Environmental Siting Guide
Environmental siting addresses the emissions, noise, and visual impacts created by a distributed energy resources (DER) system. Because some state and local approval entities are still unfamiliar with DER technologies, environmental permitting is one of the more complex and time-consuming steps on the way to a finished project.
To ensure a successful project, three key processes must occur simultaneously:
- Technical development and financing
- Environmental siting evaluation and approval
This diagram illustrates the process:
Does Technology Make a Difference?
Environmental siting requirements vary depending on the type of technology. For example, with photovoltaic systems there are usually no or few siting issues, particularly if these systems are integrated into the roof of a building. Even then, however, there may be resistance in some communities with strict rules on building appearance or in areas designated as historic.
Small wind turbines are generally not recommended for urban areas because of visual concerns and potential noise impacts. But they are usually easy to site in rural locations.
Hydroelectric systems have special requirements, particularly if they involve the construction of a dam since it generates potential safety issues downstream. Hydroelectric systems often require environmental assessments, because of their effects on streams, and may even require approval from the Federal Energy Regulatory Commission.
Fuel cell systems are generally easier to site because of their inherently low emissions and silent operation. But other generation systems are likely to fall under state, local, and Federal restrictions on air emissions. If the system generates noise that can be heard offsite, there may be local opposition to the installation. And of course, if a building is needed to house the facility, applicable building codes and permits will also apply.
The Impact of Air Quality Regulations on Distributed Generation (PDF 2.3 MB) is a recently completed report that investigates 51 case studies of various DER installations and identifies the key obstacles encountered in air quality permitting. The findings of this report may be valuable when considering DER project permitting. Download Adobe Reader.
Most contractors should be able to assist you in meeting siting requirements for your system. However, if you are installing the system yourself, you will need to work closely with state and local officials to be sure all applicable codes and regulations are met.
Navigating the Process
The first step in evaluating distributed energy resources for a facility is to identify the technology that best matches the requirements and constraints of the facility. Because this can be time-consuming, you'll want to begin researching siting and approval requirements as soon as the technology is chosen. Here are some steps to make the environmental permitting process easier and faster:
Step 1: Identify other agency projects
Ask your agency energy coordinator if any other facilities in your agency have implemented a DER project. Find out the point of contact at that facility and ask them what lessons they learned. What did they do that helped the project along? What would they have done differently?
Step 2: Identify your state Department of Environmental Protection and other regulating agencies
Identify and meet with the local representative of your state's Department of Environmental Protection (DEP). Let them know what type of project you are considering and ask them some basic questions, including:
- Have you permitted a similar technology or system before?
- If so, can the information from that project be made available?
- What are the emission standards for different technologies?
- What are the system size and running time constraints?
- Is there a standard approval process or format for DER projects?
- What specific information do you need to review an application?
- Who are the approval authorities for the various siting considerations?
- What approvals are required from the Environmental Protection Agency (EPA) for a project of this size?
For more information on state environmental departments, state energy offices, a list of state and territorial air pollution program administrators, and links to information on the power plant permitting process for individual states, see the STAPPA / ALAPCO Web site. Regulations change rapidly, so a knowledgeable contact at the state level is an excellent resource.
Various local, state, and Federal agencies are responsible for review and approval of different DER technologies and permit requests in accordance with specific laws and regulations. The required level of approval varies significantly depending on the technology. The following table summarizes possible permitting agencies and types of issue that may need to be addressed:
|U.S. Corps of Engineers||Construction in Navigable Waters, Dredging and Filling|
|U.S. EPA||The National Environmental Policy Act, the Clean Air Act, and the Clean Water Act|
|Point Source Discharge into Navigable Waters|
|FAA||Proximity to Airport Runway and Stack Height|
|FEMA||Flood Plain Development|
|Department of Environmental Protection (DEP)||Environmental Impact Assessment|
|Energy Facilities Siting Board||Construction Approval for Large Generators and Transmission|
|DEP Air Program Unit||Air Quality|
|DEP Air Program Planning||Noise Impacts|
|DEP Water Pollution Program||Wastewater Discharge|
|DEP Wetlands and Waterways||Wetlands and Waterways Development and Use|
|DEP Drinking Water Program||Present and Future Water Use|
|DEP Business Compliance Division||Solid Waste Management|
|DEP Waste Programs Planning||Handling of Hazardous Waste|
|Division of Coastal Zone Management||Coastal Zone Development and Use|
|Natural Heritage Program||Preservation of Rare Species or Habitat|
|DEP Solar Access Program||Solar Access Protection|
|Building Inspector||Building Permits, Codes, and Zoning Laws|
|Zoning Board of Appeals||Special Permits and Variances|
|Electrical Inspector||Electrical Code|
|Plumbing Inspector||Provisions of Fuel, Gas, and Plumbing Code|
|Gas Inspector||Provisions of Gas Code|
|Planning Board||Site Plan Approval|
|Conservation Commission||Wetlands, Floodplain, Soil Erosion, Runoff|
|Water/Sewer Commission||Water Supply and Quality; Sewer Extension and Connection|
|Fire Inspector||Fuel Tank and Gas (e.g., ammonia) Storage|
|Historical Commission||Modification of Sites with Historical Significance|
|Department of Public Works||Need for Curb Cuts or Service Roads|
|Town/City Engineer||Need for Grading; Impact on Highway/Traffic|
|Board of Public Health||Air Quality, Hazardous Waste Impacts|
The Massachusetts Department of Energy Resources (DOER) developed a Renewable Energy and Distributed Generation Guidebook (PDF 941 KB) that provides a good introduction to the environmental siting process in any state.
Step 3. Compile technical information on your project
Most DER technologies are encountered infrequently, so there may be a delay in the permitting process while the zoning, code, and approval reviewers become comfortable with them. It is a good idea to develop an informational package or presentation to provide reviewers with background information on the DER technology used in your project. Also, include examples of successful similar applications.
FEMP assistance is available to help educate state or local personnel who need additional information.