FDCE participants learn to write sharp op/ed pieces for the public, along with more detailed memos for policymakers.
This op/ed, by 2022-23 participant Pari Amanlou, argues for addressing environmental racism and emissions through reform in wastewater management.
The author, an executive at an environmental consulting firm, argues for valuing solutions that go beyond the math.
This memo comes from Pari Amanlou, a participant in our 2022-23 FDCE cohort.
Municipal wastewater treatment facilities across the United States generate a significant amount of waste sludge through the wastewater treatment process. Traditionally, many of these facilities have flared or released biogas to the atmosphere and have primarily disposed of the biosolids through land applications, landfilling, and incineration methods (Biosolids Uses, 2019). Regardless of the method of solid disposal, the facilities are largely contributing to onsite and third-party off-site greenhouse gas (GHG) emissions such as those of landfills.
According to Environmental Protection Agency data from roughly 2,200 large U.S. [wastewater] facilities, approximately 4.75 million dry metric tons (dmt) of biosolids were produced in the USA in 2019., and of that production approximately 4.2 million dmt of biosolids were disposed of using land application, landfill, and incineration methods (Biosolids Uses, 2019).
According to EPA’s GHG data for 2020, the total reported GHG emissions from 124 large U.S. wastewater treatment facilities was 1.9 Million Metric Tons CO2 Equivalent (MMTCDE) (Greenhouse Gas Emission from Large Facilities, 2020). Yes, it is easy to conclude clean water is polluting our air and a dirty business. But clean air and clean water can be achieved in parallel without compromising the communities where these facilities are housed.
If the U.S. is to meet the Biden Administration's GHG emissions reduction target of 40% below 2005 level by 2030, a large sum of the referenced GHG volumes needs to be captured. And, from an environmental justice perspective, it’s time to act and to lessen the burden placed on nearby disadvantaged communities that have borne the heavy burden of these past practices.
One proposed solution is to incentivize municipal wastewater treatment facilities to implement anaerobic digestion of biosolids and biogas capturing methods to produce Renewable Natural Gas (RNG), a renewable fuel used in the generation of heat and electricity, onsite or at a nearby centralized facility shared by multiple treatment facilities. This process creates an economically viable volume of RNG, reducing the volume of biosolids needed to be land-applied which significantly contribute to methane and CO2 emissions.
Anaerobic digestion also produces fertilizer and ammonia as secondary revenue-generating products. The reduction of GHG emissions also allows the facilities to participate in cap-and-trade opportunities and minimizes future carbon taxes otherwise applicable. The proposal is one approach to reducing greenhouse gas emissions and aligning facility operations to those we see invoked in current legislative bills intending to combat climate change.
On August 16th, 2022, President Biden signed the Inflation Reduction Act (IRA), which includes $369 billion in climate and clean energy investments aimed to reduce U.S. greenhouse gas emissions by 40% below 2005 levels by 2030 (Summary: Inflation Reduction Act of 2022, 2022). In addition, the bill includes an extensive amendment to the Clean Air Act, giving the EPA new tools and funds to address climate pollution and to set new methane and greenhouse gas emissions levels for industrial sources. The bill has set a timeline of 18 months for the EPA to develop new emissions standards, making this recommendation timely.
In summary, cutting methane emissions is a viable part of a strategy to slow down global warming and address climate change. It's also something we can do quickly. The IRA bill alone provides $135 billion of clean energy tax credits, $60 million towards measures addressing environmental justice, and $4 billion towards reducing emissions in rural communities and to farmers and their operations which can be utilized to fund such projects.
Additional incentives such as the Renewable Identification Numbers (RINs) credits under the EPA Renewable Fuel Standard Program and other electricity generating programs from eRINs, resiliency program funds such as Senate Bill 3 of Texas, and peak shaving can yield significate operational savings. Secondary byproduct sales such as fertilizer, and carbon credit trading will further support the financial viability of these projects and lessen the burden of implementing such processes immediately.
Biosolids Uses (2019). Retrieved from
Greenhouse Gas Emissions from Large Facilities (2020). Retrieved from
Summary: Inflation Reduction Act of 2022 (2022). Rederived from