
MWMC to support the Emergency Managers efforts to add the critical bridges and the two segments of
roadways, Beltline and Highway 126, to the State's priority routes.
Telecommunications: Emergency Managers (EMs) are not relying on cell phones, the first responder
network, or satellite phones as they all have issues. They found out that amateur radios work well.
Mitigation strategies are to follow protocol (EMs make contact with outside agencies for help and
supplies) and to follow a multi -faceted strategy: amateur radio, public safety and handheld radios, and
broadband internet. If you need outside help, you have to go through the protocols.
Power: Bonneville Power Administration (BPA) provides most of the electrical power to EWEB and SUB.
They have assessments that show various failure modes. They do expect to lose a lot of towers - they
don't know exactly how many because that is dependent upon where the center hits and how the
ground motions are. They are saying that it would take up to eight weeks to restore the grid. It is being
worked on. We found it difficult to get any information from EWEB and SUB because of confidentiality
agreements that are not in place with the MWMC. Mitigation strategies: to execute agreements with
EWEB and SUB to assess vulnerabilities, consider strategically locating portable generators, and to
identify volume of fuel required for generators.
September 13, 2019 MWMC Meeting Minutes
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Commissioner Farr said that he heard at the Emergency Preparedness meeting that Oregon has about a
3-5 day supply of transportation fuel. Mr. Gresh said that is correct.
Structural Inspections: The Cities have certified inspectors including some in the Wastewater Division and
we could get help from local structural engineering firms. Mitigation strategies include prioritizing
facilities and processes to be inspected and to consider emergency on-call services contract.
Data: The MWMC has three different categories of servers housed in different locations. Mitigation
strategies are to maintain critical information in both electronic and hard copy, maintain a backup image
of data, and have emergency generators to power critical hardware. Mr. Gresh recommends keeping the
hard copies at strategic locations. For example, for remote pump stations have hard copies out there as
well as at the central location.
Vendors and Shipping Services: Staff identified critical supplies and vendors. They ranked them and have
the top five vendors that should have contracts in place in case of an emergency. Mitigation strategies
recommended is to stock 2-4 weeks of chemicals and consumable supplies, and to establish agreements
with vendors and suppliers for emergency needs. Mr. Gresh said that you could sign agreements with
the vendors to have the MWMC as a priority. At the very least, start working with the vendors to
understand what their emergency response continuity operation plans are, their transportation plans,
and how they are going to prioritize their operations and customers.
Fuel: Fuel is a major dependency for all of Oregon. The state is working on a fuel strategy but it will take a
while to implement it. The Emergency Managers are working on storing more fuel at fire stations. They
also made it very clear that they are in charge of the fuel supply and it will be rationed based on the
priorities mentioned earlier with life safety being the highest priority. Under the disaster scenarios
contemplated in the resiliency plan, the Emergency Managers have the authority to take any fuel supply,
public or private, and allocate to the highest priority. The mitigation strategies are to support the
Emergency Managers' efforts to increase storage, to locate storage strategically, and to employ
operating strategies that minimize consumption.
Mechanical Electrical Plumbing and Equipment Assessments: Contractors have a history of assisting in
disasters. Transportation will be a challenge for movement of contractor's personnel, materials, and
equipment. The mitigation strategies are to prioritize facilities and have agreements with contractors.
Commissioner Farr stated that in a wide spread emergency, security is an issue especially in regards to
fuel. He asked how we would keep our facility secure. Mr. Gresh replied that it was not discussed. Mr.
Newman added under a disaster scenario, property security is the police's responsibility and the need
will increase over time as resources become scarce. Mr. Gresh stated that security is something that you
will want to understand and have a plan especially if you become a site to house people. Mr. Newman
said there had been some great discussions in the workshops, and they had started to discuss security.
He pointed out that this is a gap analysis where all the gaps are illuminated. One of the conversations
they had was in regards to the land directly across from the Owasso Bridge. Under a Cascadia
Subduction Zone earthquake event, the Owasso Bridge could fail structurally. The area on the other side
of the bridge is an area for getting people to a safe place. It is part of a route to get to the North Eugene
High School. If we can fortify the bridge, and people can get from that neighborhood to our facility
where we have emergency generation and well water, it might make a good place to have a tent camp
September 13, 2019 MWMC Meeting Minutes
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or lodging shelter. There seems to be interest in that at the emergency management level. Therefore, if
we can couple with that, it makes us a higher priority; we would have security prioritized to that area.
Next Tasks: Mr. Gresh said that they are working on a memo that summarizes the recommended
mitigation strategies and has an opinion of cost for those recommendations. Workshop 6 will be held to
review strategies and finalize mitigation strategies and costs. They will consolidate all the information
that they have put together into the Plan. They will present it at Workshop 7 and take comments and
then finalize and submit the Plan.
Commissioner Keeler asked what comes after number 10 in the priority list. He figured that there are
other important things that did not make it to the top ten list and wondered if they are kept on an active
list. Mr. Gresh said that staff has a good list; they went through and vetted it. He would not put that list
away but to keep working with it. Mr. Stouder replied that staff does have a list compiled. Mr. Newman
stated he could email it to him. Commissioner Keeler replied that he did not need the list he just wanted
to know if staff was keeping track of things like security. Mr. Gresh said his recommendation in general is
if you are going to be prepared, you need to make it a proactive effort. That means you are going to put
resources and time into it. You have already spent a lot of money on his team's work and a lot of effort
by the staff, you just need to keep the momentum going. Commissioner Keeler said it would add value
even if there were no emergency; this will make us more resilient and better able to handle whatever
does come.
8.00 AM Commissioner Ruffier arrived to make a quorum.
Commissioner Ruffier asked if we are totally dependent upon outside experts to do structural
assessments. Mr. Gresh replied that you have a number of people trained (in the City) and even some in
the Wastewater Division. Under the national system, people can take a training course for these
assessments. You do not have to be a licensed structural engineer. If you get into some life -safety type
things, you may want to get a license structural engineer. Mr. Breitenstein said that the structure
assessment training was a citywide effort so a lot of people from Public Works, from all divisions, were
offered the training. Mr. Newman stated that even if we do have people trained in the Wastewater
Division for structure assessment, in an emergency those people may be dispatched to assess other
structures in accordance with life -safety priorities across the City of Eugene. All resources will be directed
through the Emergency Managers. It has to be looked at holistically.
Commissioner Pishioneri said that he appreciates all the work that has been put into this but suggested
that when we have a plan, before it is adopted, it should go through the Emergency Managers to get
their input. Mr. Gresh replied that the Emergency Managers have been actively participating at all the
workshops and have reviewed all the documents. Mr. Gresh said that he agrees with Commissioner
Pishioneri that our desire would be that it would align with what is being done in the area so we are not
a silo. The Emergency Managers really would like us to partner with them to give weight to their
requests to the state. It is also important to partner with EWEB and SUB on water and power supplies. Mr.
Newman said that you have to think more as a community then as individual organizations.
September 13, 2019 MWMC Meeting Minutes
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CONSENT CALENDAR
a. MWMC 7/12/19 Minutes
MOTION: IT WAS MOVED BY COMMISSIONER YEH WITH A SECOND BY COMMISSIONER PISHIONERI
TO APPROVE THE CONSENT CALENDAR AS PRESENTED. THE MOTION PASSED
UNANIMOUSLY 5/0.
FY 2019-20 SUPPLEMENTAL BUDGET #1
Valarie Warner, MWMC Accountant, requested approval of Resolution 19-14 authorizing proposed
supplemental budget requests for FY 2019-20. She then went over Supplemental Budget #1.
Ms. Warner explained that Supplemental Budget #1 was the normal adjustments needed to balance the
actual ending balances in FY 2018-19 to the estimated beginning balances budgeted for FY 2019-20.
Staff is requesting that a portion of the additional cash carryover from FY 2018-19 be allocated among
carryover requests for existing projects and new spending request with the remaining amount recorded
as additions to reserves. The specific requests are listed below.
Operating Fund:
x Increase the Operating Reserve $710,118 to adjust Beginning Cash.
x Carryforward $183,632 for three items listed below:
o $93,650 for Small Home SDCs (leftover from previous budget year)
o $77,100 for capital outlay (for Lab and Maintenance building improvements)
o $12,882 for Contractual Services (for Digital Marketing Strategy)
Capital Funds:
x Increase Beginning Cash by $8,862,240 to align with the actual cash balance at June 30, 2019
x Carryforward $5,873,991 for Capital Projects not completed in FY 2018-19 (see complete list in
memo)
x New Spending Requests $116,040 for three projects listed below:
o $18,703 for the Thermal Load Pre -Implementation Study
o $77,337 for the Riparian Shade Credit Program
o $20,000 for the Comprehensive Facility Plan Update
® All previously discussed at MWMC meetings
x Carryover of $90,000 for Equipment Replacement to fund an emergency generator
If the Commission approves the carryforwards and the additional funding requested for the Capital
Fund, there will be a net amount of $2.8M that will be added to the budgeted reserves for FY 2020.
CWSRFLoan: Ms. Warner went over the MWMC's debt showing a slide with the 3 SRF loans listed and the
2016 Revenue Bonds. The 2010 SRF loan has the highest interest rate and is the largest at $5,314,777. Mr.
Stouder said that a SRF loan is a fixed amount that the DEQ has made available as a revolving fund for
clean water projects. If we pay the 2010 SRF loan off, then the funds are available for other agencies to
use.
Commissioner Farr stated that we have before us two versions of Resolution 19-14. Version 1 does not
include paying off the SRF loan and version 2 does. Mr. Stouder stated that in both versions of the
resolution that went out with the memo to the Commission, the last "Whereas" was left off and the
September 13, 2019 MWMC Meeting Minutes
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second to last sentence was left off. They are now both added back into both versions of Resolution 19-
14. He read them to the Commission.
DISCUSSION: Commissioner Ruff ier favored paying off the loan because it would make the money
available for others sooner and the MWMC is in a favorable financial position right now.
Commissioner Keeler said that he also favors option two - paying off the SRF loan.
Commissioner Farr looked around at the Commissioners and stated he saw nods of agreement for
paying off the loan.
MOTION: IT WAS MOVED BY COMMISSIONER PISHIONERI WITH A SECOND BY COMMISSIONER YEH
TO APPROVE RESOLUTION 19-14, Version 2. THE MOTION PASSED UNANIMOUSLY 5/0.
NPDES PERMIT RENEWAL UPDATE
Todd Miller, Environmental Management Analyst, stated that it is staff's intention to report to the
Commission semi-annually to give updates on the permit renewal process. The MWMC's NPDES permit
has been pending renewal for quite some time but some progress was being made on the DEQ's front as
well as our internal preparedness.
Mr. Miller gave an overview of the 1972 Clean Water Act (CWA). Its overall goal was to "restore and
maintain the chemical, physical, and biological integrity of the Nation's waters". It set timelines that by
mid -1983 to have water quality goals to protect fish, shellfish, wildlife, and recreation and by 1985 to
achieve the elimination of discharge of pollutants into waters. Pollutants are defined as substances at
toxic levels. Portions of the CWA were modeled on Oregon's laws. Oregon led the nation starting back to
the 1930's when it created the state sanitary authority. That was the first time the cities were required to
have some sort of wastewater treatment.
The National Pollution Discharge Elimination System (NPDES) framework is the permit system that
regulates the water quality goals and criteria that we have to meet in order to operate the treatment
plant. As a federal law, it is under the Environmental Protection Agency (EPA) but permitting authority
has been delegated to most of the states. In Oregon, it is through the DEQ. Either the state or the EPA
can adopt water quality standards. Oregon adopts most of its own. The EPA must approve all the
standards. The EPA may federalize state actions or programs at their own discretion or by lawsuit, (if the
lawsuit challenges that the state is not doing enough).
NPDES Framework: Water Quality Standards & Limits consist of three main things: 1) The Stream listings
for water quality impairments (known as 303(d) lists) - updated every two years; 2) The Water Quality
Standards or the minimum protective levels to protect the waters - updated every three years; and 3)
NPDES permit (discharge limits) - to be renewed every five years. The permit can be delayed due to
complex water quality issues and legal challenges. Oregon's NPDES permit program is under extensive
backlog, affecting the renewal of the MWMC's permit.
MWMC's Permit Timeline: Since 1983 when the first NPDES permit was given to the MWMC, we have gone
through the equivalent of seven plus permit cycles. In reality, we are on our third permit. The MWMC has
applied for renewal on time for each of those cycles and it has been in the DEQ's hands to renew the
permit. They were delayed for various complexities and they were not ready to renew the permit. There
September 13, 2019 MWMC Meeting Minutes
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are pros and cons of Administrative Extension. With Administrative Extension, you just continue to
operate under the existing permit - no new requirements. However, it also locks you into that permit
and it is very difficult or impossible to change some of your operations, i.e. your biosolids, water
management plans, or pretreatment programs. If you add new technologies to your facilities, they are
not necessarily permitted to operate under the extended permit. The MWMC is twelve plus years into
the Administrative Extension.
Permit Challenges: Oregon has one of the longest backlogs in the country for permit renewals. As of
December 20, 2018, of the total 348 NPDES individual permits, 273 are on administrative extensions. Of
the 273 extended permits, 147 have been for 5 years or more and 46 are 10 years or more. Of the 46, the
MWMC is #19 overall and #8 out of municipal wastewater permits. The DEQ considers the MWMC a low
priority overall, they have higher priority permits that are more critical for water quality protection
purposes.
Commissioner Ruffier asked if the DEQ gave any rational for giving the MWMC a low priority rating. Mr.
Miller replied that they need to get all of the permits in the state up to speed to be more protective of
the water quality. The MWMC may not be as critical overall in the context.
The DEQ has undergone several steps to address the permit backlog at the bequest of the State
Legislature. They had an independent review with recommendations and they have completely
restructured their staffing, hired some new people, shifted some people around, and centralized their
permits so that there are not different interpretations on the way permits should be issued in different
regions of the state. They did a readiness review where they went through and scored all the permits,
which had to do with the individual applicants having to supply all the data and get their data up-to-
date. The MWMC is ready in that regard. Then they take into consideration the complexity of renewing
the permit - for example if there are TMDLs that are outstanding or unresolved. The MWMC falls into
that camp; the MWMC's permit ranks amongst the most complex in the state.
Commissioner Farr stated that he thought that the MWMC should be up higher in the priority list. We
are higher upstream. He feels a bit alarmed that we are going on 12 years in administrative extension.
Mr. Miller said that he could follow-up with the DEQ to find out a bit more about that. Mr. Stouder stated
that high priority is low hanging fruit at this time. The DEQ is under immense pressure from the EPA to
get their backlog reduced. Their backlog permits consist of a lot of complex permits as well as some that
are not as complex, which are the low -hanging fruit - the ones that will ease their backlog (and therefore
get a higher priority).
Commissioner Farr asked if it was correct that we have equipment and technology that is outside of the
permit right now. Over the last 12 years, we have brought stuff on line. Mr. Millington replied that the
permit addresses the outfall and we have not changed the outfall. The processes are being modernized
but they are not changing from what the permit allows. He is not concerned about the work that has
been done. It does affect some things like the shading program. We can get that ready to go, but the
credits are not in our current permit.
Commissioner Pishioneri said that he thinks that the DEQ gave the MWMC a low priority because we are
a low risk to the environment. They realize that the MWMC's operations are well established and that we
are doing a good job. He believes that is why we are not high on the DEQ's priority list.
September 13, 2019 MWMC Meeting Minutes
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Commissioner Keeler said that it may not be in MWMC's interest to expedite the process because there
are a lot of things that need to be settled around regulatory questions and litigation. While it may
hamstring us a bit, we have been able to make improvements to the plant. He feels it would be a shame
if we went the wrong way on this only to have a regulation change and cause us to do rework.
Mr. Miller said that he expects that what Commissioner Pishioneri stated about the MWMC doing a good
job might be part of that low priority rating.
DEQ also has a Permit Issuance Plan (PIP). The PIP is a document that the DEQ issues on annual basis and
it lists all the permits that the DEQ intends to renew in the coming year. They base it on geography,
readiness, and priority. They try to renew permits in all areas of the state. The Readiness review, where
the MWMC ranks among the most complex, is not a prioritization in itself. The DEQ has reflected to us
that they are balancing out many easy permits with one or two complex permits. They would get further
behind if they focused on a bunch of complex permits in a single year.
Commissioner Farr asked if it is safe to presume that we are behind in the permit not due to our doing;
that it is completely out of our hands. Mr. Miller said that is correct.
The DEQ will issue a 5 -year PIP around October this year, and then we should have a better idea about
our permit renewal timeline. They are also focusing on wrapping up the TMDLS because that has really
held up the permit process.
TMDLS: In 2006, both the Temperature and Mercury TMDLS were issued to the MWMC. They gave either
a narrative requirement or a wasteload allocation. There were a number of challenges over the years.
The Mercury TMDL had revised mercury criteria based on the Human Health criteria and the fish
consumption rate. The Temperature TMDL needs to be rewritten.
Temperature TMDL: In 2018, the DEQ issued an interim policy for adopting temperature limits in permits
they are currently issuing. The policy is based on the more stringent of the two criteria: the 2006 TMDL
waste load allocation or the pre-TMDL calculation of thermal load limit at the point of discharge. A
recent court ruling that was adopted by the DEQ is a schedule of issuance of all new temperature TMDLS
across the state, over a five-year period (2023-27). The Willamette is a priority but they are going to do all
the tributaries first, then the main stem. Staff's expectation is that the MWMC's TMDL (on the main stem
Willamette) will be towards the end of that period. The MWMC is probably looking at a permit pre-TMDL
issuance, which means we will have the more stringent thermal load limit. The DEQ is issuing 10-20 year
compliance schedules for complying with temperature loads. They do not expect you to be fully
mitigated within the 5 -year cycle. When the new TMDL is issued, it will supersede the pre-TMDL thermal
load limit (TMDLS are not subject to anti -backsliding requirements).
Commissioner Ruffier stated that seems counter -intuitive. If you are working towards a more stringent
standard, even if anti -backsliding does not apply, you are putting a lot of effort and money into it. Mr.
Miller replied that he does not know what will happen if we actually meet the more stringent TMDL
before the new TMDL comes out. Commissioner Ruffier asked if the DEQ could legally wave anti -
backsliding.
Mr. Millington replied that it is actually within the regulations but it does not apply towards the TMDL.
He said the challenges are big and the compliance schedule is allowing a little bit more time. He thinks
September 13, 2019 MWMC Meeting Minutes
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that to accomplish the lofty goals, more time will be needed to make the changes. It is definitely a lower
likelihood that we would have exceeded already what those new goals are. He doesn't think it will be a
problem that we will have to deal with.
Mercury TMDL Staff was on advisory committees for both the Willamette Mercury TMDL and the
Willamette MDV (multi -discharger variance). The DEQ developed both of these in parallel. The TMDL
should take precedence and as long as the TMDL holds, we do not need the MDV. Compliance will be
met through adoption of minimization plans to reduce sources of mercury upstream from treatment
plants. The MDV imposes a mercury limit based on what you are currently achieving and you cannot
backslide on that.
Other Permitting Issues: There are a host of other permitting issues that are either new or are evolving.
These issues includes the new copper standard, new aluminum standard, wet weather flows (blending
rulings and CMOM), mass loads (treatment capacity basis and wet weather exemption),
nutrients/biocriteria (EPA TBEL on nutrient removal and river algae growth), and toxics— modern
products and new concerns are phthalates and PFAS (Forever Chemicals).
Next Steps: Staff is looking forward to the DEQ's 5 -year PIP. It will give a framing for how to move forward
on temperature mitigation and the Facilities Plan updating. Water Quality Trading is not part of our
current permit but following the City of Ashland's lead and our readiness with the EWEB Pure Water
Partners program, we will be looking into a pre -permit agreement to get our trading plan adopted. That
means that the water quality -trading plan, just like the biosolids or recycle water plan, would become
part of the permit. We could get the water quality -trading plan approved by the DEQ in advance of the
permit and then it would be at the discretion of the Commission to move forward with the trading
program.
Commissioner Farr asked if, at that point, we could start amassing credits. Mr. Miller replied that we
would have much more regulatory certainty that our credits would actually count towards a permit. As
long as nothing else changes and water quality trading rules remain the same the day your permit is
adopted as when the trading plan was written, yes. He will follow up with the Commission with more
information at a future meeting. For mercury minimization, he said the main thing needed is updates to
the statewide template. ACWA is working with the DEQ to do that. Then lastly, continuing with the pre -
permit monitoring.
Commissioner Ruffier stated that our NPDES permit renewal application was filed in 2006. He expects
the DEQ to ask for an update with additional information and data submittal. He asked if staff knows
how much time the DEQ will give us to do this, because it takes a lot of extensive lead-time? Mr. Miller
responded that he does not know about the timeframe but staff is aware that we need to update our
permit application. It would behoove us to update the permit application and all the data. There has
been a mixing zone study, for example, since the 2006 application. Mr. Stouder stated that we will have
time to do it and staff expects it to be showing up on the 5 -year plan.
Commissioner Ruffier encouraged staff to coordinate with the DEQ to make sure that we know what
their data demands are going to be so we can schedule to get adequate data collection. Mr. Miller
responded that there are certain things we know are required, because we are paying attention. Such as
for mercury, if the MDV is adopted, they would want a five-year data set of mercury effluent and a
minimum of two before they issue the permit. Then they would update that as more data comes in. The
September 13, 2019 MWMC Meeting Minutes
Page 11 of 13
copper biotic ligand model (BLM) is the new model for determining copper toxicity because it is based
on a number of other aquatic chemistry components. For the copper BLM, you have to have a 2 -year
data set and we are currently partway through collecting that data. Mr. Miller assured the Commission
that staff is preparing in advance, as they are aware of those data needs.
Mr. Millington said that during the course of a permit, adjustments could be made to the permit. One of
the challenges during the Administrative Extension of a permit is that it is locked in; it can't be adjusted.
It is affecting us specifically in pretreatment. Some rules have had changes that allow streamlining, but
we cannot adopt those rules right now. In addition, some changes that are more stringent in the area of
pretreatment have occurred, and we have been looking at that very carefully. He just wanted to make
the Commission aware of this.
BUSINESS FROM COMMISSION, GENERAL MANAGER, AND WASTEWATER DIRECTOR
Commission:
Commissioner Keeler said that he would like to throw out an idea to the Commission that he and
Commissioner Ruffier have been talking about for a while. For an organization as large as the MWMC, it
is a good time to do some strategic long term planning. He thinks it would be good to look at the good
things we have done over the past ten years, at a very high level, and then look at our major initiatives
for right now. The bulk of the work would be for the Commission to think, at a high level, what should
we be taking on over the next ten years. We don't know what changes will come at us, but we can look
at things like renewable energy, reuse of materials, major projects, the state of our public engagement,
and those kinds of things. He doesn't think it would be a huge undertaking. He asked the General
Manager to think about what a brief memo to the Commission would look like that would describe our
major accomplishments from the past ten years and what we are working on now. He feels it is not
urgent so it is something to think about and take on if, as a group, the Commission feels it is of value.
Commissioner Farr asked Commissioner Ruffier if he wanted to add to that. Commissioner Ruffier said
he supports the effort. It was something that he had in mind when he was chair of the Commission but
did not get around to. He said staff does an excellent job of keeping the Commission informed of things
that are directly in our wheelhouse. There are a couple of items that come up from time to time that, in
his mind, the Commission would benefit from pre -discussion and deliberation; like extra territorial
extension to Goshen, the Coburg issue, insourcing - providing services to other communities, or some
of the expertise we have in laboratory service or pump station maintenance, repairs and stuff like that. In
the past, some things came up externally that we were not prepared for from a policy standpoint to deal
with. Perhaps giving some thought to that with discussions and deliberations to what our positions
might be should we get requests for these types of things. We often get requests to provide services to
other communities for biosolids, temporary biosolids treatment, or management. He thought it would
be worth having an opportunity, as Commissioner Keeler described, for the Commission to sit down to
strategically look a little bit more at the external factors.
Commissioner Farr said that he would support that. He said that besides Goshen, we have Short
Mountain, where Lane County is currently trucking 10-12 truckloads of leachate up the freeway each
day.
September 13, 2019 MWMC Meeting Minutes
Page 12 of 13
Mr. Stouder said that he could put together a high-level summary of past successes, initiatives that we
have completed, the issues we are working on now, and a high-level summary of where we are going.
He said he would try to have it ready for the November meeting.
Commissioner Farr asked Commissioner Keeler if that would work for him. Commissioner Keeler
replied it would work very well and it would give the Commissioners time to think about it, to see if this
is something they want to pursue. He appreciates the support.
General Manaaer:
x Community Outreach: Staff made a presentation on the MWMC at the Springfield City Club yesterday.
He thanked Todd Miller and Michelle Miranda for making the presentation.
x Goshen: Staff met with Lane County staff to discuss the Goshen project. Lane County staff is going to
the Lane County Board on September 24 to get approval to continue moving forward. Mr. Stouder
plans to attend the meeting. Lane County Public Works Director, Mr. Hurley, is tentatively planning to
come to the MWMC meeting in the fall/winter to give a high-level overview of the project.
x Personnel - Communications Positions: Laura Keir gave her notice after the July MWMC meeting and
is no longer working for the City of Springfield. We have a good pool of applicants for the
Communications position that we were recruiting for, and have hired one person with an offer out to
another. Rachel Snyder starts on Monday, September 16. She comes from Republic Services, a trash
and recycling provider for Linn, Benton, Polk, and Marion Counties.
x Blending: Mr. Stouder sent a letter to the Commission about a week ago regarding a letter that
Chairman Peter DeFazio sent to the EPA Administrator on blending. The letter expressed concerns
about blending and the blending process. Mr. Stouder has reached out to Congressman DeFazio's
office to discuss the MWMC's concerns. A meeting is scheduled for September 19 and Mr. Stouder
has a couple of folks that will join him for that conversation. He doesn't expect to change Chairman
DeFazio's mind but wishes to have a conversation about what we have in common, such as putting
dollars aside to make improvements in infrastructure. Also to have a conversation about how
blending is used.
x PFAS: It is a rising concern and the public might have questions about it especially after the movie
comes out this fall regarding this topic. A large number of wastewater plants in the state are moving
forward to do some sampling to get a baseline of what level of PFAS is in the wastewater. Staff plans
to do the same but will be judicious in how they sample because it is expensive. Staff plans to test for
PFAS in our effluent, biosolids, and possibly leachate. PFAS is used for oil -water repellency and is
contained in things such as microwave popcorn, rain jackets, tents, Teflon, etc. It comes out of
peoples bodies and ends up in the wastewater system. We are working with ACWA on public
educational messages. Mr. Stouder said he could provide additional information to the Commission
if they are interested.
o Commissioner Ruffier encouraged staff to look comprehensively in testing for PFAS, to include
leachate in the analysis. He thinks it is important to have some sense of where it is coming from.
He understands the testing is expensive but it would behoove us to get some good data.
o Commissioner Farr said that we could expect a higher public awareness because of the movie.
Mr. Breitenstein stated that there was a documentary done on this subject (The Devil You Know).
Commissioner Farr stated he would be interested in seeing the documentary to be prepared for
the questions that are going to come. Mr. Stouder said the baseline information would also give
the Commission and staff some information so we can at least say here is where we are. The
September 13, 2019 MWMC Meeting Minutes
Page 13 of 13
challenge is that there is not a standard for PFAS. There is a drinking water standard but no other
standards.
Wastewater Director:
x Biosolids Application: It went smoothly with no problems or complaints and is completed for the year.
x Public Comment. Mr. Breitenstein followed up regarding the public comment (June 2019 meeting)
about camping along the river. He said staff has been vigilant about monitoring the riverbank for
camping and addressing it. In May and June there were four different times staff sought assistance
from the Eugene Police in getting campers out. This was after the large camp was removed. Since
then we have had to remove about five yards of debris, which is relatively small compared to other
cleanups. In the last two months, there has been only one time each month to clean up.
x Distributing Control System: The computer system that runs all the treatment process was recently
upgraded to a wireless system. Before, there were stations out in the plant for Operators to check on
processes. Now, the operators have tablets that provide full mobility to see what is going on from
anywhere at the plant. Before doing the upgrade, a comprehensive security assessment was
performed and appropriate security measures were incorporated in the wireless system.
o Commissioner Ruffier asked if that gives you any ideas regarding 24 hour staffing in Operations.
Mr. Breitenstein replied not yet, it was just implemented. It doesn't allow people to leave the
console room. As we implement technology, it always allows opportunities to consider changes
in use of labor. Typically, when you implement technology, it may lessen demands on one type
of labor but increase it for another such as for maintenance of the technology.
o Commissioner Pishioneri said that we spent almost $118,000 for that upgrade; that is almost 2
FTE or 1.5 FTE. Are we saving that much, becoming more efficient, or getting enough out of that
system to pay for it. Mr. Breitenstein replied that the system that we had was due for a major
upgrade. Relative to that, this was a less expensive approach so there was a cost savings.
Commissioner Pishioneri said that the hard cost replacement is where you saved. Mr.
Breitenstein replied yes it was.
ADJOURNMENT
Commissioner Farr adjourned the meeting at 9:36 a.m.
Minutes submitted by Kevin Kraaz
Metropolitan Wastewater
MANAGEMENT COMMISSION
ANON6 6kOREGON
FIELD
partners in wastewater management
MEMORANDUM
DATE: October 3, 2019
TO: Metropolitan Wastewater Management Commission (MWMC)
FROM: Josh Newman, Managing Civil Engineer
SUBJECT: Renewable Natural Gas (RNG) Marketing and Sales Agreement (P80095)
ACTION
REQUESTED: Approve Resolution 19-15 (to be provided at the Commission meeting)
ISSUE
Staff has concluded a request for proposals (RFP) process and is scheduled to score and rank proposals
received on October 3, 2019. Following the proposal scoring, staff anticipates that the top ranked
proposal (or proposals) will be identified. At the October 11, 2019 Commission meeting, staff will share
the results and recommendations from the RFP process and request approval of Resolution 19-15
authorizing the Executive Officer (or designee) to negotiate an RNG marketing and sales agreement with
the top ranked Proposer(s) to produce revenues from the sale of the RNG and associated environmental
attributes.
BACKGROUND
On August 28, 2019, after receiving direction from the Commission, staff issued an RFP for the marketing
and sale of RNG (termed offtake services in the renewable fuels industry). The RFP divided these services
into two 'Proposal Option' categories:
Proposal Option 1: Basic Services - Under this option, the proposing firm would market the RNG fuel to
fleets with whom they either have existing, or are positioned to secure, fuel supply contracts. This service
allows the MWMC to generate environmental attributes having value under federal and state (Oregon
and California) renewable fuel programs.
Proposal Option 2: Compliance and Marketing Services - Under this option, the proposing firm would A)
provide the services needed to meet registration and annual reporting requirements of federal and state
renewable fuel programs, which are also required for the MWMC to generate renewable fuel attributes;
and B) sell the environmental attributes to parties that are obligated under federal and state regulations
to purchase these attributes.
Memo: Renewable Natural Gas (RNG) Marketing and Sales Agreement (P80095)
October 3, 2019
Page 2 of 4
A detailed description of the scope items that are included in Proposal Option 1 and 2 are provided in
Attachment 1.
The RFP also included the evaluation and weighting criteria that MWMC staff would apply to the
proposals in their ranking and selection process. These criteria are summarized in Table 1, 2, and 3
below.
Table 1 - General Company and Staff Information (criteria applied to each proposer organization/firm)
Global Proposal Requirement Weighting Maximum Points
(Applies to all Proposer firms) Factor Possible *
Organization Capabilities & Staff Qualifications 2.0 20
Compliance History 2.0 20
* Criteria are scored on a 1 - 10 scale with 10 being best. The maximum points possible is based on a score of 10 and then
multiplied by the weighting factor to yield the points scored.
Table 2 - Proposal Option 1 Cost Proposal Criteria
Group 1 Proposal Requirement Weighting Factor Maximum Points
possible
Guaranteed placement in OR and/or CA 1.5 15
Offtake RIN revenue share as percent of RIN value 1.5 15
Offtake LCFS credit revenue share as percent of
1.5 15
LCFS credit value
Offtake OCFP credit revenue share as percent of
OCFP credit value 1.5 15
* Criteria are scored on a 1 - 10 scale with 10 being best. The maximum points possible is based on a score of 10 and then
multiplied by the weighting factor to yield the points scored.
Table 3 - Proposal Option 2 Cost Proposal Criteria
Group 2 Proposal Requirement Weighting Factor Maximum Points
possible
Program registration services cost 3 30
Annual program reporting services costs 3 30
* Criteria are scored on a 1 — 10 scale with 10 being best. The maximum points possible is based on a score of 10
and then multiplied by the weighting factor to yield the points scored.
On September 18, 2019, staff received proposals from six (6) firms who responded to the RFP. These
firms are listed in Table 4.
Memo: Renewable Natural Gas (RNG) Marketing and Sales Agreement (P80095)
October 3, 2019
Page 3 of 4
Table 4 - List of Proposing Firms
Firm Name I Proposal Options Status
Submitted
Biomethane, LLC Option 1 only Responsive
Blue Source, LLC Options 1 and 2 Responsive
Clean Energy, LLC Options 1 and 2 Responsive
Northwest Natural Gas Co. N/A Nonresponsive
The Energy Authority Option 2 only Responsive
Trillium Transportation Fuels, LLC Options 1 and 2 Responsive
DISCUSSION
A proposal review committee made up of representatives from both the cities of Eugene and Springfield
was provided with all six vendor proposals. A proposal scoring and ranking meeting has been scheduled
for October 3, 2019. At this meeting, staff will apply the criteria presented in tables 1 through 3 to the
proposals received and deemed responsive. The results from this effort will not be available before the
distribution date of the Commission packet. For that reason, staff intends to walk in the results of their
scoring and ranking effort on October 11, 2019 for the Commission meeting.
Under the selection framework set forth by this RFP, it is possible for different firms to be selected for
each of the two proposal options. Or the same firm may be ranked highest in each group and be
selected for both options.
As show in Table 4, the NW Natural proposal to the RFP was found to be nonresponsive. In addition, staff
will be calling each firm the week of September 30, 2019 to clarify their intent of the Proposal and the
information provided therein. After scoring is accomplished on October 3, 2019, staff may conduct
interviews to provide more detail and get to know the staff of the top ranked firms. The results of these
activities will be discussed at the Commission meeting.
Legal counsel will prepare a resolution once the proposals are evaluated and interviews conducted. It is
difficult to prepare a resolution at this point because: (a) one or two proposers may be selected; and (b)
the fee structure may change based on whether one or two proposers are selected or based on which
proposer is selected for Option 2 services. A draft resolution will be provided to the Commission prior to
the meeting.
ACTION REQUESTED
Staff requests approval of Resolution 19-15 authorizing the Executive Director (or designee) to negotiate
and execute an Agreement for RNG Offtake and Market Services between the MWMC and the top ranked
proposer(s).
Memo: Renewable Natural Gas (RNG) Marketing and Sales Agreement (P80095)
October 3, 2019
Page 4 of 4
ATTACHMENTS
1. Detailed Scope Descriptions for Proposal Options 1 and 2
Detailed Scope Descriptions for Proposal Options 1 and 2
Two proposal options are allowed under the RFP and the Proposers were allowed to submit a Cost
Proposal for either one, or both proposal options. These proposal options are described below.
Proposal Option 1 - Basic Services
Under Proposal Option 1, the Proposer provides the following basic services:
1) Contracts with end users, vehicle fleets, or compressed natural gas dispensing stations
demonstrating virtual delivery and use of the MWMC generated RNG as transportation fuel.
The MWMC expects partner to match an average annual RNG production that increases over
time in accordance with the values shown in Section 3.2, Table 3-1. The MWMC and/or the
vendor selected for Proposal Option 2 will act as the RIN generator and must have copies of
all offtake contracts and CNG station locations to use for RFS registration with USEPA.
2) Provide contract details, such as locations of fueling stations, site access, volumes consumed,
and affidavits from end users, etc. to the MWMC and/or the vendor selected for Proposal
Option 2 for use in RFS, LCFS, and CFP project registrations.
3) Provide monthly meter readings and contracts or affidavits to the MWMC and/or MWMC's QAP
provider for compliance purposes.
4) Credit (RIN/LCFS/OCFP) sales to obligated parties if the MWMC deems the fee for these
services to be cost effective.
Under Proposal Option 1, the MWMC and/or the vendor selected for Proposal Option 2 is
responsible for the following:
1) Facility registration with USEPA, California ARB including CAGREET modeling, and Oregon
DEQ
2) Credit generation and management, gas storage during the project registration phase, initial
and annual reporting, and compliance
3) Participation in a Quality Assurance Program (QAP) to generate Q-RINs
4) Credit (RIN/LCFS/OCFP) sales to obligated parties
5) Payments to Offtake Services Provider for offtake services
Proaosal Option 2 — Proaram Comaliance and Market Services
Under Proposal Option 2, the Proposer provides the full suite of Program compliance and RNG
marketing services including the following:
1) Facility registration to ensure compliance with USEPA (including but not limited to items
listed in Table 1), California ARB (including but not limited to items listed in Table 2), and
Oregon DEQ (including but not limited to items listed in Table 3)
2) Credit generation and management, gas storage during the project registration phase,
reporting, and compliance (including but not limited to items listed in Table 4)
3) RIN reporting and recordkeeping (including but not limited to items listed in Table 5)
4) Annual Attest Engagement and Quality Assurance Program (QAP) verification to generate
Q-RINs (including but not limited to items listed in Table 6)
5) Credit (RIN/LCFS/OCFP) sales to obligated parties (including but not limited to the items
listed in Table 7)
ATTACHMENT 1
Page 1 of 4
Detailed Scope Descriptions for Proposal Options 1 and 2
Under Proposal Option 2, The MWMC is responsible for the payments to Proposer for the services
provided.
Reference Tables:
Table 1: USEPA Registration Scope Items
Scope
Item # Scope Item Description
1 Ensure that MWMC renewable fuel meets RFS fuel, feedstock and process qualifications.
Biogas, in particular, requires MWMC to meet specific RIN Generation, Registration and
Recordkeeping requirements (80.1246(f)(10)(ii), (f)(11)(ii), 80.1450(b)(1)(v)(D), 80.1454(k)
2 Create New Company Request and new user accounts in EPA's Central Data Exchange
(CDX) OTAQReg, EMTS and DC Fuels. This will require the MWMC to appoint a Responsible
Corporate Officer (RCO)
3 Prepare and assemble all documents required under 80.1450(b)1 and obtain an
engineering review by a third -party independent professional. The documentation in the
engineering review shall include process flowdiagrams of site, feedstock description,
identified CNG stations that will be paired to MWMC's RNG, required monitoring and/or
sampling, and the RIN generation plan
4 Once the engineering review is finished, a completed packet (New Company Request
paperwork from CDX OTAQREG, engineering review including COA and 80.1450(b)(1)
materials) can be submitted to the EPA
5 RNG offtaker must receive bids from two QAP providers and select one to provide QAP
services. The QAP provided needs to be registered properly in the OTAQREG system
6 The selected RNG offtaker will secure and pay for all third -party services including third -
party engineering, registration, and QAP services necessary for the completion of
registration
Table 2: CARB Registration Scope Items
Scope
Item # Scope Item Description
Create new facility and user accounts in the LCFS Alternative Fuels Portal (AFP), the CARB
LCFS Reporting Tool, and the Credit Bank and Transfer System (LRT and CBTS).
Determine specific Cl score for MWMC's specific pathway to RNG offtakers CNG stations
and all other tasks needed for CARB registration, including but not limited to:
x CA Greet Model CI estimation
x Energy consumption estimation
x Provide a map showing fuel transport mode to California
x Provide a Life Cycle Analysis report
x Furnish permits and operations licenses
x Furnish process flow diagrams
x Furnish RNG production reports
x Provide the RFS2 Third -Party Engineering Report
x Complete the Fuel Producer Legal Attestation form as necessary to register with
ARB
ATTACHMENT 1
Page 2 of 4
Detailed Scope Descriptions for Proposal Options 1 and 2
Table 3: Oregon DEQ Registration Scope Items
Scope
Item # I Scope Item Description
Complete and submit fuel production facility registration application (complete with
MWMC Executive Officer signature) to Oregon DEQ
Apply for the temporary fuel pathway code/carbon intensity score for the facility
After the requisite two quarters have passed, complete a provisional fuel pathway
application and include 90 days of operational data to support Cl calculations as well as any
other required documentation
Table 4: Credit Generation, Management, Storage, Reporting, and Compliance Scope Items
Scope
Item # Scope Item Description
1 Provide enough RNG consumption to consume the MWMC's total RNG production such
that management of storage logistics is not required beyond the block of physical gas
accumulated during the EPA registration delay period
2 Provide transportation consumption data of RNG at offtaker's CNG End Use locations to
demonstrate MWMC's RNG is being fully utilized as transportation fuel
3 Generate RINs in EMTS on a periodic basis (not to exceed monthly) and LCFS or OCFS
Credits on a quarterly basis in LRT
4 Coordinate with QAP provider to ensure Q-RIN generation and LCFS Verifier once details
are provided
Table 5: RIN Reporting and Record Keeping Scope Items
Scope
Item # Scooe Item Descriation
Prepare and submit quarterly reports to EPA documenting the generation and consumption
of biogas as a transportation fuel, including:
x RFS0104: RFS2 Activity Report (quarterly)
x RFS0600: RFS2 Renewable Fuel Producer Supplement Report (quarterly)
x RFS0801: Renewable Biomass Report (as applicable)
x RFS0901: RFS2 Production Outlook Report (Annual)
x RFS2700: RFS Cellulosic Biofuel Producer Questionnaire (as applicable)
x EMTS: RFS2 RIN Transaction Report (quarterly)
x EMTS: RFS2 RIN Generation Report (quarterly)
Quarterly Affidavits from CNG consumer RNG was used as transportation fuel (quarterly)
3 Any required reporting for QAP
4 Annual Attest Engagement with Third Party Auditor
5 RNG offtaker must provide reports to MWMC for two-week review before submittal. The
timing deadlines are as follows: Quarter 1 (January 1- March 31) due June 1 of same year;
Quarter 2 (April 1- June 30) due September 1 of same year; Quarter 3 (July 1- September 30)
due December 1 of same year; Quarter 4 (October 1- December 31) due March 31 of
following year. The annual attest engagements are due by June 1 of the following year.
6 Follow all requirements in 80.1451(b)- Reporting requirements, 80.1452- EMTS
requirements, 80.1454(b) Record keeping requirements
ATTACHMENT 1
Page 3 of 4
Detailed Scope Descriptions for Proposal Options 1 and 2
Table 6: RIN Annual Attest Engagement & QAP Verification Scope Items
Scope
Item # I Scope Item Description
Hire and work with a CPA to provide Annual Attest Engagement services that meet all of
the requirements of 80.1464
Hire and work with a QAP provider to provide QAP services that meet all of the
requirements of 80.1469
When LCFS verification is determined, hire and work with the qualified parties to perform
and provide annual verification work
Table 7: RIN and State Credit Marketing Scope Items
Scope
Item # Scoae Item Description
Market RINs and CA or OR Credits and compensate MWMC based on the actual sales
proceeds tied directly to Gas Daily, Oil Price Information Service (OPIS), Argus or other
appropriate commodities markets for the sale of the RNG and RIN,LCFS,and/orOCFS credits
Pay the MWMC monthly for the RINs, and other environmental attributes sold during the
previous calendar month, within 45 days of the end of each calendar month.
Monitor market and regulatory risks impacting RIN, LCFS and OCFS credit markets and
inform the MWMC of strategic decisions
ATTACHMENT 1
Page 4 of 4
Metropolitan Wastewater
MANAGEMENT COMMISSION
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partners in was tewater man agem en t
MEMORANDUM
DATE: October 3, 2019
TO: Metropolitan Wastewater Management Commission (MWMC)
FROM: Valerie Warner, MWMC Accountant
SUBJECT: FY 2018-19 Annual Financial Summary, Budget Reconciliation
ACTION
REQUESTED: Information only
ISSUE
This memo presents the results of the FY 2018-19 Operating and Capital budgets from two perspectives:
(1) a comparison between actual results and the FY 2018-19 budget, and (2) a comparison of actual
results and the FY 2018-19 year-end estimates used during the FY 2019-20 budget and rate
development process.
DISCUSSION
Results of Operations:
It is important to compare budget and actual results to ensure that legally authorized expenditure levels
are not exceeded, as well as to evaluate overall budgeting accuracy. "Budget to Actual" results are
detailed in the regular MWMC monthly report for June 30, 2019 (Attachments 1 and 2 to this
memorandum). The results are summarized in Table 1 on Page 2.
The difference between budgeted and actual operating revenues reflects the following factors:
Operating revenue exceeded budget by $1,106,907 or 3.1 %. This was driven mainly by a combination of
monthly user fee revenue ($357K or 1.07%) and septage hauler fee revenue ($216K or 1.45%) exceeding
budget estimates and also items such as interest income ($166K or 211 %) and other miscellaneous
receipts over performing budget.
Operating expenses came in under budget by $1,059,312 or 5.8% for Eugene and Springfield combined.
The Springfield savings were $463,986 comprised of 94% materials and services, with the most
significant areas of savings in litigation/attorney fees, the Small Home SDC, contractual services and
Memo: FY 2018-19 Annual Financial Summary, Budget Reconciliation
October 3, 2019
Page 2 of 4
insurance premiums. These four items comprised 74% of the Springfield M&S savings. Personnel costs
were under budget by 1.5%, and represent 6% of the total savings.
In Eugene savings were $595,325. Personnel costs came in $816,532, or 8.9%, less than budgeted due
mainly to turnover and holding positions vacant during the hiring process.
Eugene's materials and services (M&S) came in over budget by $221,207 or 4.4%. This was driven
primarily by utility costs being over budget by $206K or 27% due to the biogas co -generation engine
being off-line.
Table 1 - FY 2018-19 Budget -to -Actual Comparison
Budget Actual Variance
over/under
Operating Revenue
$36,289,955
$37,396,862
$1,106,907
3.1%
Beginning Cash
85,519,121
85,519,121
-
0.0%
Capital Revenue (excludes SDC's)
15,581,077
16,801,107
1,220,030
7.8%
S DC Revenue
1,735,000
2,183,332
448,332
25.8%
Total Revenue
$139,125,153
$141,900,422
$2,775,269
2.0%
Operating Expenditures
$33,299,867
32,240,557
$1,059,310
-3.2%
Capital Expenditures
39,093,823
17,646,246
$21,447,577
-54.9%
Debt S ervice
10,472,695
10,396,981
$75,714
-0.7%
Reserves
56,258,768
81,616,638
($25,357,870)
45.1%
Total Expenditures & Reserves
$139,125,153 $141,900,422 $2,775,269 2.0%
The Capital Revenue is over budget (7.8%) mostly due to a conservative interest income budget. Capital
interest income was $1,218,830 or 225% of the amount budgeted. Between FY 2017-18 and FY 2018-19
the interest rates increased significantly and capital has not been spent down as quickly as staff
budgeted. Capital expenditures as a whole commonly come in below budget because the projects are
budgeted at their full cost in order to award contracts, regardless of overall length of construction. SDC
revenues also exceeded budget by 25.8% due to a continued strong development environment.
The capital expenditures that were budgeted, but not yet expended also directly reflect in the reserves
ending higher than budgeted. While these reserves are present as of the end of the year, they are re-
programmed in FY 2019-20 for those same capital projects.
FY 2019-20 Supplemental Budget Adjustments:
Actual amounts often differ from estimates used during the budget process, principally because the
budget development process takes place mid -year. Consequently, estimates for the future year are
based on approximately six months of actual experience. As a result, certain adjustments are generally
Memo: FY 2018-19 Annual Financial Summary, Budget Reconciliation
October 3, 2019
Page 3 of 4
necessary at the beginning of a new fiscal year in order to reconcile actual prior year ending balances
with budgeted beginning balances for the subsequent year. These adjustments were discussed with the
Commission at the September meeting (Supplemental Budget #1 request). The following summaries
show the difference between estimated (mid -year) and actual amounts for the major components of the
Regional Wastewater Program FY 2018-19 Budget.
Operating Fund -The Operating Reserve adjustments, displayed below in Table 2, outline what makes
up the change to beginning cash for the current budget year, and how much was re -budgeted in FY
2019-20. The remainder of the beginning cash adjustment not re -programmed will be returned to
reserves resulting in an increase of $526,486.
Table 2 - Operating Fund - Estimated vs. Actual
Adjustments to FY 2019-20 Operating budget
Operating expenditures over estimates
$ 314,874
User fee revenues above estimates
216,876
Debt service underestimates
75,709
Miscellaneous revenue above estimates
63,701
Septage revenue above estimates
21,200
Administrative expenditures under estimates
17,758
Beginning cash adjustmentfor FY 2019-20
710,118
S upplementa I budget -Tiny home carryforward
(93,650)
Supplemental budget- Eugene operations carryforward
(77,100)
S upplemental budget- Digital Marketing Strategycarryforward
(12,882)
S upple me nta I budget- retire CWS RF 64840
Increase Revenue -Transferfrom Capital Fund
4,588,871
Increase DebtService Principal
(4,929,407)
Decrease DebtService Principal
88,125
Decrease CWS RF Loan Reserve
252,411
Net increase to reserves with S B 1
$ 526,486
Capital Fund:
The Capital reserve adjustments displayed below in Table 3 outline what made up the change to
beginning cash for the current budget year, how much was re -budgeted in FY 2019-20, and new money
requests in SBI. The amount over and above the beginning cash adjustment will reduce reserves
resulting in a decrease of $1,716,662.
Memo: FY 2018-19 Annual Financial Summary, Budget Reconciliation
October 3, 2019
Page 4 of 4
Table 3 - Capital Funds - Estimated vs. Actual
Adjustments to F Y 2019-20 C a pita I budget
Capital projects not spent $ 6,142,351
E ugene capital not spent 1,517,173
S DC Revenues above estimates 738,333
Interestincome above estimates 459,831
Merchantfees underestimates 3,483
Miscellaneous incomeabove estimates 1,069
Beginning cash adjustmentfor FY 2019-20 8,862,240
S upple me nta I budget - C a pita I project ca rryforwa rds
(4,880,991)
S upple me nta I budget - Major re ha b ca rryforwa rd
(703,000)
S upple me nta I budget - C a pita I outlay ca rryforwa rd
(200,000)
S upple menta I budget- E q ui pme nt re pla ce me nt ca rryforwa rd
(90,000)
New spending requests
(116,040)
Transfer to Operating Fund to retire CWS RF 64840
(4,588,871)
Net decrease to capital reserves with S B 1 $ (1,716,662)
ACTION REQUESTED
This is informational only, no action is requested.
ATTACHMENTS
1. MWMC Statement of Revenues and Expenses
2. MWMC Comparison and Reserve Charts
Statement of Revenues and Expenses
METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
STATEMENT OF REVENUES AND EXPENSES
For the Month Ending June 30, 2019
REVENUES
OP E RATIONS:
User fees, Septage & lease income
Miscellaneous & internal engineering
Interest income
Beginning cash -operations
Total operating revenue
CAPITAL:
Capital and ER supportfrom user fees
Transfers from other funds
SDC Revenues
Interest income
Misc Revenue
Beginning cash - capital
Total capital revenue
Total revenue
EXPENDITURES
OPERATIONS:
Administration - Springfield
O&M - Eugene
Capital and E R contribution
Total operating expenditures
CAPITAL:
Capital projects
Eugene equipment replacement
Eugene major rehab.
Other Capital Items - SDC
Interfund transfers
Total capital expenditures
DEBT SERVICE
RESERVES
TOTAL EXPENDITURES & RESERVES
B udqet
Current
YTD
$ 33,797,000
$
5,637,359
$
34,380,233
2,342,955
79,715
2,700,478
150,000
113,797
316,152
14, 063,149
-
14, 063,149
50,353,104
5,830,871
51,460,012
15,000,000
-
15,000,000
35,067
-
35,067
1,735,000
960,772
2,183,333
541,000
253,973
1,759,831
5,010
1,941
6,209
71,455,972
-
71,455,972
88,772,049
1,216,686
90,440,412
$ 139,125,153
$
7,047,557
$
141,900,424
Budget
Current
YTD
$ 4,103,416
$
315,109
$
3,639,432
14,196,451
2,964,985
13, 601,126
15, 000, 000
-
15, 000, 000
33,299,867
3,280,094
32,240,558
34, 469, 611
2,177, 796
14, 542, 691
884,000
112,578
339,321
1,678,300
255,677
705,806
4,000
-
517
2,057,912
-
2,057,912
39,093,823
2,546,051
17,646,247
10,472,695
-
10,396,981
56,258,768
1,221,412
81,616,638
$ 139,125,153
$
7,047,557
$
141,900,424
ATTACHMENT 1
% YTD Budget
111%
115%
211%
100%
100%
126%
325%
124%
89%
105%
100%
42%
38%
42%
13%
100%
90,000,000
80,000,000
70,000,000
60,000,000
50,000,000
40,000,000
30,000,000
20,000,000
10,000,000
Schedule of Cash Reserves
RESERVES
FY 2018-19
■ ImprovementSDC
reserve
■ Reimbursement SDC
reserve
Equipment
replacement reserve
■ Capital reserve
■ Rate stability reserve
■ Rate stabilization
reserve
■ Insurance reserve
SRF Loan reserve
■ Springfield working
capital
■ Eugene working capital
■Operating
6/30/19
Budget vs. Actual Revenues and Expenditures
40,000,000
35,000,000
30,000,000
25,000,000
20,000.000
15,000,000
10,000,000
5,000,000
0
Operating revenues Administration expenses Operations expenses
❑Budget ❑YTD Actual ■YTD Budget
ATTACHMENT 2
Metropolitan Wastewater
MANAGEMENT COMMISSION
ANON6 6kOREGON
FIELD
partners in wastewater management
MEMORANDUM
DATE: October 3, 2019
TO: Metropolitan Wastewater Management Commission (MWMC)
FROM: James McClendon, Wastewater Business Analyst
SUBJECT: FY 2017-18 MWMC Greenhouse Gas Inventory Report
ACTION
REQUESTED: Information Only
ISSUE
In September 2019 staff completed an MWMC FY 2017-18 Greenhouse Gas (GHG) Inventory Report that
is attached to this memo. The inventory included data gathering and analysis of the emissions from the
MWMC facilities, including regional and local pump stations.
BACKGROUND
Previous GHG inventories were conducted on the MWMC facilities for calendar years 2010, 2012, 2014,
and for fiscal year FY 2015-16. After the 2014 report, the inventory timeline was switched to fiscal years
to align with the City of Eugene's GHG inventory.
The purpose of conducting the GHG inventory and producing the report is to assist the MWMC with the
following:
x Continuing to identify opportunities to reduce GHG emissions
x Addressing potential future regulatory reporting requirements
x Incorporating GHG emissions reduction strategies into future planning efforts
x Meeting the MWMC's Key Outcome to "achieve and maintain high environmental standards"
x Continuing the commitment to conduct biennial GHG inventories as a reference to assess
operational and environmental performance
In 2018 the City of Eugene requested information from the MWMC in the development of a Community
Action Plan, referred to as CAP 2.0. The MWMC has partnered with Eugene in the CAP 2.0 by contributing
information on projects and activities that are considered in the plan. One of the MWMC projects
referred to in CAP 2.0 is the Renewable Natural Gas (RNG) project, which is currently in progress. The
Memo: FY 2017-18 MWMC Greenhouse Gas Inventory Report
October 3, 2019
Page 2 of 2
MWMC resiliency planning and associated project work is also indirectly referred to as a region -wide
effort in the CAP 2.0 document.
Another purpose for conducting the inventory is to report annually on specific GHG emissions to Lane
Regional Air Protection Authority (LRAPA) in accordance with the Eugene/Springfield (MWMC) Water
Pollution Control Authority Air Contaminant Discharge Permit.
DISCUSSION
The FY 2017-18 GHG Inventory Report on MWMC facilities provides the following:
x Comparisons of current emissions to the emissions in previous inventory years
x The offset of GHG emissions (benefits) from displaced grid electricity, carbon sequestration by poplar
trees, and other MWMC activities
x Recent and upcoming GHG emissions reduction action items
x An appendix including detailed explanations on data gathering and the methodology used in this
GHG inventory report
Overall, the total FY 2017-18 GHG emissions (21,385 MT CO2e) from anthropogenic activity at the MWMC
facilities were approximately 28% higher than the FY 2015-16 emissions (16,681 MT CO2e). A brief
summary of the results from the FY 2017-18 inventory are as follows:
x The largest overall source of GHG emissions was from purchases of goods and services for capital
construction projects, which is categorized as indirect emissions (Scope 3). The increased emissions
were primarily due to the construction of a new anaerobic digester, construction of the maintenance
building expansion, and the initial phase preparations for the environmental laboratory construction.
In previous inventory years, supply chain purchases for operational activities were typically the
largest source of emissions.
x The greatest offset (benefit) from the GHG emissions was from carbon sequestration of about 18,000
MT CO2e due to the growth of poplar trees at the Biocycle Farm.
The next GHG emissions inventory will be conducted for the FY 2019-20 timeframe and is scheduled to
be completed in the summer of 2021.
ACTION REQUESTED
Information only — no action requested.
ATTACHMENTS
1. Greenhouse Gas Inventory Report for FY 2017-18
t4. .3. +
,fit � _t�: i� ,ry; E„y�l. �, � •, }
3 �� �•��, !' g1� � ,.� � _����^.` is � � r
Introduction
This report quantifies the Greenhouse Gas (GHG) emissions for FY 2017-18 from the regional wastewater
treatment plant, Biosolids Management Facility (BMF), and regional pump stations serving the Eugene -
Springfield Metro Area in Lane County, Oregon — known collectively as the MWMC (Metropolitan
Wastewater Management Commission). The report also includes emissions data for wastewater pump
stations that are owned independently by the City of Eugene and City of Springfield.
The analytical framework applied by staff to produce this
report has quantified harmful GHG emissions resulting Recorded Change in Global COz Levels
from the MWMC's activities in FY 2017-18 that contribute
to increasing global CO2 levels. The framework also
quantified the MWMC's activities that are beneficial to our
environment—those which reduce, sequester, or offset
GHG emissions.
Page 4 of the report outlines the MWMC's contribution of
information to -date towards community action planning
for local and regional GHG emissions reduction. The
Appendix to the report describes the GHG methodology,
illustrates the GHG emissions totals, and provides more
detailed support and commentary. Not included in the
report is an evaluation of the MWMC's progress toward
GHG emissions reduction as targets and goals have not
yet been established.
GHG EMISSIONS SUMMARY
380
0 340
E 300 HIGhEST HISTORIC4- COz LEVEL 1950 10
--
CL
I
260
n
O 220
L)0%% I'Voi
180
400 350 300 250 200 150 100 50
Thousands of Years before today (0 = 1950)
Source: National Aeronautics and Space Administration
(NASA). Retrieved on July 18, 2019 at
https://climate.nasa.gov/vital-signs/carbon-dioxide/
Greenhouse gas inventories have been conducted for the MWMC facilities every other year beginning with
calendar year 2010. Starting in 2017 the GHG inventories have been reported based on fiscal year (FY) timing
versus calendar year (CY) to align with the City of Eugene's GHG inventory year.
Figure 1 - GHG Emissions'
■ Emissions from Operating Activities ,. Emissions from Capital Projects
z,.000
zo.mo ---------------------
H
CY 2010 CY 2012 C1' 2014 FY 2015-15 FY 2017-18
GHG inventory Reporting Year
' Emissions data and methodology detail provided in the Appendix.
FY 2017-18 GHG emissions were the
highest since reporting began in 2010.
A high volume of capital construction
was the main driver for the increase
from the prior reporting period.
FY 2017-18 GHG Emissions Report I Page 1
Figure 2 — GHG Emissions Offset
CLIMATE BENEFITS FROM MWMC ACTIVITIES
While wastewater treatment activities generally contribute to GHG emissions, some beneficial activities by
the MWMC have removed or offset GHG emissions. The beneficial activities were mostly from displacing
GHG emissions (e.g., electricity generated from the biogas-fueled generator) and by carbon sequestration
(e.g., emissions captured by poplar trees at the Biocycle Farm).
The GHG inventory protocol (methodology) used to calculate the FY 2017-18 emissions from the MWMC
facilities does not subtract the benefits of displaced and sequestered CO2e from the total. The following
benefits of the MWMC operational activities are explained for reference only.
Carbon Sequestration
x Carbon Sequestration by Biocycle Poplar Trees (-18,000 MT CO2e)
The Biocycle farm has been in operation since 2004 when Management Unit #1 (MU I) was planted with
35,000 trees. Two subsequent units were planted for a total of 88,000 trees. MU1 was harvested in stages
between the years 2013-2015 and then replanted in 2017. In December 2016 an ice storm severely
damaged MU2 and some of MU3. This resulted in the early harvesting of MU2 and parts of MU3 in 2017.
The harvested portions of the Biocycle Farm are not counted as sequestration in this report. Also, MU1
has much smaller trees due to the recent replanting, and many studies indicate that younger trees
sequester less carbon than more mature ones. The FY 2015-16 GHG inventory calculation resulted in an
estimated -31,359 MT CO2e sequestered as biomass because that occurred before the loss and
harvesting of mature trees in 2017.
x Soil Carbon Sequestration ( -613 MT CO2e)
When biosolids are applied to soil, a proportion of the organic carbon remains trapped and therefore
increases the health and sequestration potential of the existing soil.
FY 2017-18 GHG Emissions Report I Page 2
FY 2017-18 Displaced/Sequestered MT CO2e
The total amount of GHG emissions
that were offset or displaced by the
MWMC's activities in FY 2017-18 was
Tree Farm
21,125 MTCO2e. The Biocycle Farm
Sequestration
(poplar trees) provided the largest
20,000
Tree Farm Sequestration
benefit and sequestered 18,000 MT
18,000
16,000
CO2e due to the growth in biomass.
14,000
Displaced Natural Gas
12,000
° 10,000
Displaced Grid Electricity
r
� s,aao
5,000
Soil Sequestration
4,000
2,000
Displaced Fertilizer
CLIMATE BENEFITS FROM MWMC ACTIVITIES
While wastewater treatment activities generally contribute to GHG emissions, some beneficial activities by
the MWMC have removed or offset GHG emissions. The beneficial activities were mostly from displacing
GHG emissions (e.g., electricity generated from the biogas-fueled generator) and by carbon sequestration
(e.g., emissions captured by poplar trees at the Biocycle Farm).
The GHG inventory protocol (methodology) used to calculate the FY 2017-18 emissions from the MWMC
facilities does not subtract the benefits of displaced and sequestered CO2e from the total. The following
benefits of the MWMC operational activities are explained for reference only.
Carbon Sequestration
x Carbon Sequestration by Biocycle Poplar Trees (-18,000 MT CO2e)
The Biocycle farm has been in operation since 2004 when Management Unit #1 (MU I) was planted with
35,000 trees. Two subsequent units were planted for a total of 88,000 trees. MU1 was harvested in stages
between the years 2013-2015 and then replanted in 2017. In December 2016 an ice storm severely
damaged MU2 and some of MU3. This resulted in the early harvesting of MU2 and parts of MU3 in 2017.
The harvested portions of the Biocycle Farm are not counted as sequestration in this report. Also, MU1
has much smaller trees due to the recent replanting, and many studies indicate that younger trees
sequester less carbon than more mature ones. The FY 2015-16 GHG inventory calculation resulted in an
estimated -31,359 MT CO2e sequestered as biomass because that occurred before the loss and
harvesting of mature trees in 2017.
x Soil Carbon Sequestration ( -613 MT CO2e)
When biosolids are applied to soil, a proportion of the organic carbon remains trapped and therefore
increases the health and sequestration potential of the existing soil.
FY 2017-18 GHG Emissions Report I Page 2
Displaced GHG Emissions
x Displaced Grid Electricity ( -740 MT CO2e)
Biogas-generated electricity, which is considered renewable and the emissions largely biogenic,
displaces Northwest Power Pool (NWPP) grid electricity2 that has significantly higher anthropogenic
carbon intensity. The renewableness of biogas-generated electricity is accounted for with Renewable
Energy Certificates, or RECs (1 kWh of electricity = 1 REQ.
Displaced grid electricity significantly decreased in FY 2017-18 due to the 80OKW engine generator not
operating for part of the year. The generator was offline for several months as it was being rebuilt. Also,
during this time, personnel operated a temporary boiler that was connected to natural gas. Therefore,
most of our biogas produced during this time was directly flared through the waste gas burner and did
not contribute to offset emissions.
The MWMC sells 100% of the RECs generated at the treatment plant to EWEB and therefore cannot claim
any of the associated environmental benefits. For FY 2017-18, the MWMC Facilities received $520 for
RECs, which follows a significant downward trend over the past several years as the market value of RECs
has decreased.
x Displaced Conventional Natural Gas ( -1,659 MT CO2e)
The wastewater treatment plant displaces the use of natural gas with biogas in the boiler as well as
capturing the heat generated from the plant's combined heat and power (CHP) system.
x Displaced Conventional Fertilizer ( -113 MT CO2e)
Substituting biosolids for conventional fertilizer displaces the emissions that would have otherwise been
created in the production of conventional fertilizers.
RECENT AND UPCOMING GREENHOUSE GAS REDUCTION ACTION ITEMS
The following GHG reduction related activities are currently underway or being discussed for future action.
In the fall of 2018, City of Eugene and City of Springfield staff on behalf of the MWMC contributed the
following information to the City of Eugene Community Action Plan, referred to as CAP 2.0:
Implement Biogas to Fuels project - Renewable Natural Gas (RNG). This project will utilize nearly
100% of the biogas generated at the wastewater treatment plant and upgrade the biogas to RNG at
the plant.
Current operational activity in support of GHG reduction:
Ongoing adherence to the ISO 14001 standard for Environmental Management System (EMS)
compliance. One of the current Objectives of the EMS program is to Reduce Energy Use.
Community Partners: Lane County and City of Eugene
City of Eugene and Lane County government have issued department -wide directives to reduce GHG
emissions within their respective organizations:
Incorporate energy efficient technologies and green building design into new capital construction
and refurbishment of buildings (e.g., energy efficient HVAC systems, repurposed road paving
materials, etc.).
Contract from local service and material providers.
2 Oregon is part of the Northwest Power Pool (NWPP) sub -regional electricity grid. For more information, see
http://www.epa.gov/cleanenergy/energy-resources/egrid/.
FY 2017-18 GHG Emissions Report I Page 3
x Reduce vehicle miles traveled by promoting teleconferencing (e.g., webinars, conference calls,
online seminars) or utilize bus, bike or other low -carbon transportation options.
Expand urban tree canopy cover through new and replacement tree planting.
Replace gasoline/diesel fleet vehicles with electric, hybrid electric, and/or compressed natural gas
(CNG) fleet vehicles.
Establish a climate recovery ordinance (CRO) with emissions reduction targets.
CONTACT INFORMATION & ADDITIONAL RESOURCES
City of Eugene staff Ivan Campbell, John Huberd, James McClendon, and Sharon Olson conducted the FY
2017-2018 inventory of the MWMC's GHG emissions, with portions of the data provided by Tom Mendes,
Wastewater Division Environmental Data Analyst. Technical support on the FY 2017-2018 GHG inventory was
provided by Aaron Toneys at Good Company, a leading provider of professional consultation and services
for sustainability planning in the public and private sectors.
For more information, call or email:
Ivan Campbell, 541-682-8620 ICamr)bellPeuaene-or.aov
John Huberd, 541-682-8603 JHuberdPeuaene-or.aov
James McClendon, 541-682-8608 JMcclendonPeuaene-or.aov
Sharon Olson, 541-682-8625 SOlsonPeuaene-or.aov
FY 2017-18 GHG Emissions Report I Page 4
Appendix
GREENHOUSE GAS ACCOUNTING: EMISSIONS SCOPES
The main sources of emissions from the MWMC facilities include wastewater treatment process emissions,
electricity usage, and supply chain purchases.
GHG emissions are categorized into three Scopes according to the protocol, defined as follows:
x Scope 1 emissions are direct emissions which originate from equipment and facilities owned and
operated by the MWMC—primarily from fossil fuel combustion and wastewater treatment processes.
x Scope 2 emissions are indirect emissions from purchased electricity.
x Scope 3 emissions are all other indirect emissions that result from the activities of the MWMC Facilities,
but where the direct sources are controlled by other entities or service providers, such as construction of
capital projects, supply -chain related transport, solid waste disposal, employee commute and business
travel, and energy transmission and distribution losses.
In the City of Eugene FY 2017-18 GHG inventory and report, the cumulative total of the MWMC facility
emissions (i.e., all three scopes) are included as Scope 3 emissions for Eugene.
GREENHOUSE GAS ACCOUNTING: METHODOLOGY
The inventory used for this FY 2017-18 GHG report follows the Local Government Operations Protocol
(LGOP), which was developed jointly by The Climate Registry and affiliated organization s.3 The LGOP
protocol only requires the reporting of emissions in Scopes 1 and 2 as defined by the World Resources
Institute. Therefore, this inventory has been expanded to include several additional Scope 1 process
emission sources specific to biosolids management as well as shared emission categories from Scope 3. The
use of these tools to measure additional emissions sources has enabled a more accurate inventory of GHG
emissions from the MWMC facilities.
The protocols and methods used to account for the additional Scope 1 and Scope 3 emissions sources are
documented in Good Company's Carbon Calculator (G3C) and the G3C-WW (Wastewater) module used to
calculate emissions for this inventory. The additional Scope 1 emissions sources were estimated using either
the LGOP (for emissions associated with denitrification and discharge of effluent) or the Canadian Ministers
of the Environment's Biosolids Emissions Assessment Model (BEAM) for emissions associated with biosolids
storage, drying and land application.
Displaced emissions from grid electricity and conventional natural gas are calculated to be the same as an
equal quantity of grid -purchased electricity or natural gas. BEAM was used to estimate benefits associated
with displaced conventional fertilizer and soil carbon sequestration from land application of biosolids.
Carbon sequestration by poplar trees at the Biocycle Farm was calculated using the methodology specified
by the Climate Action Reserve's Urban Forest Protocol.'
3 The Local Government Operations (LGO) Protocol was developed in collaboration among The Climate Registry (TCR), the
California Air Resources Board (CARB), the California Climate Action Registry (CCAR, now the Climate Action Reserve),
and ICLEI Local Governments for Sustainability. The LGO Protocol follows the same format as The Climate Registry's
General Reporting Protocol (GRP).
4 Climate Action Reserve (CAR) Urban Forest Protocol can be found at
http://www.climateactionreserve.org/how/protocols/urban-forest/
Appendix I Page 1
GREENHOUSE GAS ACCOUNTING: SUMMARY OF INVENTORY DETAILS
Scope 1 emissions for the MWMC facilities in FY 2018-19 which include process related emissions from
wastewater treatment and biosolids processing amounted to 4,448 MT CO2e and was very similar to the
amount of emissions in previous reporting years, a reduction of 1.9%, as shown in Figure 1
Scope 2 emissions are the result of consuming electricity and amounted to the second highest emissions of
the three scopes for FY 2017-18. Scope 2 emissions were 6,789 MTCO2e, a reduction of 4.3% from FY 2015-
16.
Scope 3 emissions result from
the purchase of goods and
services for capital projects,
travel, solid waste disposal,
and upstream energy
production. Scope 3 emissions
were 5,053 MT CO2e in FY
2015-16 and increased to
10,149 MT CO2e in FYI 7-18.
Supply chain emissions
increases in FY 2017-18 were
largely due to intensive
construction activity at the
MWMC facilities for the new
digester and expansion of the
maintenance building.
Figure 1 - MWMC Facilities Emissions by Scope
Emissions by Scope 1-3
12,000
11,000
° 10,000
E 9,000
W 0,
8,000
�o
0 u 7,000 -
d F
c 6,000
5,000
°1 4,000 -
C7
3,000 -
2,000 -
1,000 -
_U
Scope 1 Scope 2 Scope 3
2010
2012
2014
FY 2015-16
FY 2017-18
In FY 2017-18, the largest category of emissions from the MWMC facilities was Scope 3, which increased by
101 % over FY 2015-16. Within Scope 3, supply chain and related emissions increased by 209% over FY 2015-
16, as illustrated in Figure 2.
Figure 2 - Overview of the MWMC Facilities' Greenhouse Gas Emissions
8,000
7,500
7,000
6,500
6,000
5,500
5,000
4,500
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
Greenhouse Gas Emissions MT COze
Wastewater Biosolids Fleet Other * Electricity Supply Solid Upstream Commute &
Treatment Process Chain Waste Energy Business
Production Travel
Scope 1 Scope 2 Scope 3
* Other category represents emissions from refrigerants, natural gas, and non -fleet fuels.
■ 2012
■ 2014
■ FY 2015-16
■ FY 2017-18
Appendix I Page 2
Scope 1 - Direct Emissions Details
Wastewater Treatment and Biosolids Process Emissions
GHG inventory protocol for the accounting of greenhouse gas emissions distinguishes human -caused
emissions (anthropogenic) and greenhouse gases from natural processes (biogenic).
Anthropogenic GHG emissions are those emissions associated with human activities dependent on the
combustion of fossil fuels such as the burning of oil, coal and gas and process emissions from industrial
activities.
Biogenic emissions are part of the natural biogeochemical cycling of carbon. Biogenic emissions are carbon
dioxide from the combustion of non -fossilized, biologically based materials such as biogas and biofuels (e.g.,
biodiesel) and natural processes such as the decomposition of organic materials.
For FY 2017-18, wastewater treatment and biosolids process emissions accounted for 96% of Scope 1
emissions. As shown in Figure 5, methane is the largest source of anthropogenic GHG emissions from the
biosolids lagoon process'.
Figure 3 - MWMC Facilities Anthropogenic Emissions for FY 2017-18
1,500
0
1,250
E
W „
R 1,000
ED u
m F_
750
D
s
c
y 500
L
250
0 —
Biogas
Combustion
Nitrogen Nitrogen in Biosolids Lagoon Biosolids Drying Blosolids Land
Removal Effluent Apply
Nitrous Oxide (N20) Methane (CH4)
Scope 2 - Indirect Emissions Details, Electricity
Electricitv Emissions
Scope 2 emissions resulting from the consumption of electricity increased by 9.4% between 2012 and 2014;
decreased 7.4% between 2014 and FY 2015-16; and decreased again by 4.3% between FY 2015-16 and FY
2017-18. As shown in Figure 6 below, the regional treatment plant location continues to be the largest
source of Scope 2 emissions among all the MWMC facilities.
Efforts to reduce electricity usage over the last eight years have included large- and small-scale energy
efficiency projects. The projects included implementation of an air -compressor management program,
installation of a passive grit collection system, replacement of pump station equipment with more efficient
variable frequency drive pumps, efficiency improvements to odorous air controls, and upgrading to a more
efficient aeration blower in the Secondary treatment area.
5 Wastewater lagoons in the US are significant contributors of methane emissions, contributing approximately 2,300,000
metric tons per year. See Harper, L.A. "Methane emissions from an anaerobic swine lagoon." Journal of Atmospheric
Environment. Retrieved 2 November 2011.
Appendix I Page 3
Figure 4 - Emissions from Electricity Consumption
6,000
c
N
5,000
E
h
m 4,000
� O
� u
v H
5; 3,000
0
z
c
y 2,000
u
1,000
Emissions by Location - Scope 2
Treatment Plant Pump Stations Biosolids
Electricitv Use Emission Factors
2010
2012
2014
FY 15-16
FY 17-18
Several assumptions are factored in to estimate GHG emissions from the sources included in the GHG
inventory. The most significant assumption regards which emissions factor is used to calculate emissions
from electricity use. An emissions factor is a representation of the carbon intensity per unit of electricity (e.g.,
MT CO2e per megawatt -hour).
The FY 2017-18 inventory uses the location -based Northwest Power Pool (NWPP) regional grid emissions
factor to calculate the amount of emissions resulting from electrical usage, but this report also provides a
market-based emissions factor as comparison. Historically, a location -based emissions factor has been
applied to the calculation as it is consistent with current GHG inventory protocol.
Location -Based Versus Market -Based Electricity Accounting
The Greenhouse Gas Protocol's Scope 2 Guidance system, the global standard for public agencies, includes
two separate methodologies for calculating Scope 2 electricity emissions. The location -based methodology
is calculated according to a defined geographic boundary, or regional grid, and is weighted toward
collective consumer demand and maintaining grid integrity. The location -based emissions factor is the
Northwest Power Pool (NWPP).
The market-based approach is weighted according to which utility company is contracted to supply
electricity and any power purchasing agreements (PPAs) associated with the contract. The market-based
emissions factor for this report is Eugene Water and Electric Board (EWEB), which distributes electricity
primarily from the Bonneville Power Administration (BPA), whose electricity is almost entirely generated
from low -carbon sources such as hydropower and wind.
Appendix I Page 4
Figures 5 and 6 highlight the differences between the two accounting methodologies for electricity.
Figure 5 - Location- and Market -Based Comparison for MWMC Facilities
Accounting
Activity Data
Emissions Factor
Emissions
Method
MWh/Year % of Tot Use
Description
MT CO2e /MWh
MT CO2e
Location -Based
16,385
100%
Regional Grid Ave. (NWPP)
0.414
6,789
E
Oregon Department of
cLU 3,000
Environmental Quality (ODEQ).
Location -
Based Total:
6,789
16,385
100%
Utility -Specific (EWEB)
0.010
164
Market -Based
0
0%
Purchase Agreements
0
0
0%
Renewable Energy Credits
0
Market -Based
Total:
164
Figure 6 - Details of location -based and market-based emissions calculations
8,000
Activity data are based on the
7,096 6,789 MWMC Facilities FY 2017-18
7,000
electricity consumption. The
ai 6,000
NWPP emissions factor is from
U
eGRID 2016, which is the most
S'000
current factor available. The
o
utility -specific factor (i.e., EWEB)
4'000
is based on the 2016 report by
E
Oregon Department of
cLU 3,000
Environmental Quality (ODEQ).
2,0°0
1,000
171 164
Electricity Emissions (market-based) Electricity Emissions (location -teased)
EWEB NWPP
■ FY 2015-16 ■ FY 2017-18
Scope 3 — Indirect Emissions Details, Supply Chain
Scope 3 emissions are from the purchase of goods and services for capital construction projects, travel, solid
waste disposal, and upstream energy production. Scope 3 emissions were 5,053 MT CO2e in FYI 5-16 and
increased substantially to 10,149 MT CO2e in FYI 7-18. The increased emissions were mainly due to greater
construction activity, including the construction of Digester #4, the expansion of the maintenance building,
and construction of the new Environmental Services Laboratory at the plant.
The primary emissions categories for Scope 3 are capital construction supply chain, operations supply chain,
and upstream energy production, as shown in Figure 7. These are the emissions resulting from the
production, delivery, and use of building materials, fuels and energy products, and all other supplied goods
and services. Scope 3 emissions also include emissions from the landfilling of solid waste and business travel
in non-MWMC vehicles.
Appendix I Page 5
Figure 7 - Categories of Indirect Emissions
Indirect Emissions - Scope 3
6,000
5,500
E 5,000
4,500
C7 U 4,000
m H
3,500
D
= 3,000
y 2,500
L
C7 2,000 —
1,500 —
1,000 —
500
Business Solid Upstream Commute Operations Capital
Travel Waste Energy Supply Construction
Production Chain Supply Chain
2012
2014
FY 2015-16
FY 2017-18
Note: Emissions from upstream electricity production are calculated based on the NWPP location -based
emissions factor.
The capital construction category includes all capital construction emissions during the reporting period FY
2017-18. Construction activities that utilize concrete, steel, and other building materials produce a
substantial GHG emissions footprint. Other emissions are produced mainly from purchases related to
maintenance of buildings, facilities, and equipment.
Upstream energy production includes emissions from the MWMC's supply chain purchases of energy
products. Scope 1 and Scope 2 emissions account for'tailpipe' emissions from combusting fossil fuels. Scope
3 emissions from upstream energy production include the energy use and process emissions resulting from
the extraction, transportation, refinement, and distribution of energy products used in MWMC-owned
equipment or used in the generation of grid electricity consumed by the MWMC facilities and equipment.
For example, methane leakage during natural gas extraction and transport falls under the category of
upstream energy production within Scope 3.
The operations supply chain category includes chemicals used in the treatment processes at the MWMC
facilities. Chemicals comprise a large proportion of the materials and supplies emissions as is replacement
parts and components. Purchases of vehicles, heavy equipment, laboratory supplies, and professional
services are also accounted for in operations supply chain emissions.
Appendix I Page 6