U.S. Department of Energy - Energy Efficiency and Renewable Energy

Federal Energy Management Program

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
  • Interconnection

This diagram illustrates the process:

To ensure a successful project, site analysis, permitting, and utility interconnection processes must occur simultaneously. Each process consists of four steps and some process steps are interlinked. The site analysis process entails conducting a feasibility study, deciding whether or not to proceed with a project, conducting the necessary design and engineering for the project, and deciding on how to finance the system. The permitting process entails first performing an environmental analysis, then obtaining the necessary air, water, historical, or other permits, obtaining a zoning permit, and finally obtaining a construction permit. The interconnection process entails first contacting the local utility to see if interconnection is an option, then applying for grid interconnection, conducting the necessary interconnection engineering, and finally obtaining the interconnection approval. The decision whether to proceed depends not only on the results of the feasibility study, but also on the provisions for interconnection to the local utility. For instance, some utilities may outrightly prohibit interconnection to their grid. The decision to proceed also depends on the ability to obtain the necessary environmental permits for the DG technology being considered. The design and engineering of the project is also linked to the ability to obtain environmental permits. For instance, more stringent combustion controls or exhaust treatments may be required to obtain an air permit.

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:

Agency Jurisdiction
Federal
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
State
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
Local
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.