Blue Bridge White Paper by 202design

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE Report of Findings and Strategic Business Plan

NOVEMBER 8, 2019

TABLE OF CONTENTS Executive Summary.............................................................................................................................................. 1 Part 1: Introduction, Summaries, Recommendations, and Implementation Plan....................................3 1.1 Introduction....................................................................................................................................3 1.2 Summary of Findings.....................................................................................................................4 1.3 Summarized Recommendations..................................................................................................7 1.4 Implementation Plan.....................................................................................................................9 Part 2: Existing Conditions, Data Analysis, Findings and Recommendations........................................ 15 2.1 Pilot Area Selection...................................................................................................................... 15 2.1.1 FSE Clusters with Known Outdoor Extractors........................................................... 15 2.1.2 Downtown Pilot Area.......................................................................................................16 2.1.3 Dupont Pilot Area............................................................................................................. 17 2.1.4 Jefferson Pilot Area........................................................................................................... 18 2.1.5 North Pilot Area................................................................................................................19 2.1.6 Recommendations........................................................................................................... 20 2.2 Vendor Engagement, Procurement and Selection.................................................................. 21 2.2.1 Procurements.................................................................................................................... 21 2.2.2 Extractor Cleaning and Maintenance, & Delivery to WPCP (FOG Recovery)...... 21 2.2.3 Line Jetters.........................................................................................................................22 2.2.4 Requests for Proposal......................................................................................................22 2.2.5 Vendor Registries and/or Certifications........................................................................22 2.2.6 Recommendations............................................................................................................23 2.3 FSE Engagement and Stakeholder Process.............................................................................24 2.3.1 Bundled Stakeholder Engagement.................................................................................24 2.3.2 Process Recommendations.............................................................................................25 2.4 FSE Marketing and Recruitment...............................................................................................26 2.4.1 Messaging and Marketing Materials..............................................................................26 2.4.2 Recruitment Strategy.......................................................................................................26 2.4.2.1 Indiana University (IU).................................................................................... 27 2.4.2.2 Purdue University Fort Wayne (PFW)............................................................ 27 2.4.3 Recommendations............................................................................................................27 2.5 Data Collection and Analysis.....................................................................................................28 2.5.1 Data Gaps and Limitations............................................................................................. 30 2.6 Food Service Establishment (FSE) Assessment .................................................................... 31 2.6.1 Non-Contributors............................................................................................................. 31 2.6.2 FSE Data Gaps and Assumptions .................................................................................. 31 2.6.3 Potential Contributors ....................................................................................................32 2.6.4 Recommendations ...........................................................................................................32

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.7 FOG Recovery Analysis and Projections.................................................................................. 33 2.7.1 Restaurants & Non-Restaurant FSEs with Known Outdoor Interceptor................ 33 2.7.2 Restaurants & Non-Restaurant FSEs With Assumed Outdoor Interceptor...........34 2.7.3 Restaurants & Non-Restaurant FSEs With Known or Assumed Indoor Traps .....34 2.7.4 Schools ............................................................................................................................. 35 2.7.5 Feedstock projections......................................................................................................36 2.7.6 Recommendations............................................................................................................36 2.8 FOG Impacts on FWCU Sewage Collection System..............................................................37 2.8.1 Hydraulic Degreasing.......................................................................................................37 2.8.2 Problem Areas...................................................................................................................37 2.8.3 Degreasing Clusters..........................................................................................................37 2.8.4 2013 Grease Interceptor Cleaning Frequency Study...................................................37 2.8.5 Projected Sewer Operation and Maintenance Reductions........................................39 2.8.6 Recommendations........................................................................................................... 39 2.9 FOG Loading and Treatment Estimates................................................................................. 40 2.9.1 FOG Bypass Estimates.................................................................................................... 40 2.9.2 Recommendations............................................................................................................ 41 2.10 Energy Production Trends and Projections............................................................................42 2.10.1 FWCUGC Projection Methodology ..............................................................................42 2.10.2 FWCUGC Energy Recovery Projections ......................................................................43 2.10.3 Recommendations ...........................................................................................................43 2.11 FOG Authorities...........................................................................................................................44 2.11.1 Extractors â&#x20AC;&#x201C; requirement to install................................................................................44 2.11.2 Extractor Location............................................................................................................44 2.11.3 Extractor Type and Capacity..........................................................................................44 2.11.4 Plumbed Fixtures..............................................................................................................45 2.11.5 Extractor Maintenance and Cleaning............................................................................45 2.11.6 Sampling and Effluent Limitations................................................................................45 2.11.7 Grease Cooperative Authorities.....................................................................................47 2.11.8 Recommendations ...........................................................................................................48 2.12 Implementation and Enforcement...........................................................................................49 2.12.1 Extractors...........................................................................................................................49 2.12.2 Plumbed Fixtures..............................................................................................................49 2.12.3 Sampling and Effluent Limitations............................................................................... 50 2.12.4 Extractor Maintenance and Cleaning........................................................................... 50 2.12.5 Enforcement and Resource Demands.......................................................................... 50 2.12.6 Recommendations............................................................................................................52

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.13 Sewer Rates................................................................................................................................... 53 2.13.1 FWCU Surcharge.............................................................................................................. 53 2.13.2 FWCU Strength Calculation........................................................................................... 53 2.13.3 Alternative Rate Structures.............................................................................................54 2.13.3.1 Differential Rate for FSE Types.........................................................................54 2.13.3.2 Differential Rate for Compliance and/or FOG Best Practices..........................54 2.13.3.3 Combined Differential Rate Structures..............................................................54 2.13.3.4 Differential Rate Impacts on FSEs.....................................................................55 2.13.4 Tipping Fees.......................................................................................................................56 2.13.5 Recommendations............................................................................................................56 2.14 Program Structure and Staffing.................................................................................................57 2.14.1 Separate Roles and Interaction......................................................................................57 2.14.2 Contracted Inspections...................................................................................................57 2.14.3 Recommendations............................................................................................................57 2.15 Data and Administrative Systems.............................................................................................58 2.15.1 Data Gaps Summarized...................................................................................................58 2.15.2 Data Collection Strategies...............................................................................................58 2.15.3 Linko for Data....................................................................................................................59 2.15.4 Linko for Administration.................................................................................................59 2.15.5 Market Alternatives..........................................................................................................59 2.15.6 Recommendations........................................................................................................... 60 2.16 Summarized Projected Program Benefits and Measurable Goals.......................................61 2.16.1 Projected Outcomes / Measurable Goals......................................................................61 2.16.2 Monetized Benefits...........................................................................................................61 2.16.3 Costs...................................................................................................................................61 2.16.4 Net Present Value.............................................................................................................61 2.17 Conclusions...................................................................................................................................62

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

iii

LIST OF TABLES 1. FSEs with Recoverable FOG Production Volumes................................................................................ 32 2. Data Gaps & Strategies Informed............................................................................................................. 58 3. FWCUGC Projected Annual Benefits...................................................................................................... 61

LIST OF FIGURES 1. Resource Recovery Cooperatives............................................................................................................... 3 2. Recommended Pilot Areas...........................................................................................................................6 3. Implementation Schedule..........................................................................................................................14 4. FSE Clusters / Potential Pilot Areas..........................................................................................................15 5. Downtown Pilot Area................................................................................................................................. 16 6. Downtown Pilot Area Feedstock Projections......................................................................................... 16 7. Dupont Pilot Area........................................................................................................................................17 8. Dupont Pilot Area Feedstock Projections................................................................................................17 9. Jefferson Pilot Area..................................................................................................................................... 18 10. Jefferson Pilot Area Feedstock Projections............................................................................................ 18 11. North Pilot Area.......................................................................................................................................... 19 12. North Pilot Area Feedstock Projections.................................................................................................. 19 13. Collection System O&M Costs of FOG...................................................................................................20 14. Pilot Area Feedstock Potential by Comparison.....................................................................................20 15. Annual FOG Deliveries to WPCP............................................................................................................. 22 16. Data Inputs, Outputs, Findings & Projections.......................................................................................29 17. Fort Wayne FSEs with Outdoor Interceptors........................................................................................ 33 18. Outdoor Interceptor Configuration......................................................................................................... 34 19. Baseline & Projected FOG Recovery by Source..................................................................................... 35 20. FWCUGC FOG Recovery Projections..................................................................................................... 36 21. Degreasing Lines with Identified “Hot Spots”....................................................................................... 38 22. Monthly WPCP Energy Portfolio............................................................................................................. 42 23. Sampling Time Requirements...................................................................................................................50 24. Inspection Time Requirements.................................................................................................................51 25. Combined Differential Surcharge Example.............................................................................................55 26. Differential Surcharge – Total Annual Costs to FSEs............................................................................55

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

EXECUTIVE SUMMARY Fort Wayne City Utilities (FWCU) is projected to achieve the following targets within 10 years of implementation of the Fort Wayne City Utilities Grease Cooperative (FWCUGC) by implementing recommended strategic initiatives: ■

Lower operating costs for 865 community restaurants and FSEs, and recognize those businesses as critical contributors to creating sustainable community infrastructure

■

Recover an additional 2.1 million gallons of FOG for codigestion annually over current levels

■

Increase tipping revenues at the WPCP by $213,000 annually

■

Reduce collection system maintenance activities and costs for the prevention of FSE-related sewer obstructions by 25%, or $71,000 annually

■

Remove 4.8 million pounds of chemical oxygen demand (COD) from the City’s waste stream, resulting in savings in wastewater treatment costs of $274,000 annually, or $320 per FSE

■

Generate an additional 144,500 kilowatt hours (KWh) of renewable electricity per month at the WPCP, or 26% over current levels, resulting in a savings of $123,500 per year in energy costs

A number of strategic initiatives are recommended for successful implementation of the FWCUGC and achievement of projected goals. Under a reasonably aggressive time frame, completing these developmental initiatives can be expected to take approximately one year prior to a formal launch of the program.

Strategic Initiatives 1. Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing The program’s success depends on Implementing an effective FSE stakeholder engagement, recruitment, and marketing strategy that bundles parallel stakeholder processes for rule revisions, sewer rates, and FWCUGC implementation, makes use of strategic partnerships with community groups such as Greater Fort Wayne, Inc. and Purdue University – Fort Wayne, and secures high profile advocates in local FSE ownership.

2. Vendor Engagement and Procurement Implement an effective vendor engagement and procurement strategy that secures proven FOG haulers with established records of effectively delivering feedstocks to the Water Pollution Control Plant is critical to the program’s success.

3. Program Resourcing FWCU has recruited and hired a half-time Program Manager in its Utility Energy and Sustainability Services Section to serve as the primary coordinator for development and implementation of the FWCUGC. This role is intended to be the utility’s lead on each of the strategic initiatives above. Resource demands during development and implementation of the program warrant modifying ongoing staffing to the equivalent of a full-time Program Manager in a coordinating role, and two FTE interns, e.g., four half-time interns at all times, for data collection and analysis, supporting research, marketing and recruitment, service scheduling and administration, and billing. Recommended initiatives will also require support from the utility’s procurement staff, City Attorney’s Office, Collection System and Capital Asset groups, and Public Information / Community Relations staff.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

4. Data Collection and Management Additional data collection and field verification for Fort Wayne food service establishments (FSEs) is needed to validate projections, prioritize candidate businesses for marketing and recruitment, and verify infrastructure compliance through plumbing inspection. This will include both field and desk-top data collection for more than 500 businesses but will begin with a limited number of FSEs within proposed pilot program areas in the North-Central and downtown portions of Fort Wayne.

5. Revision of Authorities Revision of FWCU’s enforcement authorities, including General Rules and Regulations and Design Standards is needed to achieve objectives related to restructured and more effective enforcement criteria to support FWCU’s strategic goals and the objectives established for the FWCUGC.

6. FOG Program Structure and Implementation Review and restructuring of FWCU’s approach to FOG program implementation and enforcement is needed, including greater emphasis in cleaning frequency and procedures, reconsideration of the use of sampling and effluent limits for enforcement, the use of certified thirdparty contractors for some field work, and more robust use of existing technology.

7. High Strength Sewer Rates Review and revision of FWCU’s approach to high-strength sewer rates is recommended to better reflect differential costs of service, compel best FOG practices at FSE’s, and incentivize participation in the FWCUGC for long-term feedstock security.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

SUMMARIES, RECOMMENDATIONS, AND IMPLEMENTATION PLAN 1.1

Introduction

Fort Wayne City Utilities (FWCU) established its intent to develop a cooperative resource recovery program for the management and recovery of fats, oils and grease (FOG) generated at area restaurants and food service establishments (collectively, FSEs) in 2017. FWCU’s primary objective in establishing a FOG cooperative is to expand upon the current resource recovery program at the Water Pollution Control Plant (WPCP) as part of its overall strategy to achieve energy neutrality at the WPCP within 10 years by means of codigestion of organic feedstocks and renewable biogas recovery. Implementation of the Fort Wayne City Utilities Grease Cooperative (FWCUGC) was one of three strategic initiatives established by FWCU in response to its 2017-2022 Strategic Planning goals for energy neutrality. Plans to implement the program were among the attributes that earned FWCU honor from the National Association of Clean Water Agencies (NACWA) and partner agencies as a 2018 Water Resource Utility of the Future.1 FOG cooperatives are innovative partnerships between municipal utilities and community FSEs that place the utility at the receiving end of the FOG management transaction with waste haulers. As customer on behalf of the restaurant, the utility brokers and enforces service quality, pricing, and disposition practices in transaction with the hauler. Additionally, long-term security of FOG as a codigestion feedstock is bundled into the

restaurant’s agreement with the utility, and a delivery commitment is bundled into the utility’s transaction with the hauler, allowing the utility to project and achieve renewable energy growth from community restaurants and other FSEs with greater confidence.

Resource Recovery Cooperatives Restaurant Restaurants enroll in the municipal resource recovery cooperative, entrusting the utility to serve as their broker and advocate, and establishing municipal ownership of waste

Sewer Utility Haulers provide service to member restaurants under total oversight and quality assurance by the utility

On behalf of partner restaurants, the utility brokers discounted FOG management practices and disposition in one bundled transaction with haulers

FOG Waste Management

FOG Disposition

Tracking and disposition practices are established in contract and enforced with utility oversight. In addition to measures that prevent illegal dumping and improper disposal, contracts establish security and delivery for resource recovery and anaerobic digestion

Schools

Figure 1. Resource Recovery Cooperatives

Blue Bridge Cooperatives, LLC (BlueBridge) is being retained by FWCU to develop a Strategic Business Plan for implementation of the FWCUGC. Recommended measurable goals and implementation strategies directly or indirectly support many of the specific goals established in FWCU’s 2017-2022 Strategic Plan, including: ■

Empowering stakeholders with information to enable them to protect water quality through proper use of the wastewater system

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

■

Better informing customers relative to their use of resources, enabling them to make more environmentally friendly decisions

■

Establishing rates, fees, and charges (e.g., for grease interceptor service, FOG disposition, and commercial sewer charges) that meet FWCU’s objectives

■

Supporting the community’s desire to grow jobs and the City’s tax base; and

■

Continuing efforts to identify cost-effective measures to reduce FWCU’s use of energy, related costs, and associated greenhouse gas emissions (GHGs), including prioritizing potential renewable energy strategies.

This last goal of renewable energy generation through long-term consistent FOG feedstock security has been identified by FWCU through this strategic planning process as the highest priority goal for the FWCUGC. Specific objectives of the program that are the basis of recommendations in this report are: ■

Provide the most efficient, effective, and measurable protection of FWCUs sewage collection system from the detrimental effects of FOG in a way that best supports Fort Wayne’s food service businesses.

■

Establish transparency and quality in the grease trap and interceptor service provided to local restaurants by FOG recovery service providers by establishing FWCU as restaurants’ advocate in service transactions.

■

Establish transparency and quality in the transport and disposition of FOG collected from community restaurants by FOG recovery service providers to ensure that disposition practices best support the goals of the utility and community.

■

Ensure that FOG collected from participating restaurants is delivered to FWCU’s Water Pollution Control Plant (WPCP); that collection, transport and

delivery procedures best support FWCU’s goals for resource recovery and energy generation at the WPCP; and that that FOG recovery is effectively coordinated with FWCU’s Resource Recovery Phase II - Liquid Organic Waste Procurement and Management Program.

1.2 Summary of Findings This section provides summary of the detailed findings in Part 2 of this report. For more detailed descriptions of methodologies and assumptions, see referenced sections in Part 2.

FSE Analysis and FOG Recovery Projections An estimated 704 Fort Wayne FSEs have outdoor interceptors with average capacities of 1,000 gallons and will be the primary targets for enrollment in the FWCUGC. Projections assume that 85% of these FSEs, or 598 FSEs with 1,000 gallon interceptors, can be enrolled in the FWCUGC within the first 10 years of implementation. Additionally, projections assume another 267 FSEs with indoors grease traps could be retrofit to have outdoor interceptors and could be enrolled in the cooperative within the first 10 years with appropriate incentives, bringing projected membership to 865 FSEs after 10 years. Note that these estimates include generalized assumptions for approximately 489 FOG producers because site specific information regarding extractor type, size and location is unrecorded. For these FSEs, field verification is necessary to validate assumptions. If this target of 865 member FSEs can be achieved after 10 years, an additional 2.1 million gallons over baseline FOG deliveries is projected to be recovered and delivered to the WPCP in year 10 of the program. See Part 2, Sections 2.6 and 2.7 for more detailed descriptions of methodologies and assumptions used to project FWCUGC participation and resulting FOG recovery.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Collection System Impacts of FOG Annually, FWCU conducts hydraulic degreasing on 188 miles of sewer line due to restaurant FOG, at a cost of over $287,000 to the utility to prevent sewer obstructions. Almost 30% of the utility’s degreasing activities, and approximately $84,000 in annual costs for degreasing, are estimated to be preventable by implementing and enforcing extractor cleaning frequency requirements consistent with grease interceptor manufacturers’ specifications. Projected reductions of $71,000 annually in degreasing costs depend on FWCU’s implementation of effective cleaning frequencies and protocol. See Section 2.8 for more detail.

FOG Loading and Treatment Estimates FOG bypass into FWCU’s system is estimated to be 1.98 million gallons per year due solely to inadequate cleaning frequencies, requiring treatment of 7.3 million pounds of COD annually, or 5,495 pounds of COD per FOGproducing FSE per year. The cost of this treatment is conservatively estimated to be approximately $423,000 annually for FWCU, or over $300 per FSE based on the strength of waste surcharge calculation in Sewer Use Ordinance (SUO) §51.075(B)(1) and (2). See Section 2.9 for more detail.

Energy Production Trends and Projections Currently, approximately 31% of the WPCP’s monthly energy demand is generated from biogas recovery. To meet FWCU’s renewable energy goal 100% of the facility’s demand within the next 10 years, the WPCP must generate an additional 1,222,000 renewable kilowatt hours (KWh) monthly in addition to the current average of 550,000 KWh. That amounts to a 122% net increase in energy recovery within 10 years. Based on FWCUGC growth projections, estimated energy production is expected to increase by approximately 144,500 KWh per month by year 10 of the program. Energy recovery from the FWCUGC is projected to save FWCU $123,500 per year. The year

10 projection represents a 26% increase in renewable energy production over current levels and delivers approximately 12% of the additional energy needed to achieve FWCU’s neutrality goal. See Section 2.10 for more detail.

FOG Authorities An estimated 37.5% of FOG generated at Fort Wayne FSEs, on average, may be bypassing extractors due solely to the lack of enforceable cleaning frequencies and practices. Additionally, requirements for cleaning frequency and protocol are critical for compelling FSE participation in the FWCUGC. Requirements for effluent sampling and limits are practiced as FWCU’s stand-alone line-inthe-sand for FSE compliance. The structure of these requirements appears to create a regulatory framework that is designed to be reactive to FSEs located on sewer lines requiring excessive grease-related maintenance, rather than proactively protecting both the collection system and the WPCP. Resource constraints restrict FWCU’s ability to implement effective sampling frequencies, and the high rate of sample violation for FSEs that are otherwise determined to be in compliance with extractor and plumbing requirements raises questions regarding the efficacy of sampling to inform preventative FOG practices and/or compliance assessments. See Section 2.11 for more detail.

Implementation and Enforcement The thoroughness of FWCU’s process for plumbing verification stands out among peer utilities. Dye testing is effective at both identifying plumbing non-compliance and limiting recidivism. Effective dye test inspections, however, are the most resource-intensive component of FWCU’s inspection process. As a result, only 35% of FWCU FSEs have been dye tested for compliance with plumbing requirements in the last five years.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Additionally, approximately 39% of active regulated Fort Wayne FSEs are not documented as ever having been inspected for compliance with the requirement to install an extractor. FWCU is able to conduct comprehensive initial inspections, and any follow-up inspections, of approximately 200 FSEs annually, and collect compliance and repeat samples at approximately 80 facilities annually. At these inspection rates, it would take eight years to inspect all regulated FSEs. See Section 2.12 for more detail.

Sewer Rates FWCU currently utilizes a flat strength surcharge for all FSEs of $1.0129 per 100 cubic feet (ccf) of metered water. A flat volumetric surcharge for FSEs based on strength is common industry practice but does not distinguish between FSE types and characteristics that result in dramatically variable wastewater strengths. Additionally, a flat surcharge does not reflect distinctions between FSEs with effective and ineffective FOG practices.

Increasingly, utilities are turning to distinctions within FSE flat sewer rates based on FSE type. Additionally, differential rates based sitespecific practices and compliance status are effectively used to compel best practices, such as participation in resource recovery programs like the FWCUGC. See Section 2.13 for more detail.

FWCUGC Pilot Program Area Four areas with dense clusters of FSEs were reviewed as candidates for pilot program implementation. At 188 FSEs within a 4.5 square mile area, the North Pilot Area (see map below) has a more dense concentration of FSEs than any other area of its size within FWCUâ&#x20AC;&#x2122;s service area, and includes 13% of Fort Wayneâ&#x20AC;&#x2122;s FSEs with the potential to produce recoverable FOG. FSEs within this cluster have the potential to contribute approximately 444,000 gallons annually to codigestion.

North Pilot Area

Figure 2

Downtown Pilot Area

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

This dense cluster of FSEs also has a more significant impact on collection system maintenance of any other area within FWCU’s system. Two of six of the “hot spots” within FWCU’s collection system are located within this area, and 313,000 linear feet of sewer line annually, or 32% of all of FWCU’s annual degreasing activities, are concentrated in this area and account for 34% of FWCU’s greaserelated O&M costs.

The Downtown Pilot Area provides challenges related to available feedstock security and retrofit potential, but it provides great opportunities for branding and integrating resource recovery innovation into redevelopment efforts in the urban core. These two areas, out of four areas evaluated, are recommended for pilot program implementation. See Section 2.14 for more detail.

1.3 Summarized Recommendations The following table provides summarized recommendations for implementation based on data analysis and findings. More detailed descriptions of each recommendation are provided in Part 2, with corresponding sections referenced below in parentheses. RECOMMENDATIONS FSE Engagement and Stakeholder Process

• Bundle FSE engagement processes for FWCUGC implementation, revisions to the R&R, and adoption of new high-strength sewer rates (2.3) • Engage first with industry groups, including Greater Fort Wayne, Inc., the Northeast Indiana Hospitality Association, and the Indiana Restaurant and Lodging Association to establish up-front support for initiative that impact FSEs (2.13) • Inform and secure approximately five high profile business advocates in local FSE ownership (2.3)

FSE Marketing and Recruitment

• Continue to engage with both PFW and IU in preparation for hiring interns to perform the bulk of recruitment activities (2.4) • Continue to develop marketing materials in-progress for distribution during recruitment (2.4)

Vendor Engagement, Procurement and Selection

• Engage individually and early on with experienced haulers of FOG (2.2) • Finalize RFPs for FOG recovery and line jetting, and hold pre-bid meetings once RFPs are issued (2.2) • Establish a vendor registry for ancillary services in the FWCUGC Terms of Enrollment and develop criteria for registration (2.2)

Data Collection and Management

• Collect site-specific information for all FSE’s without extractor information populated in FWCU systems (2.6, 2.7, 2.15) • Conduct assessments to determine which FSEs with indoor traps would be suitable for retrofits for FSEs with indoor traps to outdoor locations (2.6, 2.15) • Conduct a new collection system study during pilot program implementation to differentiate the impacts of cleaning interceptors at different frequencies (2.8) • Collect and maintain FSE-specific data on sales/service volume and water consumption (2.9, 2.15) • Make better use of Linko functionality and explore how Linko can be utilized to streamline data entry and management; engage Linko to discuss the full suite of data and administrative functions needed to support the FWCUGC and related goals, and solicit a quote for full migration to the hosted solution and implementation of supporting modules (2.12, 2.15)

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

RECOMMENDATIONS FOG Authorities

• Establishing specific and enforceable criteria for extractor cleaning frequency and procedures (2.7, 2.11) • Directly establish the enforceability and authority to issue civil penalties for failure to comply with cleaning frequency and procedure requirements as well as other requirements unrelated to effluent sampling (2.11) • Establish FWCUGC authorities and terms of enrollment in a stand-alone Terms of Enrollment authority to be approved by the Board of Public Works (2.11) • Reconsider the use of sampling and enforcement of discharge limitations as a sole or even primary enforcement criteria. Revise authorities accordingly (2.11, 2.12) • Remove distinctions for high maintenance portions of the collection system and expressed or implied differential criteria. Make FOG requirements and criteria uniform across the service area (2.11) • Establish more flexible extractor sizing criteria based on FSE-specific calculations of grease production (2.11)

Implementation and Enforcement

• Conduct plumbing/dye test inspections at all Fort Wayne FSEs on a 5-year rotation (2.15) • Consider the development of a certification process for the utilization of thirdparty vendors for trap and plumbing inspections (2.12, 2.2) • Consider desktop self-inspections and e-reporting for low risk FSEs and/or FSEs with histories of compliance (2.12) • Establish and implement specific goals for inspection frequencies that effectively ensure and document a high rate of compliance and resource recovery (2.12)

Sewer Rates

• Adopt a combined differential tiered high-strength rate structure that considers FOG production based on FSE type, characteristics, and FSE-specific practices (2.13) • Establish a discounted WPCP disposal fee for FWCUGC members and consider a billing structure in which disposal costs are billed directly to FSEs (2.13)

Pilot Area Selection

• Adopt the North Pilot Program Area and the Downtown Pilot Area as areas for pilot program implementation (2.14)

Program Structure and Staffing

• Administer the FWCUGC from the utility’s Energy and Sustainability office, but establish clear lines of coordination between FWCUGC and IPS (2.14) • Staff the FWCUGC with one FTE, and the equivalent of 2 full time interns, or four part-time, for recruitment during the pilot program, possibly expanding to two FTEs during full scale implementation (2.14)

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

1.4 Implementation Plan This section provides phase-by-phase tasks and outcomes that FWCU needs to implement and achieve in preparation for a pilot program implementation time frame of one year from commencement of these activities. Subsequently, the pilot phase will last an additional year. PHASE I: MONTHS 1-2

Initiative 1: Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing a. Working with the City’s Community Liaison, develop a vision and strategy for bundling FSE stakeholder processes for rate adjustments, revision of the General Rules and Regulations, and implementation of the FWCUGC. b. Make contact with Greater Fort Wayne, Inc., Northeast Indiana Hospitality Association, and Indiana Restaurant and Lodging Association; hold meeting with each to explain the FWCUGC and seek support and endorsement from each organization. c. Working with Greater Fort Wayne Inc., develop a schedule and strategy for holding a stakeholder meeting with restaurant community participants in Phase II of this implementation schedule. Decision Point: Whether to bundle FWCUGC stakeholder engagement processes and strategy with outreach processes and strategy for rate adjustments.

Initiative 2: Vendor Engagement and Procurement a. Meet individually with five vendors identified in Section 2.2, and any other potential candidate vendors, to inform them of plans for the FWCUGC, assess each one’s interest in being a participating vendor, and address any questions and concerns. Include IPS’ FOG Coordinator in these meetings; also discuss possible third-party certified plumbing inspection concept and solicit feedback.

Initiative 3: Program Resourcing a. Recruit and hire up to four half-time (20 hour) interns for one-year internships in partnership with Purdue University Fort Wayne’s (PFW) School of Public Policy and Cooperative Education Program (contact: Debra Barrick, (260) 481-5471). b. Consult with and advise management in supporting workgroups, including procurement, customer service/billing, City Attorney, etc., regarding their contributions to the program and resource demands. c. Modify Program Manager position to create a full-time Program Manager role. Alternatively but less preferably, hire another part-time position to create the equivalent of one FTE for FWCUGC program management and coordination. Decision Point: Increase the part-time Program Manager to a full time position or hire an additional part-time position

Initiative 4: Data Collection and Management a. Assign interns collection of data for all FSEs (extractor size, location) with unknown extractor information within the North and Downtown Pilot Program Areas and begin data collection. b. Begin plumbing inspections and dye testing of all FSEs within pilot program areas not dye tested within the last 5 years to assess baseline compliance using Industrial Pretreatment Section (IPS) staff and interns. c. Assign interns to begin compiling information for FSEs city-wide on water consumption from water metering and billing systems, and restaurant sales from local or state financial and tax/license recordings, if available. This will be used to perfect FOG recovery projections and to support potential differential rate categories. d. Working with Collection System and Capital Asset teams, develop a strategy for, and design the specific protocol for,

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

implementation of a follow-up cleaning frequency study based on recommendations in Sections 1.3 and 2.8. Decision Point: Adoption of recommended pilot program areas

Initiative 5: Revision of Authorities a. Convene internal meeting to discuss specific sections of General Rules and Regulations in need of revision and goals of revisions based on recommendations in Section 1.3, 2.11 and 2.12; include Energy & Sustainability Program Manager as Coordinator, City Attorney’s Office, IPS FOG Coordinator, and others as deemed appropriate. b. Complete draft revisions to the Rules and Regulations in preparation for stakeholder engagement and feedback based on recommendations. c. Complete draft of FWCUGC Terms of Enrollment in preparation for stakeholder engagement and feedback. Decision Point: Adoption of extractor cleaning frequency requirements

Initiative 6: FOG Program Structure and Implementation a. Convene internal meeting to include IPS FOG Coordinator and Utility Energy & Sustainability Office to discuss and consider recommendations in Sections 1.3, 2.12 and 2.15, and possible third-party certification and inspection program as described in Sections 2.2 and 2.12. b. Meet with Linko to discuss the full suite of data and administrative functions needed to support the FWCUGC and related goals, and solicit a quote for full migration to the hosted solution and implementation of supporting modules. Decision Point: Whether to develop a program for third-party plumbing inspections based on recommendations in Section 1.3, 2.2 and 2.12

Initiative 7: High Strength Sewer Rates a. Convene internal meeting between Utility Energy & Sustainability Office and utility leadership involved in the current sewer rate revision process to determine: 1) whether to pursue the development of a differential rate structure for FSEs; 2) whether the timing of FWCU’s rate revision process allows for development of a differential rate structure for FSEs; and 3) set a timeline for development of differential rate structure based on rate revision schedule; 4) determine plans for commercial stakeholder engagement for rate adjustments to coordinate that process with FWCUGC stakeholder engagement. b. Depending on the outcome of (a), convene meeting with FWCU’s rate consultant to formalize the development of a differential high-strength sewer rate structure. Decision Point: Whether to develop a differential rate structure for high-strength sewer customers. PHASE II: MONTHS 3-6

Initiative 1: Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing a. Working with assistance from Community Liaison and Greater Fort Wayne Inc., identify and meet with approximately five high profile restaurant industry professionals to explain the business and community benefits of the FWCUGC and to solicit their advocacy. b. In coordination with sewer rate revision team, Community Liaison, and Greater Fort Wayne Inc., schedule and hold the first of two to three public meetings with broader FSE stakeholders, to present the FWCUGC, related rule revisions, and proposed high strength sewer rate adjustments. Solicit feedback on rules, rates and Terms of Enrollment and address comments and concerns.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Initiative 2: Vendor Engagement and Procurement a. Develop and issue the RFP for vendor services. b. Hold pre-bid open meetings to further explain the program and answer questions. c. Begin development of vendor registry categories and criteria based on recommendations in Sections 1.3 and 2.2.

Initiative 3: Program Resourcing a. Complete reclassification of Program Manager to full time, or complete recruitment of additional half-time support.

c. Meet with Development Services to discuss revisions to Design Standards (SA6) based on recommendations in Sections 1.3 and 2.11. make revisions to SA6 based on this meeting and prepare to present to Board of Public Works for approval along with rule revisions.

Initiative 6: FOG Program Structure and Implementation a. Continue to review and develop changes to FOG program structure and inspection priorities based on recommendations in Sections 1.3, and 2.12.

Initiative 4: Data Collection and Management

b. Begin developing criteria for a certification process for third-party plumbing inspections, depending on decision made during Phase I.

a. Complete collection of data for all FSEs with unknown extractor information within the North and Downtown Pilot Program Areas.

c. Begin procurement and implementation of improvements to Linko based on quote and functionality provided by Linko in Phase 1.

b. Complete plumbing and dye test inspections for all FSEs in pilot areas so that all FSEs in these areas will have been inspected within the last five years.

d. Continue to develop and implement thirdparty certification process for plumbing inspections.

c. Complete compiling information for FSEs city-wide on water consumption from water metering and billing systems, and restaurant sales.

Note: Continuation of this initiative depends on the decision point in Phase I

d. Convene Utility / FWCUGC billing workgroup to discuss integration of FWCUGC billing into existing billing system. e. Continue to develop a strategy for, and design the specific protocol for, implementation of a follow-up cleaning frequency study.

Initiative 7: High Strength Sewer Rates

a. Using data on FSE type, service volume, water consumption, utility costs and benefits, and methodologies used by other utilities, develop a draft rate proposal for consideration in the current sewer rate adjustment process. Present the draft proposal to the internal rate adjustment team for review and consideration.

Initiative 5: Revision of Authorities a. Make further draft revisions to authorities based of feedback from FSE stakeholders after holding initial meetings in coordination with Greater Fort Wayne Inc. b. Prepare Rule Revisions for approval by Board of Public Works.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

PHASE III: 7-9 MONTHS

Initiative 1: Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing a. Develop and finalize marketing strategy and materials, develop list of prioritized FSEs within pilot program areas. b. Hold the last of two to three public meetings with broader FSE stakeholders to present the FWCUGC, related rule revisions, and proposed high strength sewer rate adjustments.

Initiative 2: Vendor Engagement and Procurement a. Convene vendor selection team for review of proposals submitted in response to RFP. b. Make vendor selection(s) based on review criteria, including pricing. c. Begin to draft vendor contract(s). d. Finalize vendor registry categories and criteria.

Initiative 3: Program Resourcing (Complete) Initiative 4: Data Collection and Management a. Utilize interns to begin collection of extractor data (size, location) for expected high FOG producers outside of pilot program areas. b. Begin baseline data collection for collection system cleaning frequency study, e.g., TVing lines in selected study area, gathering baseline cleaning frequency data.

a. Implement modifications to Linko functionality based on scope and changes provided in Phase II, including merge of Linko to hosted solution. b. Implement changes to Inspection and Enforcement structure and procedures.

Initiative 7: High Strength Sewer Rates Note: Continuation of this initiative depends on the decision point in Phase I a. Include recommended differential high strength rate structure with other rate changes and carry through the rate adjustment hearing and approval process concurrent with other changes. PHASE IV: 10-12 MONTHS

Initiative 1: Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing a. Utilizing interns, commence marketing and recruitment strategy within the pilot areas.

Initiative 2: Vendor Engagement and Procurement a. Finalize vendor contract(s). b. Establish pricing schedules for contracted service. c. Market vendor registry to qualifying vendors and begin to build registry.

Initiative 3: Program Resourcing (Complete) Initiative 4: Data Collection and Management

c. Continue to develop a strategy for integration of FWCUGC billing into existing billing system.

a. Continue collection of extractor data (size, location) for expected high FOG producers outside of pilot program areas.

Initiative 5: Revision of Authorities

b. Continue baseline data collection for collection system cleaning frequency study, e.g., TVing lines in selected study area, gathering baseline cleaning frequency data.

a. Revise draft rules, terms & SA6 based on stakeholder feedback

Initiative 6: FOG Program Structure and Implementation

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

c. Finalize strategy for integrating FWCUGC billing into existing utility billing system, and/or for integrating Linko or other software functionality into existing system.

Initiative 5: Revision of Authorities a. Obtain approval from Board of Public Works for revisions to General Rules and regulations and to Designs Standards SA6.

Initiative 6: FOG Program Structure and Implementation a. Implement modifications to Linko functionality based on scope and changes provided in Phase II, including merge of Linko to hosted solution. b. Implement changes to Inspection and Enforcement structure and procedures. c. Implement third-party certification and inspection program/procedures.

Initiative 3: Program Resourcing (Complete) Initiative 4: Data Collection and Management a. Collect data from pilot program implementation, e.g., recruitment rates, FOG recovery, program costs, etc. b. Continue collection of extractor data (size, location) for expected high FOG producers outside of pilot program areas. c. Begin collection of extractor data for expected low FOG producers outside of pilot areas. d. Begin field assessment of indoor traps for retrofit potential to outdoor extractors. e. Implement cleaning frequency changes for collection system cleaning frequency study, collect data, and complete study. f. Implement new billing functionality during pilot phase.

Initiative 5: Revision of Authorities (Complete) Initiative 6: FOG Program Structure and Implementation

PILOT PHASE: MONTHS 13-24

a. Continue to implement new inspection and enforcement procedures, and tweak as necessary.

Initiative 1: Restaurant / FSE Stakeholder Engagement, Recruitment and Marketing

b. Implement third-party plumbing inspection process.

a. Continue marketing and recruitment strategy within the pilot areas.

Initiative 2: Vendor Engagement and Procurement

Initiative 7: High Strength Sewer Rates (Complete)

a. Begin and monitor contracted services; review vendor performance. b. Continue recruiting for vendor registry.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Months 13-24

Month 12

Month 11

Month 10

Month 9

Month 8

Month 7

Month 6

Month 5

Month 4

Month 3

Month 2

Month 1

Figure 3. Implementation Schedule FSE Stakeholder Engagement, Recruitment & Marketing Determine Coordination Strategy for FWCUGC, Rules & Rates Engage Industry Groups; Develop Strategy for FSE Engagement Identify & Meet w/ Restaurant Business Advocates Hold 2-3 FSE Stakeholder Meetings & Solicit Feedback Develop & Finalize Marketing Materials Marketing & Recruitment Using Interns Vendor Engagement & Procurements Engage with Individual Haulers Draft & Publish RFPs; Hold Pre-Bid Meeting(s) Develop Vendor Registry & Criteria Review & Select Haulers Develop & Execute Contracts; Establish Pricing Schedule Engage & Recruit for Vendor Registry Begin / Monitor Contracted Services Program Resourcing Recruit/Hire Interns Consult w/ Supporting Workgroups on Staffing Needs Increasing Program Staffing to one FTE Data Collection and Management Collect FSE Extractor Data (Pilot Area) Pilot Area Plumbing Inspections / Dye Tests Collect Data on FSE Type, Sales/Service, Water Use Cleaning Frequency Study, Design, Data Collection, Implementation FWCUGC Financial and Billing System Development and Implementation Collect FSE Extractor Data (Outside Pilot Area - FOG Producers) Collect FSE Extractor Data (Believed Low FOG Producers) Collect Information on Trap Retrofit Potential Pilot Program Data Collection Revision of Authorities Draft Revised General Rules & Regulations Draft FWCUGC Terms of Enrollment Revisions to Design Standards Manual, (SA6) Revise Rules, Terms & SA6 Based on Stakeholder Feedback Board of Public Works Approval FOG Program Structure & Implementation Evaluate Current & Alternative Program Structures Meet w/ Linko, Procure Full Linko Functionality Develop Criteria & Procedures for Third-Party Inspection Process Implement Changes to Inspection & Enforcement Procedures Implement New Linko Modules & Migrate to Hosted Solution Implement Third-Party Certification & Inspection Process High Strength Sewer Rates Meet Internally & w/ Rate Consultant to Evaluate Recommended Rates Develop Proposed Differential Rate Structure/Strategy Rate Adjustment / Approval Process (Timing Uncertain) Implement Rate Revisions

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

EXISTING CONDITIONS, DATA ANALYSIS, FINDINGS AND RECOMMENDATIONS 2.1

Pilot Area Selection

FWCU has established its intent to first deploy the FWCUGC as a pilot program with a limited scope and area. FWCU has retained BlueBridge in part to evaluate service area FSEs and to establish proposed pilot area program boundaries, desired participants, and an implementation plan for deployment of the Pilot FWCUGC that is designed to inform a full-scale program. A number of criteria are being considered to identify pilot program parameters, all of which are intended to return measurable results that could be used to test baseline projections and inform full-scale implementation. Desirable characteristics of a pilot program area were determined in consultation with FWCU and include: ■

A concentrated cluster of FSEs with outdoor grease interceptors, and large feedstock potential, within a limited area

■

Feedstock recovery for codigestion as the highest priority goal

■

A preference to start with restaurants as the highest priority, not to the exclusion of nonrestaurant FSEs

■

Significant potential for FOG recovery, and the opportunity to measure FOG recovery during a pilot program that could be compared to the FOG recovery projections in this report

■

Significant baseline activity and costs for FSE-related collection system degreasing, for which reductions resulting from pilot program implementation could be measured

Figure 4. FSE Clusters / Potential Pilot Areas

■

Proximity to collection system “hot spots” identified by FWCU’s Asset Management group

2.1.1 FSE Clusters with Known Outdoor Extractors The first process for selection of candidate pilot program areas was simply a visual survey of FWCU’s service area to identify areas that have concentrated clusters of FSEs with outdoor interceptors. Having established Google map layers for each of the categories of FSEs identified in Section 2.6, this assessment of FSE clusters allowed for the identification four distinct clusters that could be considered candidate areas.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

West, and Monroe to the East. This area was considered due to spatial density of FSEs, but also because innovative concepts like the FWCUGC pair well with urban redevelopment efforts and economic development incentives focused on the urban core. Bold concepts in resource recovery integrate and brand well with bold redevelopment projects like the Landing and Electric Works. Within this area, there are 95 FSEs. However, only 22 are known to have outdoor interceptors, and 41 have interior traps. Thirty of the FSEs in this area have Figure 5. Downtown Pilot Area, showing outdoor interceptors in large circles and indoor traps and extractors of unknow type, size unknown extractors in smaller dots. Smaller dots almost certainly have lower potential for feedstock and location. This area currently security than like FSEs in other pilot areas due to limited space and access for retrofitting to outdoor contributes approximately 21,600 interceptors. Red lines show very limited degreasing areas in downtown. gallons of FOG to codigestion The remainder of this section present annually and has a maximum projected comparative data and considerations for each of potential of 166,000 based upon Section 2.7 the four areas, concluding with recommended assumptions. However, the assumptions used pilot areas and supporting conclusions. of 50% of FSEs with unknown extractors having outdoor interceptors is almost certainly high 2.1.2 Downtown Pilot Area in downtown due to limited space and exterior This area encompasses just less than one access. Additionally, this is one pilot area square mile of the downtown core roughly candidate where assuming 100% of interior bordered by Superior Street to the North, traps in stand-alone building can be retrofit to Brackenridge to the South, Broadway to the

Downtown Pilot Area Feedstock Projections (gal/an) 180,000

Orange and grey sections of feedstock security and growth are probably larger than actual potential due to limited space and accessibility downtown

160,000 140,000 120,000 100,000 80,000 60,000 40,000 20,000 0 Current

5 Year

10 Year

Max Potential

■ Known Outdoor Extractor ■ Assumed Outdoor Extractor ■ Outdoor Retrofit ■ Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 6. Downtown Pilot Area Feedstock Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Figure 7. Dupont Pilot Area showing FSEs with Outdoor Grease Interceptors and degreasing areas (red)

outdoor interceptors is also inaccurately high due to limited space for outdoor interceptor installation. Conversely, downtown projections do not account for redevelopment growth that will attract food corridors. In summary, current FSEs downtown provide little opportunity to inform full-scale FWCUGC implementation. Additionally, this area is scheduled for only 15,043 linear feet of degreasing annually at a cost of $4,362 annually. This provides little opportunity to observe the collection system benefits of the pilot FWCUGC. However, downtown provides the best opportunity for branding the FWCUGC as a bold innovation that complements sustainable development in the urban core.

Within this cluster, there are 40 FSEs with known outdoor interceptors, 28 FSEs with indoor traps, and 14 FSEs with unknown extractor type and location. FSEs within this area currently contribute approximately 54,000 gallons of FOG per year to the WPCP codigestion operation and are estimated to have a maximum potential of 208,000 gallons of recoverable FOG annually based on assumptions and projections in Section 2.7. One unique characteristic of this area is that 83% of the projected feedstock potential comes from existing FSEs with outdoor interceptors. Accordingly, retrofitting and data collection for unknowns is less critical than in other areas to achieving feedstock projections. The Dupont area requires 58,316 linear feet of hydraulic degreasing annually at a cost of $16,912, mostly at major intersections with restaurant clusters spread throughout the eastwest length of Dupont Road.

2.1.3 Dupont Pilot Area

This northern-most potential pilot area candidate consists of 4.25 linear miles eastwest along Dupont Road, between Lima and Diebold Roads, and includes FSEs on the Western frontage of Lima Road, Dupont Pilot Area Feedstock Projections (gal/an) and extending South on Lima to 250,000 just North of Till Road. This linear 200,000 configuration provides for good 150,000 sequencing of 100,000 service schedules. 50,000 0

Current

5 Year

10 Year

Max Potential

■ Known Outdoor Extractor ■ Assumed Outdoor Extractor ■ Outdoor Retrofit ■ Schools

Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 8. Dupont Pilot Area Feedstock Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

It contains 65 FSEs with known outdoor interceptors, 17 with known indoor traps, and 35 with unknown extractor type and location. At 115,000 gallons of FOG annually, it has the largest current contribution of FOG to the WPCP volumetrically and has a maximum recovery potential of 385,000 gallons annually. Notably, only a marginal amount of projected feedstock in this area comes from retrofits due to the disproportionately low number of indoor traps. Approximately 64,000 linear feet of degreasing is performed annually to maintain sewer lines along Jefferson at a cost of $18,554 annually. However, much of that is responsive to grease discharges from multi-family housing along Getz Road. The only FSErelated degreasing occurs in the area of Jefferson Pointe and Parkwest. Figure 9. Jefferson Pilot Area showing FSEs with outdoor interceptors and degreasing lines Accordingly, there would be little opportunity to observe any collection 2.1.4 Jefferson Pilot Area system improvements resulting from improved This cluster extends five linear miles southwestmanagement of FOG other than at the northeast along Jefferson Blvd, between Liberty intersection of Jefferson and Illinois. Mills Road and Illinois Road, and includes the Jefferson Point and Parkwest shopping centers and surrounding cluster of restaurants.

Jefferson Pilot Area Feedstock Projections (gal/an) 400,000 350,000 300,000 250,000 200,000 150,000 100,000 50,000 0

Current

5 Year

10 Year

Max Potential

■ Known Outdoor Extractor ■ Assumed Outdoor Extractor ■ Outdoor Retrofit ■ Schools

Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 10. Jefferson Pilot Area Feedstock Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.1.5 North Pilot Area This cluster of FSEs is roughly contained South of Ludwig Road, North of the intersection of Lima Road and Clinton Street, East of the direct Southern elongation of the intersection of Ludwig and Lima, and West of the direct North/South elongation of Washington Center Road and Clinton Street. At 188 FSEs within a 4.5 square mile area, it has a more dense concentration of FSEs than any other area of its size within FWCU’s service area, and includes 13% of Fort Wayne’s 1,404 FSEs with the potential to produce recoverable FOG. The 188 FSEs in this area include 82 with known outdoor interceptors, or 20% of known outdoor interceptors in FWCU’s service area. Sixty FSEs have known indoor traps, and 46 have unknown extractor size type or location. Sixtysix of the FSE’s with outdoor interceptors are commercial restaurants, and only 16 are nonrestaurant FSEs. Currently, FSEs within this cluster contribute approximately 109,000 gallons annually to codigestion, with a maximum potential of 444,000 gallons. Predominant sources are restaurant FSEs with existing outdoor interceptors, accounting for 340,000 gallons of feedstock potential annually.

Figure 11. North Pilot Area

North Pilot Area Feedstock Projections (gal/an) 450,000 400,000 350,000 300,000 250,000 200,000 150,000 100,000 50,000 0

Current

5 Year

10 Year

Max Potential

■ Known Outdoor Extractor ■ Assumed Outdoor Extractor ■ Outdoor Retrofit ■ Schools

Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 12. North Area Feedstock Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Collection System O&M Cost of FOG Downtown Dupont 1% 6%

Jefferson 6%

Non-Pilot 53%

North 34%

Schools Figure 13. Collection System O&M Costs of FOG, showing costs by potential pilot area

2.1.6 Recommendations The North Pilot area provides an opportunity to secure FOG feedstock from 20% of Fort Wayne’s FSEs with outdoor interceptors, and 13% of all commercial FOG sources, within a 4.5 square mile area. FSEs in this area are 3.25 times the average City FSE density, and FOG bypasses from this area account for 34% of FSE-related collection system costs. Two of six greaserelated “hot spots” are within this area, and it is home to the only FSE-related system blockages within the last three years. The Downtown Pilot Area provides challenges related to available feedstock security and retrofit potential, but it

provides great opportunities for branding and integrating resource recovery innovation into redevelopment effort in the urban core. BlueBridge recommends adoption of the area established as the North Pilot Program Area for initial implementation of the FWCUGC. Additionally, concurrent implementation should be considered in the Downtown Pilot Area. A combined implementation in these areas provides the best opportunity for resource recovery, measurable verification of projections, and branding the program in alignment with innovative redevelopment in the urban core.

Pilot Area Feedstock Potential by Comparison (gal/an) 450,000 400,000 350,000 300,000 250,000 200,000 150,000 100,000 50,000 0

Current

5 Year

10 Year

Max Potential

■ Downtown ■ Dupont ■ Jefferson ■ North

Figure 14. Pilot Area Feedstock Potential by Comparison

Assumed Outdoor Extr actor

Outdoor Retrofit

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.2 Vendor Engagement, Procurement and Selection The menu of services that can be procured for a FOG cooperative must include extractor maintenance, cleaning, and recovery services by haulers; and line jetting services, but can also include a number of supporting services for the convenience of FSEs such as minor extractor repairs (e.g., baffle replacement), extractor installation, plumbing upgrades, and fryer oil collection. Tempe Arizona’s Grease Cooperative learned after a number of years of operation that procurements are the best way to establish accountability for critical services, but municipal procurement processes require significant time and resources to complete. Tempe also learned that once the utility establishes itself as advocate in the realm of FOG management, it should also be prepared to provide some direction to FSEs regarding where to go for quality supporting services. In response, Tempe adopted the concept of a vendor registry for ancillary services that the utility can provide to member FSEs for direct transaction, and on which plumbing or minor repair providers can be listed if they pass and maintain certain service quality criteria. The registry does not imply any endorsement of vendors, but only describes the criteria that listed vendors pass in order to be listed – it is said to be the “Angie’s List” of supporting services for the Tempe Grease Cooperative. This process brought value to FSEs for supporting services and also saved the utility significant time on procurements and transaction management. FWCU’s procurement process to secure partner vendors for hauling and line jetting in the FWCUGC, and any vendor registry criteria that may be applied, should emphasize quality criteria and experience and may include other criteria that the City deems important. Additionally, cooperative resource recovery is a concept that strives to establish local circular economies for the recovery and reuse of waste.

Waste recovery operations should support local economies and locally owned businesses, member FSEs and participating vendors alike.

2.2.1 Procurements The foundation of a successful FOG cooperative is the utility’s procurement of quality, low-cost FOG recovery services on behalf of community FSEs that include the terms of WPCP delivery. Because hydraulic or mechanical FSE line jetting is also a critical service that needs to be coordinated with extractor cleaning, line jetting also requires a procurement to establish accountability between the utility and service provider.

2.2.2 Extractor Cleaning and Maintenance, and Delivery to WPCP (FOG Recovery) A number of criteria are recommended for consideration in procuring FOG recovery services, including: ■

Verifiable experience providing extractor service to FSEs in Fort Wayne

■

Verifiable experience delivering FOG to the WPCP

■

Interest in participating in a program that emphasizes service quality as foundational to the businesses success and growth

FWCU is fortunate to have been transacting for several years with waste haulers who deliver FOG to the WPCP for codigestion. Only six haulers are approved to deliver FOG to the WPCP. Five companies are currently making deliveries, collectively accounting for all FWCU restaurant and non-restaurant FSE FOG delivered to the WPCP. Additionally, these 5 vendors deliver most of the additional non-industrial source liquid organics from unidentified FSEs outside of FWCU’s service area. Collectively, these vendors establish a target core for initial vendor engagement, not to the exclusion of other interested waste haulers.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Annual FOG Deliveries to WPCP (gal/yr) 400,000

300,000

200,000

100,000

J&S Liquid Waste

Lone Palms/ Three Sons

Mahoney

Perkins Septic

The Drainman

■ Fort Wayne FSEs ■ Out-of-Town FSEs

Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 15. Annual FOG Deliveries to WPCP

Two of these liquid waste haulers, J&S Liquid Waste and Lone Palms / Three Sons (Three Sons), are locally owned Fort Wayne businesses. Mahoney and The Drainman are both located in Indianapolis, and Perkins Sceptic in Hudson, all outside Allen County. Perkins provides service mostly to McDonalds restaurants inside and outside Fort Wayne under a corporate contract. The Drainman’s primary client is Kroger groceries. Mahoney services a significant number of restaurants with the FWCU service area but provides very little service to nonrestaurant FSEs such as nursing homes or hospitals. Three Sons and J&S account for 42% and 28% of all FWCU FSE FOG delivered to the WPCP for codigestion, respectively. Three Sons is also the largest provider of out-of-town nonindustrial FSE FOG to the WPCP, delivering over 91,000 of the 210,000 gallons delivered annually. Because of their experience servicing local FSEs, and their experience delivering FOG to the WPCP, these five companies should be engaged as potential participating vendors in the FWCUGC. Additionally, approval to deliver to the WPCP can justifiably be established as a criteria for evaluating FWCUGC haulers.

2.2.3 Line Jetters Some FOG recovery vendors also offer line jetting services. Others do not. Line jetters should be secured using a simple price and qualifications-based bid process after securing FOG recovery vendor(s). Because FOG vendors will be coordinating service times with line jetters, selected haulers may be able to provide advice and input on securing the best line jetters.

2.2.4 Requests for Proposal FWCU has made progress on a draft request for proposal (RFP) for both FOG recovery (waste hauling) and line jetting. This draft RFP was based on Tempe’s RFP language for quality criteria in hauling and jetting. It contains most of the service quality criteria that would be needed to evaluate potential vendors but should be separated into different procurements for hauling and line jetting.

2.2.5 Vendor Registries and/or Certifications The need for minor repairs to grease interceptors will most certainly be identified during FWCUGC-administered cleanings, as might other ancillary plumbing needs. Rather than conducting a separate procurement to secure these and any other supporting services,

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

a vendor registry process for minor repairs to grease interceptors and other plumbing would allow FWCU to direct FWCUGC member FSEs to quality-reviewed vendors. Currently, IPS’s FOG Compliance and Best Management Practices (Outreach) Manual lists haulers who are approved to discharge to the WPCP, and some available plumbers, but also clearly dismisses any endorsement. A vendor registry for minor repairs or other plumbing services would look very similar, but like the list of “approved” haulers, would involve some level of vetting for approval to be listed. Once the registry is established, any other supporting services could be added when identified as a need for member FSEs. A slight modification to the vendor registry concept could also be used to secure certified third-party extractor and plumbing inspectors, as discussed in Section 2.12.5 and recommended for consideration in Section 2.12.6.(2).

2.2.6 Recommendations Recommendations for securing FWCUGC and related services include: 1. First engage individually with experienced haulers of FOG to the WPCP to inform them about the benefits of participating in the program, and gauge their interest in participating 2. Finalize RFPs for FOG recovery and line jetting, and hold pre-bid meetings once RFPs are issued 3. Establish the structure for a vendor registry for ancillary services in the FWCUGC Terms of Enrollment and develop criteria for registration 4. Consider the use of a certification process for third-party extractor and plumbing inspections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.3 FSE Engagement and Stakeholder Process Deliberate and early inclusion of FSE stakeholders will contribute to a collaborative brand for the FWCUGC and will secure early stakeholder buy-in. However, stakeholder engagement for the FWCUGC is complicated by the need to modify FOG authorities, at the very least for cleaning frequency, and FWCU’s sewer rate adjustment process happening concurrent with implementation of the program. Engaging with FSEs solely to bring them good news about the voluntary FWCUGC has a very low risk of negative response from FSE stakeholders. However, the recommendations in this report include promulgating new extractor maintenance frequency requirements as critical to the success of the FWCU, and differential surcharges as strongly recommended. Without coordinating new regulatory revisions and rate adjustments, they may individually increase both transaction costs and sewer rates for some customers within the FSE user class, and collectively result in significant increases in total operating costs for FSEs. Utility changes that could increase operating costs for both FOG service and sewer rates risk strong opposition. As discussed in Section 2.13.3.4, the concurrent implementation of regulatory changes, the FWCUGC, and FWCU’s sewer rate adjustment process provides an opportunity to leverage their collective benefits and costs to bring bottom-line value to FSEs.

2.3.1 Bundled Stakeholder Engagement New FOG requirements, FSE sewer rates and the FWCUGC are very interrelated due to the need for new authorities to support the FWCUGC’s goals, the impact that both compliance and the FWCUGC have on utility costs of service, and the impact that new rate and regulatory costs collectively have on community businesses. Accordingly, if the timing can accommodate it, stakeholder engagement for FSEs is better approached as a bundled process for collective changes to FSE programs rather than separate outreach processes for each individual interrelated issue. Additionally, bringing forth these changes through separate stakeholder processes might be perceived to lack transparency regarding their collective financial impact on businesses. By bundling stakeholder processes, the summary message to FSE stakeholders for the collective roll-out of new requirements, rate adjustments, and the FWCUGC could be that it will 1) cost you more if you don’t support the community’s goals through effective FOG management, 2) cost you about the same if you effectively comply on your own, and 3) save you money if you comply by enrolling in the FWCUGC. Figure 26 in section 2.13.3.4. illustrates the opportunity to leverage rates, regulatory costs and FWCUGC benefits to lower FSE operating costs.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.3.2 Process Recommendations Detailed structure for a stakeholder process will depend on which issues are and aren’t bundled and the timing of rates and rule revisions. Helping coordinate a stakeholder process is within the Scope the current contract with BlueBridge, which is available to help coordinate any outreach strategy. Advisory and external opportunities for connecting with community FSEs include: ■ ■ ■ ■

Utility Advisory Group Greater Fort Wayne, Inc. Northeast Indiana Hospitality Association Indiana Restaurant and Lodging Association

It is worth noting that Greater Fort Wayne, Inc. established a restaurant/hotel subcommittee to work with the City during early implementation of, and modifications to, its FOG program in the 1990s. It is uncertain whether such a subcommittee still exists. Nonetheless, establishing upfront support for the collective changes and FSE impacts among industry

organizations and advocates will be invaluable to establishing FSE buy-in. Additionally, utilizing these organizations to establish connections with the most appropriate and influential representative Fort Wayne business owners will allow FWCU’s proposed changes to be introduced from a position of trust and transparency. Recommendations for engaging FSE stakeholders include: 1. Bundle FSE engagement processes for FWCUGC implementation, revisions to the R&R, and adoption of new high-strength sewer rates 2. Engage first with industry groups, including Greater Fort Wayne, Inc., the Northeast Indiana Hospitality Association, and the Indiana Restaurant and Lodging Association to establish up-front support for initiative that impact FSEs 3. Inform and secure approximately five high profile business advocates in local FSE ownership.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.4 FSE Marketing and Recruitment The projections in this report for FWCUGC growth, feedstock security, energy production, and collection system benefits all depend on FWCU’s ability to recruit approximately 865 FSEs into the cooperative within 10 years of implementation, or an average of 87 new members into the cooperative annually. Once rules, rates, and the advantages of the FWCUGC are structured to offer bottomline financial benefit to FSE’s, those benefits are the marketing points for recruitment. A coordinated rollout of rates, rules and the FWCUGC provides that utility with an opportunity to explain through its marketing efforts that FWCUGC membership is the best and most financially beneficial alternative for management of FOG. The benefits of cooperative resource recovery to FSEs are well established: ■

discounted bulk/wholesale pricing on FOG management services

■

service quality, enforced with haulers by the utility to the standards of local ordinances

■

reduced restaurant odors and plumbing backups

■

compliance assurance

■

peace-of-mind: the utility manages the process on their behalf, restaurateurs focus on their product - the dining experience

■

recognition / green marketing

Additionally, FWCU has the opportunity to structure rates and tipping fees to incentivize and reward FWCUGC membership.

2.4.1 Messaging and Marketing Materials FWCU has made great initial progress in developing marketing materials and messaging that inform FSEs regarding the benefits of FWCUGC enrollment. Specifically, a draft trifold marketing brochure was developed that highlights the general benefits of the FWCUGC. Once a specific program structure, terms of enrollment, and any related rates are finalized, this brochure can be finalized for distribution. Similar messaging should be developed for a FWCUGC website, which should also allow for online enrollment.

2.4.2 Recruitment Strategy Once the program is implemented, media, social media, emails and direct mailings should be utilized to broadcast information on the program as widely as possible. After the initial marketing blitz, there is one best strategy to engage directly with FSE owners regarding the program – face-to-face recruitment meetings with FSE decisionmakers by college interns and possibly other community volunteers. Tempe’s Grease Cooperative learned that restaurant and other FSE operators respond most readily to student interns who have a true personal interest and investment in the sustainability of the community’s infrastructure and energy systems. Additionally, recruiting FSEs concurrent with IPS inspection and enforcement activities risks branding the FWCUGC as being aligned with regulatory programs. This can create barriers to establishing trust and partnership. In Tempe, eleven student interns supported the program within its first five years by being the sole recruiters of new members. Using community members who are not permanent employees of the City will allow the FWCUGC to differentiate itself from the City’s traditional role as FSE regulator. Additionally, interns are able to support the program with technical research, program administration, measurement and analysis of performance metrics, vendor relations, and special research projects.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

BlueBridge met with representatives and gathered information from both Indiana University’s O’Neill School off Public and Environmental Affairs (O’Neill School) and Purdue University Fort Wayne’s (PFW) Office of Academic Internships, Cooperative Education and Service Learning to better understand potential partnerships with those programs to support the FWCUGC’s growth and success. BlueBridge estimates that FWCU could utilize three to four part-time or two fulltime interns to support FWCUGC recruitment and program development. 2.4.2.1. Indiana University (IU) The O’Neill School is recognized nationally as a top school for the study of Public Policy, particularly as it relates to sustainability and the environment. Accordingly, engaging IU students with interests and academic tracks such as innovative local governance, sustainable infrastructure and energy, small business sustainability creates a great opportunity, particularly when implementation issues arise that require significant research. BlueBridge held three workshops in Bloomington with O’Neill faculty in students in April, 2019, and participants expressed a strong interest in getting involved with the implementation of the FWCUGC. O’Neill provides a great opportunity to engage students in this innovative concept. However, the distance between Fort Wayne and Bloomington likely limits face-to-face recruitment roles to Summer internships for IU students. 2.4.2.2 Purdue University Fort Wayne (PFW) PFW offers several academic programs with designed curricula that provide an opportunity for alignment with the principles of the FWCUGC. Community sustainability ties in to several PFW academic programs, including Business Economics and Public Policy, Interpersonal and Organizational Communication, Hospitality and Tourism, Organizational Leadership, and most notably, PFW’s undergraduate and graduate programs in Public Policy. Students from any of these

areas could find applied linkages between academic tracks and practical experience in the FWCUGC. Additionally, PFW is located just East of the North Pilot area, which is recommended for pilot program implementation. PFW has two structured internship programs that are perfectly designed to provide interns for the FWCUGC. The Department of Public Policy has an internship program that could provide part-time support throughout the school year with students specializing in Public Policy. The other very notable program administered by PFW’s Office of Academic Internships, Cooperative Education, and Service Learning is the Cooperative Education Program. This program distinguishes itself from traditional internships by offering multi-term work assignments (18-24 months), higher levels of responsibility, and either part time or fulltime employment. This program is designed to immerse interns in the full experience of professional employment.

2.4.3 Recommendations PFW provides an opportunity to integrate local early-stage professionals into FWCUGC’s organic community partnership. Interns and Cooperative Education participants are available to conduct recruitment activities and advocacy year-round. Additionally, IU provides a great opportunity to engage students for Summer internships or recent graduate internships. 1. Continue to engage with both PFW and IU in preparation for hiring interns to perform the bulk of recruitment activities. 2. Interns can be utilized immediately for field and desktop data collection, and can presumably begin recruiting FSEs in the Spring of 2020 3. Continue to develop marketing materials inprogress for distribution during recruitment

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.5 Data Collection and Analysis Task 1 of the strategic planning process involved the collection and analysis of data from multiple sources that served multiple purposes. The goal for available data is to establish a utility “footprint” comprised of metrics that will allow FWCU to establish data-driven goals for the program, and to identify data-driven implementation strategies that will best allow FWCU to achieve strategic goals. The majority of quantitative data and information used in this analysis is obtained and consolidated from internal Fort Wayne data systems. Other industry data and analytical tools and systems from the Water Environment Research Foundation, U.S. EPA, other sewer utilities, and other sources, are used to support assumptions where FWCU-specific data is unavailable, and to calculate projections and identify best practices. Generally, FWCU maintains excellent systems for data to inform and support implementation of programs like the FWCUGC, particularly its collection system asset management and GIS systems, and the hauled waste module in Linko. Figure 2 summarizes primarily quantitative but some qualitative data and information sources, inputs established in Task 1 of the BlueBridge Scope of Basic Consulting Services (Scope) and describes output categories that inform the findings and recommendations described in this report. Some data sources and inputs inform multiple analyses and outputs, and in some cases more than one data source for the same input are consulted to validate sources, e.g., Allen County Health Department records and FWCU Linko. Much of the FSE raw data is consolidated into sortable Excel spreadsheets to support projections and other findings. Analytical tools utilized to calculate, support, and/or validate projections from raw data included FOG production calculations publicly available from IW Consulting Services and Schier Products’ Grease Monkey production calculator; Clean Water Services’ 2011 Brown

Grease Supply Study prepared by Kennedy/ Jenks Consulting; assumptions utilized in U.S. EPA’s Codigestion Economic Analysis Tool (C0EAT); FWCU’s biogas and cogeneration cocktail calculator; Water Environment Research Foundation’s (WERF) 2008 Assessment of Grease Interceptor Performance; and WERF’s 2010 Report on Codigestion of Organic Waste Products with Wastewater Solids. In addition to the data sources described in Figure 2, a number of interviews and field observations were conducted to support recommended best practices for implementation of the FWCUGC. Field observation of FWCU sampling and inspection processes were observed over a one-day period along with interviews of FWCUs FOG Program Coordinator to identify time allotments to various sampling and inspection components and opportunities for process improvements. Internship and Cooperative Education program coordinators with Indiana University’s O’Neill School of Public and Environmental Affairs (IU) and with Purdue University Fort Wayne (PFW) were interviewed regarding utilization of internships and interns to support enrollment and member engagement activities of the FWCUGC. Pretreatment and Financial staff from the cities of Portland, OR, Nashville, TN, and Tacoma, WA were interviewed regarding their use of rate structures and incentives to support sustainable FOG practices and resource recovery. One Fort Wayne-based grease hauler was contacted to identify preliminary interest in participating in the FWCUGC, and one Phoenix Arizona based FOG hauler that is the primary provider for the Tempe, Arizona Grease Cooperative was interviewed to identify challenges and best practices for engaging and securing hauler services. One industry software provider was consulted regarding compatibility of industry FOG data management software systems with administration of resource recovery programs. Additionally, the functionality of four different software systems were compared using product descriptions and online tutorials.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

BLOCKAGES/ SSOS

HOT SPOTS

DEGREASING UNIT COST

DEGREASING FREQUENCY

DEGREASING LOCATION

TRUNK LINE LOCATION

CMMS FW GIS

AUTHORITIES & IPS OUTCOMES

STAFF ALLOCATION % TO FOG

IPS PROGRAM COSTS

FWCU BUDGET/ FINANCIALS

SAMPLING PROCEDURES

WASTE MANIFESTS

FSE ACTIONS SUMMARY

OUTREACH BINDER

ENFORCEMENT RESPONSE PLAN

FWCU IPS SOPS

PILOT PROGRAM AREA(S) ANALYSIS

DESIGN STANDARDS (SA6)

RULES & REGS SECTIONS 5-9

ORDINANCE 51.069-51.074 SEWER RATES

ORDINANCE 51.030-51.040

FWCU ORDINANCE & RULES

PROJECTED FWCUGC COSTS & BENEFITS

UTILITY COST/ KWH

COGEN (KWH)

BIOGAS RECOVERY

ENERGY CONSUMPTION

FWCU WPCP ENERGY DATA

RECOMMENDATIONS/IMPLEMENTATION STRATEGY

WPCP ENERGY TRENDS & PROJECTIONS

ANALYTICS

REMEDIES

CIVIL PENALTIES

VIOLATION(S)

SAMPLE RESULT(S)

#SAMPLES COLLECTED

SAMPLE DATE(S)

IPS SAMPLING (2018)

HAULED WASTE TRENDS & PROJECTIONS

HAULER LOCATION

HAULER

WASTE TYPE

DELIVERY VOLUME (FSE)

DELIVERY DATE

ORIGIN FSE

LINKO HAULED WASTE

INPUTS

FSE ASSESSMENT & FEEDSTOCK PROJECTIONS

TRUNK LINE

CNTY CLASS (1,2,3,4(

STATUS (ACTIVE/ INACTIVE)

FACILITY

ALLEN COUNTY HEALTH

CS DEGREASING PROGRAM FINDINGS

FSE COMPLIANCE RATE

SUBTYPE (E.G. FAST)

BLDG TYPE

DATE LAST INSPECTION

EXTRACTOR LOCATION

EXTRACTOR TYPE/SIZE

FSE TYPE

LOCATION

FACILITY

LINKO FOG

DATA INPUTS, OUTPUTS, FINDINGS & PROJECTIONS SOURCES FINDINGS & PROJECTIONS

Figure 16. Data Inputs, Outputs, Findings & Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.5.1 Data Gaps and Limitations Some data gaps exist within Linko due to resource constraints resulting in only partial population of data systems, particularly sitespecific FSE information that could be valuable for strategic targeting of larger feedstock sources and deploying strategies for enrollment and incentives for FWCUGC participation. Assumptions have to made where FSE-specific information was not available in FWCU systems. Any assumptions utilized are collected from reliable industry sources and are explained during each component of analysis. Other gaps exist within internal systems, partly due to system structure, and partly due to less robust use of some of the system attributes, particularly within Linko modules. Opportunities identified for the retrieval and management of data that would be particularly helpful for establishing and tracking FWCU goals and outcomes are discussed throughout this report, and summarized in Section 2.15.

It is important to note that data and information related to FSEs and FOG is variable, and any snapshot of FOG and FSE data, for example number of FSEs currently operating in Fort Wayne, cannot claim precision over time, even throughout the duration of this data analysis, due to openings, closures, and changes in practices. Conversely, a large data set for metrics that are widely variable, for example over 2,000 facilities with daily openings and closures, can be expected to contain a constantly varying but relatively marginal level of data error. Snapshots of data analyzed for this report are intended to be representative of reasonably typical conditions within FWCUâ&#x20AC;&#x2122;s system and are believed to be reliable for projections and planning purposes.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.6 Food Service Establishment (FSE) Assessment

■

FWCU utilizes Linko’s CTS System to track information related to regulated commercial food businesses (Linko FOG) and for FOG delivered to the Water Pollution Control Plant (WPCP) for codigestion (Linko HW). Linko systems contain information for roughly 2,061 facilities identified as “active”. However, this inventory represents a wide variety of facility classifications and types, some of which are not food-based and provide no opportunity for FOG recovery, and others that also are not projected to be reliable sources of any FOG resulting from implementation of the FWCUGC due to the nature or operation of the business or institution. The first objective in analyzing FSE data is to identify these facilities.

■

2.6.1 Non-Contributors Among the 2,061 businesses populated in Linko, 657, or 32%, are estimated not to be reliable sources for recovery of any FOG resulting from implementation of the FWCUGC. Most of these (563) are businesses and institutions that only sell pre-packaged or pre-prepared food as secondary to their primary service, or businesses that have no food-based component whatsoever. These facilities include: ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■

Insurance firms construction companies excavators auto shops/service facilities garages funeral homes car washes laundromats gyms medical supply companies waste disposal sites non-resident health and rehab centers child & family services facilities landscaping companies sceptic haulers municipal lift stations logistics companies

■

■ ■

■

■ ■

small industrial companies equipment rental facilities plumbing supply businesses small conference centers without food service entertainment venues without kitchens or snack bars gas stations, groceries, convenience stores, and general stores known by FWCU to sell only prepackaged food or that have been inspected and determined not to not require an interceptor salons serving wine and minimal prepared foods pre-schools elementary and middle schools with no onsite food prep non-resident churches without k-12 schools hotels and motels w/ no restaurant, room service, or food preparation

Other assumed non-contributors include 51 food trucks, 28 businesses that are closed, and 15 large industrial sources that are significant feedstock contributors but are presumed to be categorized and managed under FWCU’s Resource Recovery Phase II – Liquid Organic Waste Procurement and Management Program.

2.6.2 FSE Data Gaps and Assumptions Site specific information on extractor type, size and location is unrecorded for approximately 489, or 35%, of the remaining 1,404 FSEs that are projected to have potential to generate FOG for the FWCUGC. Collecting and recording information for these facilities during pilot program implementation will be critical to establishing more accurate projections of FOG recovery. Pending collection of this information, 50% are assumed to have outdoor 1,000 gallon grease interceptors, and 50% are assumed to have indoor grease traps. A roughly 50/50 split between interceptors and traps is typical among urban utilities and is consistent with data for Fort Wayne’s known FSEs, 49% of which have outdoor interceptors and 51% of which have indoor traps.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.6.3 Potential Contributors

2.6.4 Recommendations

Filtering of low to no potential FSEs and the determination of assumptions for those with unknown extractors leads to the establishment of 12 categories of FSEs listed in Table 1 within which each of the potential FOG contributing FSEs are categorized for the purpose of projecting FOG recovery.

1. Collecting site-specific information for all FSEâ&#x20AC;&#x2122;s without extractor information populated in FWCU systems is critical to establishing reliable projections and data-driven goals for FOG recovery in the FWCUGC.

CATEGORY

NUMBER OF FSES

Restaurants with Outdoor Grease Interceptors

269

Restaurants with Indoor Grease Traps

329

Restaurants with Assumed Outdoor Grease Interceptors

146

Restaurants with Assumed Indoor Grease Traps

146

Non-Restaurant FSEs with Outdoor Grease Interceptors

156

Non-Restaurant FSEs with Indoor Grease Traps

116

Non-Restaurant FSEs with Assumed Outdoor Grease Interceptors

Non-Restaurant FSEs with Assumed Indoor Grease Traps

Schools with Outdoor Grease Interceptors

Schools with Indoor Grease Traps

Schools with Assumed Outdoor Grease Interceptors

Schools with Assumed Indoor Grease Traps

Total

2. Additionally, conducting assessments to determine which sites would be suitable for retrofits for FSEs with indoor traps to outdoor locations would allow for more defensible projections of resource recovery potential for those FSEs.

1,404

Table 1. FSEs with Recoverable FOG Production Volumes

Assumptions made for each of these categories to establish projections of FOG recovery are explained in Section 2.7.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.7 FOG Recovery Analysis and Projections The 12 categories of FSEs distinguished in Section 2.6.3, can be consolidated into four groupings for which common FOG recovery assumptions are utilized.

2.7.1 Group 1: Restaurants and NonRestaurant FSEs with Known Outdoor Grease Interceptors The FSEs in this grouping of approximately 425 Fort Wayne businesses are known to have outdoor grease interceptors of known capacity. Three hundred seventy-four (374) interceptors have 1,000 gallon capacities, 11 have capacities ranging from 200-800 gallons, and 40 have capacities between 1,200 and 3,500 gallons. This grouping represents the largest and most immediately available collective source of FOG and should be targeted as the highest priority for FWCUGC recruitment. Schools are excluded from this group due to less assumed FOG production. Based on averages for 229 of the FSEs in this category for which data on service frequency is populated in the hauled waste module of Linko, interceptors for FSEs in this group are serviced (pumped) an average of 2.5 times per year. Manufacturers specifications for all gravity and hydromechanical interceptors provide for servicing at least quarterly to prevent full bypass of FOG, and even more frequently for higher FOG producers, meaning that on average, 100% of FOG is likely bypassing from these businesses to FWCU sewers for 4.5 months out of each year. Estimated bypass and resulting costs to the utility are discussed in Sections 2.8 and 2.9. Two hundred twenty-nine (229) of the 425 restaurants in this category were sources for some delivery of FOG to the WPCP, but not necessarily all FOG collected. Baseline (current) FOG deliveries from this category to the WPCP are approximately 672,860 gallons annually. Total potential for recoverable FOG for this category is 1.87 million gallons of

FOG annually based on interceptor capacities and quarterly pump-outs, or an additional 1.2 million more gallons of FOG above baseline deliveries annually resulting from implementation of the FWCUGC. Assumptions made to calculate projected FOG recovery in this grouping include: ■

Baseline FOG delivery volumes for this group of FSEs will be secured long-term

■

Cleaning frequencies for these FSEs will increase to quarterly (assumes implementation of changes to General Rules and Regulations recommended in Section 2.11)

■

50% of total remaining recoverable FOG (minus baseline quantities) will be recovered within the first five years of implementation of the FWCUGC through linear program growth, and 85% will be recovered after 10 years of implementation

Growth projections assume implementation of recommended incentives and recruitment strategies.

Figure 17. Fort Wayne FSEs with Outdoor Interceptors. Restaurants with outdoor interceptors are plotted with blue dots and non-restaurant FSEs plotted in purple.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Figure 18. Outdoor Interceptor Configuration. Outdoor interceptors have much higher capacities and can typically be accessed from the FSE parking lot or drive-through lane but must be serviced when filled to capacity to prevent bypass.

2.7.2 Group 2: Restaurants and Non-Restaurant FSEs With Assumed Outdoor Grease Interceptors This group is comprised of the FSEs believed to be potential FOG contributors, but without documented extractor information, and for which 50%, or 227 FSEs, are assumed to have outdoor interceptors pending field verification. Projections for this group have a far lower degree of confidence, reflecting the importance of collecting site-specific information for the 489 (including schools) FSEs with unknown extractor type and location. Nonetheless, the group has the potential to yield 906,000 gallons of FOG annually if assumptions hold true, making it second in FOG recovery potential only to Group 1. Assumptions for this group include: ■

All FSEs assumed to have outdoor interceptors have one with 1,000 gallon capacity

■

Interceptors will require service on a quarterly basis

■

FOG from 50% of the 227 FSEs can be captured through FWCUGC enrollment over the first 5 years of the program; FOG from 85% can be captured after 10 years of implementation

The FOG recovery potential for this group makes data collection for FSEs with unknown extractor information and moving those found

to have outdoor interceptors into Group 1, among the highest priority tasks in the FWCUGC implementation plan.

2.7.3 Group 3: Restaurants and Non-Restaurant FSEs With Known or Assumed Indoor Grease Traps Approximately 426 of the 671 FSEs that make up this group are known to have indoor grease traps, with a small number (19) either having no extractor or sharing an extractor. The remaining 226 FSEs in this grouping make up the second half of FSEs with unknown extractors, and for which 50% are assumed to be indoor traps. The baseline potential for FOG yield is marginal in this group because indoor trap capacities range from 20 to 50 gallons, compared to 1,000 gallon-plus capacities of outdoor interceptors. Growth projections for this group assume no recoverable FOG from indoor traps, but a modest transition to outdoor interceptors for 267 of these FSEs that are known or assumed to be stand-alone buildings over time using recommended incentives to retrofit to outdoor interceptors. This can best be achieved during accompanying remodels, changes in ownership, or when indoor traps fail and require replacement. Projections for this group estimate a maximum potential of 267,000 gallons of FOG recovery annually, achievable with linear growth between year three and year 10 after incentives begin to take effect. These

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

1) Known Outdoor Extractor

2) Assumed Outdoor Extractor

3) Outdoor Retrofit

117,300

103,643

71,775

26,250

267,000

80,100

906,000

453,000 0

672,860

770,100

1,870,850

1,271,855

1,691,152

Baseline & Projected FOG Recovery by Source (gal/an)

4) Schools

■ Current ■ 5 Year ■ 10 Year ■ Max Potential

Figure 19. Baseline & Projected FOG Recovery by Source

projections result in this group having the third greatest FOG recovery potential, but growth to maximum potential will take many years and will require significant policy changes. Assumptions for this grouping include: ■

Retrofit potential for 100% of facilities in stand-alone buildings

■

No retrofit or FOG potential for facilities in large or small multi-tenant buildings and where FSEs are located within non-FSEs

■

Linear rate of retrofit between year three and 10 with high capacity, but smaller volume, hydromechanical grease interceptors (HCGIs), resulting in 250 gallons per pump out on average

Note that some small multi-tenant (strip mall) locations may have the potential for retrofit, and policies are being recommended to encourage retrofits in these facilities, but no FOG recovery is being assumed due to the uncertainties of site-specific conditions.

2.7.4 Group 4: Schools Thirty-four (34) of the potential contributors in this grouping have known outdoor interceptors, and 18 are assumed to have 1,000 gallon interceptors. The remaining 29 FSEs in this grouping are known or assumed to have indoor traps. Schools are a lesser source of FOG than other FSEs because they are intermittently closed (Summers, weekends, holidays, etc.). Accordingly, outdoor interceptors at schools are projected to collectively be a securable source of feedstock, but because of less production at schools and so not to impose unreasonable service requirements and costs, projections for this grouping assume less recovery per unit than other FSEs. Thirteen of the 34 schools with known outdoor interceptors are currently delivering 26,250 gallons per year of FOG to the WPCP as a baseline. Total potential for recoverable FOG for this category is 117,300 gallons of FOG annually based on interceptor capacities and semi-annual pump-outs. Assumptions for FOG production and feedstock growth for Fort Wayne’s schools include:

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

■

Baseline deliveries will be secured long-term

2.7.6 Recommendations

■

All schools were assumed to only require service / pump-outs twice annually

■

50% of assumed FOG production from schools can be captured through FWCUGC enrollment over the program’s first 5 years; 85% can be recovered after 10 years of implementation

With a focus on securing FOG from FSEs with outdoor extractors, the most critical steps to achieving projected rates of FOG recovery are:

2.7.5 Feedstock Projections

1. Promulgation and effective enforcement of requirements for the frequency and procedures for cleaning extractors 2. Collecting FSE-specific information for all FSEs without known extractor information

Implementation of the FWCUGC and supporting policy changes is expected to result in the recovery of close to 1.9 million gallons of FOG annually within five years of implementation, and 2.8 million gallons after 10 years. This will add approximately 2.1 million gallons of FOG annually to FWCU’s feedstock portfolio in year 10, or almost three additional tanker trucks per day with a 3,000 gallon capacity, excluding weekends and holidays. The largest and most immediate sources of added feedstock are FSEs with outdoor grease interceptors.

FWCUGC FOG Recovery Projections (gal/an) 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,000,000 500,000 0

Current

5 Year

10 Year

Max Potential

■ Known Outdoor Extractor ■ Assumed Outdoor Extractor ■ Outdoor Retrofit ■ Schools

Assumed Outdoor Extr actor

Outdoor Retrofit

Figure 20. FWCUGC FOG Recovery Projections

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.8 FOG Impacts on FWCU Sewage Collection System 2.8.1 Hydraulic Degreasing FWCU has identified uncontrolled FOG from restaurants and other FSEs as the root cause for grease build up and blockage in 991,000 feet of pipe reach, or 74%, of the city’s annual preventative degreasing lengths. The remaining 379,000 feet of degreasing length is attributable mostly to grease in discharges from multifamily housing. Degreasing frequencies for specific pipe reaches range from once every 14 days to every other year. Annually, FWCU conducts hydraulic degreasing on 188 miles of sewer line due to restaurant FOG, at a cost of over $287,000 to the utility. As a result of FWCU’s preventative degreasing program, restaurant-related grease blockages have resulted in only two back-ups in the last three years, limiting costs for response and mitigation to $9,901.

2.8.2 Problem Areas FWCU’s Asset Management team identified six area “hot spots” or problem areas within Fort Wayne’s collection system that experience a disproportionate build-up of grease and require more time and resources to manage. One hot spot is located within a strictly residential area. The remaining five are in FSE-dense areas. These areas were identified as: ■

The area surrounding Coldwater Crossing (West side of Coldwater Rd from W. Washington Center Rd to W Coliseum Blvd W)

■

Parkwest Shopping Center (W. Jefferson Blvd at Illinois Rd)

■

Glenbrook Mall area (south side of W. Coliseum Blvd W from Lima Rd to Coldwater Rd)

■

Georgetown area (NE and SE corners of Maplecrest Rd and E. State Blvd)

■

Waynedale area (Lower Huntington Rd and Old Trail Rd)

2.8.3 Degreasing Clusters Figure 21 Illustrates degreasing reaches displayed in FWCU’s GIS system in red, and five areas identified by FWCU’s Asset Management team as system “hot spots” in areas with restaurants and FSEs in blue. Neighborhoods in the North Central section of the map, particularly the Coldwater Crossing and Glenbrook Mall areas are disproportionately dense.

2.8.4 2013 Grease Interceptor Cleaning Frequency Study FWCU’s Water Pollution Control Maintenance Department (WPCM) conducted a short-term study in 2013 to assess the impacts of different grease interceptor cleaning frequencies at a number of restaurants along East Coliseum Blvd and at the corner of Stellhorn and Maplecrest Roads. Findings of the study concluded that: 1. Regardless of increased interceptor cleaning frequency, a small amount of grease build-up (5-10% of pipe capacity) was observed in all areas; 2. Grease build-up rate could not be differentiated between increased frequency and lesser frequency cleaning periods, implying that a greater interceptor cleaning frequency did not provide substantial additional protection for the collection system. BlueBridge notes that conclusion (1) can be explained based on typical efficiencies of gravity grease interceptor - the type in operation at all five restaurants at the time of the study - of approximately 78%, meaning that even if they are not filled to capacity, approximately 22% of FOG is expected to be bypassing to a collection system.3 The finding (2) that FOG build-up was not substantially different during the higher and lower cleaning frequencies of the study can be explained by the duration of observation when cleaning frequency was returned to “normal”, which was two months after interceptor

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Figure 21. Degreasing Lines with Identified “Hot Spots”. Degreasing lines are represented in red with identified commercial “hot spots” in blue.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2013 Frequency Study - Baseline

2013 Frequency Study – Increased frequency & grease build-up

cleaning. A gravity grease interceptor typically operates for up to 90 days, or three months, before reaching capacity failure, depending on the type of restaurant and sales volume. BlueBridge believes that if the period of observation was extended to beyond 90 days, televised lines would reveal greater build-up compared with observations during increased cleaning frequencies and recommends that a follow-up study be implemented during the pilot FWCUGC.

2.8.5 Projected Sewer Operation and Maintenance Reductions There are no available published studies designed to assess the impact of proper management of FOG at the source on collection system cleaning frequencies or costs. Additionally, FWCU’s 2013 study does not simulate the changes recommended in this report to effectively manage and recover FOG. Accordingly, and pending implementation of additional studies on the collection system impacts of modifications in cleaning frequency, the following assumptions were used to calculate estimated reductions in degreasing frequency and cost resulting from implementation of the FWCUGC: ■

Twenty-two percent (22%) of FOG produced at FSEs would bypass regardless of cleaning frequency (WERF, 2008)

■

Interceptor cleaning frequencies would be assumed to increase from 2.5 times to 4 times annually, and trap cleanings increased proportionally (60% increase in cleaning frequency) resulting in extractor bypass reduction of 37.5% at participating FSEs

2013 Frequency Study – after two months of lesser frequency

■

Cleaning frequencies would increase over time proportional to projected growth in FSE participation in the FWCUGC (50% by year 5; 85% by year 10)

■

Restaurant-related degreasing frequencies would be reduced proportional to the projected amount of FOG that could be removed from the system as a result of implementing the Part II recommendations.

Based on these assumptions, preventative degreasing could be decreased by 15%, or 145,000 feet/year, by year 5, and 25%, or 246,000 feet, by year 10 of the FWCUGC. Based on a $0.29 per foot cost of degreasing, this would amount to a savings of approximately $42,000 annually by year 5, and $71,000 annually by year 10.

2.8.6 Recommendations To best assess the collection system impacts of increased FOG extraction resulting from changes to cleaning frequency requirements and implementation of the FWCUGC, a new collection system study should be coordinated with FWCU’s Asset Management team during pilot program implementation. This study should be designed to differentiate the impacts of cleaning interceptors at different frequencies using FSE-specific FOG production criteria and manufacturers’ specifications for cleaning frequency, and then at longer periods. Results from this study can be used to more accurately assess the benefits of correct extractor cleaning methods and frequency, to support regulatory changes in frequency, and to assess any cost-ofservice impacts that could be used to support incentives for effective FOG recovery and FWCUGC membership.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Business-specific data was unavailable for FWCU FSEs regarding sales volume (i.e., meals served), and FSE-specific extractor cleaning intervals. While FSE business volume can be calculated using other metrics, such as water consumption or gross sales revenue, such data was also not immediately available for this analysis. Without this information, bypass estimates were calculated using the following assumptions:

2.9 FOG Loading and Treatment Estimates The organic load of FOG on wastewater treatment plants, measured by chemical oxygen demand (COD), is difficult to measure using collection system water quality sampling due to variations and dilution from other sources. This section uses a FOG production-based mass balance approach as the best information available to calculate how much COD is being treated as a result of FSE FOG bypasses into FWCU’s collection system, and what the costs of treating avoidable FOG-related COD are to the utility. Bypass resulting from limitations in extractor efficiency, as explained in Section 2.8, is not included in this loading and treatment analysis because it is not preventable by implementing the regulatory changes in extractor cleaning frequency and practice that are recommended in this report.

2.9.1 FOG Bypass Estimates Ideally, loading could be calculated using information regarding type of FSE and sales volume, type and size of interceptor, and service frequency. These could collectively be used to calculate actual FOG entering extractors and FOG bypassing to the collection using available calculators for FSE-specific extractor sizing: FOG production factor based on FSE type

# meals served between cleaning intervals

■

FOG production for FWCU’s 1,323 FSEs with significant FOG production potential (schools were excluded due to lower FOG production potential and variability) was assumed based on industry averages for all FSEs

■

Average FOG bypass per FSE resulting from inadequate cleaning frequency was assumed to be 37.5% based on observations of average extractor cleaning frequency

■

Data from the Water Environment Research Foundation’s 2010 Report on Codigestion of Organic Waste Products with Wastewater Solids was used to calculate COD loading per gallon of FOG by-passed4

extractor FOG capacity

FOG Bypass

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Based on the assumptions described above, FOG bypass into FWCU’s system is estimated to be 1.98 million gallons per year due solely to inadequate cleaning frequencies. Using 2010 WERF Report data for raw grease trap waste at 10% solids, these bypasses require treatment of 7.3 million pounds of COD annually, or 5,495 pounds of COD per FOG-producing FSE per year. The cost of this treatment is conservatively estimated to be approximately $423,000 annually for FWCU, or more than $300 per FSE based on FWCU’s strength of waste surcharge calculation using 50% of COD mass to calculate a COD-equivalent BOD surcharge as provided in §51.075(B)(1) and (2). Note, again, that this is solely due to inadequate cleaning frequencies. Bypasses based on extractor efficiency add significantly to the cost of COD loading per FSE.

2.9.2 Recommendations Collecting and maintaining FSE-specific data on sales/service volume, water consumption, and extractor type/size is recommended to support more accurate FWCU-specific projections of FOG bypass and the promulgation of updated extractor sizing criteria. FSE-specific loading information could also be used to establish more defensible production-based sewer rate surcharges to better reflect and more equitably distribute FSE costs of service as described in Section 2.13.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Monthly WPCP Energy Portfolio 3,000,000 2,500,000 2,000,000 1,500,000

Renewable

1,000,000

■ Purchased KWh

May-19

Jan-19

Mar-19

Nov-18

Sep-18

Jul-18

May-18

Mar-18

Jan-18

Sep-17

Nov-17

Jul-17

May-17

Jan-17

Nov-16

Sep-16

Jul-16

May-16

Mar-16

Jan-16

Nov-15

Mar-17

Non-Renewable

500,000

■ Cogen KWh

Figure 22. Monthly WPCP Energy Portfolio

2.10 Energy Production Trends and Projections Since implementing the energy recovery program at the WPCP in 2015, FWCU has generated an average of 31% of the WPCP’s monthly energy demand from biogas recovery and cogeneration for combined heat and power (CHP). The utility’s goal is to increase renewable energy production to 100% of the facility’s demand within the next 10 years. To meet this goal, the WPCP must generate an average of 1,222,000 renewable kilowatt hours (KWh) monthly in addition to the current average of 550,000 KWh. That amounts to a 122% net increase in energy recovery within 10 years.

2.10.1 FWCUGC Projection Methodology Feedstock projections established in Section 2.7 were utilized to estimate the projected contribution of FWCUGC-secured FOG feedstocks toward meeting FWCU’s strategic goal of energy neutrality at the WPCP after five and ten years of implementation. Several methodologies were utilized to cross validate energy production projections, including: ■

BlueBridge’s Bridgebuilder Consolidated Methodology

■

Cocktail Calculator provided by FWCU Energy Engineering & Sustainability Services

■

U.S. EPA’s Codigestion Economic Analysis Tool (Co-EAT)5

■

Tempe, Arizona’s calculation for costs and benefits of energy potential for the Tempe Grease Cooperative

■

WERF’s 2010 Report on Codigestion of Organic Waste Products with Wastewater Solids

The Bridgebuilder consolidated methodology is a high-level simplification of several industry calculators that uses gallons of raw FOG, a conversion to dry solids, industry information on energy content per pound of FOG measured in btu, and an assumption of generator efficiency. Projections in this section are intended to provide a general sense of energy potential. Detailed projections are premature until FWCU evaluates technology modifications to expand its resource recovery operation. FWCU has communicated its intent to explore other biogas recovery and/or cogeneration technologies, and possibly utilize favorable markets for the sale of renewable biogas and associated market credits (RINs) after implementation of the FWCUGC

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

and the parallel Phase II – Liquid Organic Waste program. Different technologies could result in significantly different energy potential and revenue for the utility. For example, the current cogeneration operation loses an estimated 62% of energy potential due to inefficiencies associated with converting biogas into electrical energy.

2.10.2 FWCUGC Energy Recovery Projections

2.10.3 Recommendations Although outside of the scope of the FWCUGC, energy recovery of biogas for compression and use on site, in City or regional compressed natural gas (CNG) vehicles, and/or for sale on renewable biogas markets after further processing, could yield far greater energy recovery and value for FWCU, and should be considered.

Projections in this section reflect best available information and are fairly consistent with similar projections using FWCU’s Cocktail Calculator. Based on FWCUGC growth projections established in Sections 2.6 and 2.7 and energy conversion efficiencies consistent with current processes at the WPCP, estimated energy production is expected to increase by approximately 80,000 KWh per month by year five of the FWCUGC, and 144,500 KWh per month by year 10. Two other calculators used to validate these findings established projections of 122,000 KWh per month and 164,000 KWh per month at year ten, respectively. Based on FWCU’s current electrical rate of $0.0712 per KWh, energy recovery from the FWCUGC will save FWCU $69,000 per year on purchased energy by year 5, and $123,500 per year by year 10. The year 10 projection represents a 26% increase in renewable energy production over current levels and delivers approximately 12% of the additional renewable energy needed to achieve FWCU’s goal of energy neutrality at the WPCP. These projections only include new feedstock sources within FWCU’s sewer service areas, and not potential increases in feedstocks available from out of town FSEs.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.11 FOG Authorities FWCU authorities establishing FSE responsibilities and requirements for preventing FOG interference with the public sewer system include: ■

Fort Wayne, IN Code of Ordinances, Chapter 51: Sewers (Sewer Use Ordinance, or SUO)

■

FWCU’s General Rules and Regulations (R&R) established pursuant to authorities granted in SUO §51.033(B), §51.038 and §51.110

■

City Utilities Design Standards Manual, Sanitary (SA), Chapter 6: Building Sewer and Appurtenance Design (SA6)

Based on discussions with FWCU staff, a number of criteria were highlighted as being important to the effective administration of FWCU’s FOG program and the FWCUGC. These criteria include but are not limited to the following: ■

Extractors located outside of buildings are more desirable for inspection and service access

■

Extractors that remove and recover more FOG through correct sizing and higher removal efficiency are more desirable for collection system and resource recovery goals

■

Authorities should achieve their intended goals of preventing FOG bypass and enhancing resource recovery

■

Requirements should be reasonable, defensible and enforceable, and should not create unnecessary costs for small businesses

■

The FWCUGC terms of enrollment should be clearly established in FOG authorities

2.11.1 Extractors – Requirement to Install FWCU’s SUO, General Rules and Regulations, and Design Standards Manual (SA6) collectively establish broad discretionary authority for FWCU to require the installation of a grease extractor when it “determines that

interceptors or traps are needed to protect the City’s sewerage collection system or the City’s treatment plant6” Despite this authority, SA6 categorically established the extractor requirement as mandatory in high sewer maintenance areas, implying a lesser mandate where collection system problems do not occur.7 It is important to note that SUO §51.038 clearly establishes protection of the treatment plant, as well as the collection system, as the intent of grease interceptor installation and maintenance requirements.

2.11.2 Extractor Location SA6 requires all grease extractors to be located outside of buildings. However, this requirement is only applicable and enforceable for new construction or significant rebuilds at the time of plan review and construction. FSEs with indoor traps are effectively “grandfathered” out of the outdoor requirement until and unless significant remodeling occurs. As a result, 426 FSEs with known extractors remain indoors and projections estimate that more than 670 Fort Wayne FSEs could have indoor traps.

2.11.3 Extractor Type and Capacity SA6 requires a minimum capacity of 1,000 gallons for extractors. Many variables affect extractor performance, including type of restaurant, flow velocity, residence time, etc. While capacity can reduce frequency between servicing, a 1,000 gallon requirement may preclude the installation of newer more efficient technologies, such as high capacity hydromechanical grease interceptors (HCGIs). HCGIs can operate at a much greater FOG removal efficiency of between 95 and 99% FOG removal using diffusers to lower velocity and create laminar flow, compared to removal efficiencies of approximately 78% for standard 1,000 gallon GGIs at a 100 gallon per minute (gpm) flow rate.8,9 HCGIs may be installed and operated at a cost comparable to GGIs for the FSE, and are made of thermoplastic materials that last longer in high pH environments common in grease extractors. Additionally,

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

HCGIs are not susceptible to shearing failure from heat or surfactants, making the plumbing of dishwashers to them acceptable. Interceptor sizing and design criteria are also evolving toward more tailored approaches based on analysis of restaurant FOG production calculated using FSE-specific characteristics and sales volume. Such tailored analyses are becoming more available, and allow for more defensible sizing, which results in more effective FOG recovery without imposing unreasonable costs on regulated FSEs. City Utilities Development Services (DVS) currently adheres to the 1,000 gallon GGI requirement with few exceptions for new construction and significant rebuilds at FOG-producing FSEs.10 FSEs with indoor traps, however, are effectively “grandfathered” out of the sizing requirement as previously discussed.

2.11.4 Plumbed Fixtures The goals of establishing and enforcing plumbing requirements are to prevent direct bypass of FOG to the collection system due to direct connections and to enhance resource recovery by capturing FOG from all kitchen sources. SA6 incorporates the International Plumbing Code (IPC) by reference to establish what fixtures must be plumbed to an extractor. Additionally, SA6 categorically prohibits connection of garbage disposals, dishwashers, and sanitary drains to extractors.

2.11.5 Extractor Maintenance and Cleaning Extractor maintenance and cleaning using effective practices and frequencies, along with proper FOG disposition, are the responsibilities that a utility assumes and manages on behalf of participating FSEs in a resource recovery cooperative. Accordingly, effective authorities and enforcement strategies for requiring FSEs to procure proper cleaning practices and frequencies are a critical prerequisite for a successful cooperative. SUO, §51.038 and R&R Section 9 establish that required grease extractors “shall be so

maintained by (the FSE) so that none of such substances can be discharged or carried over into the public sewers”, but provide no specificity regarding the frequency or methods of maintenance. R&R Section 9 further states that “if notification is given that maintenance is required, said maintenance shall be carried out within 30 days”, and that the cost and responsibility for maintenance are the sole responsibility of the FSE.11 SUO §51.038, and SUO §51.110 together give clear authority for FWCU to establish and enforce maintenance requirements in the R&R that could include frequency and procedural metrics. However, the R&R currently appear to limit FWCU’s authority to require cleaning at a specific frequency and/or using specific cleaning practices to establishing requirements as mitigation for sampling violations. FOG programs at similar utilities typically utilize enforceable prescribed or tailored cleaning frequency requirements, or performance-based frequency requirements, e.g. extractors must be serviced before the FOG layer reaches 25% thickness. Increasingly, cleaning frequencies may be determined using FOG production calculators based on FSE-specific characteristics and sales volumes and by comparing FOG production to extractor capacities to determine a tailored frequency for each FSE. This approach yields fairly effective and defensible frequencies. A review of pump out data in Linko resulted in an estimated average cleaning frequency at FOGproducing FSEs of 2.5 times annually, or once every 146 days. This is 56 days less frequent than typical minimum manufacturers’ specification for outdoor grease interceptors. Based on this estimate, approximately 37.5% of FOG generated at Fort Wayne FSEs, on average, may be bypassing extractors due solely to the lack of enforceable cleaning frequencies and practices.

2.11.6 Sampling and Effluent Limitations The goal of sampling, when utilized as enforcement criteria, should be to provide information that will allow an FSE, with

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

support from the regulatory utility, to implement remedies to effectively remove FOG from its wastewater discharges. To be effectively consistent with FWCU’s strategic goals, effluent limits should be established to extract FOG from FSE discharges in order to prevent problems from occurring within the collection system, to reduce loading to the WPCP, and to recover FOG for codigestion. FWCU’s authorities, beginning with SUO §51.033(B), require that acceptable limits for FOG be established in the Sewer Utility R&R, that limits be calculated and set at an amount shown not to cause interference or obstruction; and that they be reevaluated and adjusted as necessary to protect the integrity of the sewer utility. In summary, the SUO requires that limits be set at a threshold beyond which there is demonstrated impact to the publicly owned treatment works (POTW). SUO §51.037 and supporting authorities establish the responsibility of FSEs to construct and maintain a control manhole for sampling discharge. This can be considerably costly for both new and existing FSEs, particularly when considered in the context of the limitations of sampling discussed in this section. R&R Section 5.1 establishes a threshold of 200 mg/L as an acceptable discharge concentration for total Oil and Grease (O&G) and applies the limit broadly to all commercial FSEs. However, Section 5.2 appears to limit the applicability of compliance sampling requirements to FSEs discharging to high maintenance sewer lines, though the language of this limitation is ambiguous. Information on how the 200 mg/L limit was established and data was used to inform the establishment of 200 mg/L was not available for review in this analysis. Furthermore, as discussed in Section 2.11.2, despite FWCU having broad authority to require the installation of extractors at all FSEs, SA6 categorically establishes the extractor requirement as mandatory in high sewer

maintenance areas, implying a lesser mandate where problems do not occur. R&R Section 5.2 also establishes civil penalty schedules for multiple violations. In summary, FWCU’s authorities for effluent sampling and limits appear to create a regulatory structure designed to be reactive to FSEs located on sewer lines requiring excessive grease-related maintenance, rather than proactively serving to prevent FOG from being discharged to, and creating problems in, the collection system and at the WPCP. Such a structure, whether intentional or not, may create inequity between FSEs based solely on location. Notes from the history of FWCU’s IPS program reviewed for this analysis reflect past complaints from FSEs regarding the fairness of FWCU sampling program. Additionally, this approach isolates collection system issues as the sole purpose of FOG regulation and disregards WPCP loading and FOG resource recovery as goals for FOG management, despite protection of the WPCP as an expressed goal in SUO §51.038. The following list summarizes the results and notable findings from a review of compliance sampling conducted in calendar year 2018. ■

Ninety-five (94) samples were collected at 80 FSEs over the calendar year

■

Initial samples at nineteen (19) FSEs, or 24% of the facilities sampled, violated the O&G limit of 200 mg/L

■

Including repeat samples, 34 of 94 samples collected, or 36%, violated the O&G limit of 200 mg/L

■

All of the 19 FSEs with violations had been inspected within one year prior to the date of initial sampling, and at least 18 of them were in compliance with extractor and plumbing requirements at the time the violating sample was collected

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

■

$5,600 in fines were issued to violating FSEs due to repeat violations

■

Sample results in 2018 ranged widely from less than reportable levels of 5 mg/L to 7,958 mg/L

Based on these findings and other information provided by IPS, it appears that that violations typically result either from extractor bypass due to inadequate service frequency, or due to poor kitchen practices like utilizing direct plumbed fixtures such as hand sinks to dispose of grease sources such as mop water. Nonetheless, the high rate of sample violation for FSEs that are otherwise determined to be in compliance raises questions regarding the efficacy of sampling to inform preventative FOG practices and/or compliance assessments other than compliance with the limit itself. If all kitchen plumbing fixtures in an FSE were plumbed to the extractor, and extractors were being serviced adequately, there would be nothing to explain exceedances when they occurred. Furthermore, SUO §51.039 Subsection (B) requires all wastewater sampling to be representative of a user’s discharge. Comparable utilities are increasingly abandoning sampling and effluent limitations as enforceable measures for a number of reasons related to representativeness: ■

Extractor influent concentrations range widely throughout the day, seasonally, and between restaurants. Extractor influent has been measured at over 35,000 mg/L for O&G in WERF studies.12 Even with a highefficiency removal rate of 95%, effluent would contain concentrations of over 1,700 mg/L.

■

Collecting a grab “snap-shot” sample from an FSE’s widely variable effluent, or even a series of samples over 24 hours, is not strongly defensible with regard to representativeness. There are over 8,700 hours in a year. Randomly isolating 24 contiguous hours as a window into

representativeness, and analyzing only one sample collected within that window, risks challenge. ■

WERF’s Report on Assessment of Grease Interceptor Performance measured a range of laboratory error rates for EPA Method 1664 for Oil and Grease from 29% to 44%, raising significant questions related to the defensibility of results.

SUO §51.041, Use of Representative Analysis, allows FWCU to make a determination of the character and concentration of wastes by using data based on analysis of similar processes or data for the type of business that are available from U.S. EPA or industry-recognized sources. As stated previously, industry calculators are available that can utilize calculated FSE specific loading information along with extractor capacity and efficiency, and extractor cleaning frequency, to estimate effluent loads and concentrations that are arguably more reliable than effluent sampling results. SUO §51.041 may provide strong opportunities to utilize more defensible and representative methodologies than field sampling using existing ordinance authorities.

2.11.7 Grease Cooperative Authorities SUO §51.038 establishes the FSE’s responsibility to maintain grease extractors to prevent FOG from being “carried over” (bypassed) to sewer. This section of the SUO does not authorize the utility’s assistance in complying with this responsibility, but it does not preclude it either. SUO §51.110 grants FWCU’s authority to “make and enforce appropriate rules and regulations… for implementation and enforcement.” To date, FWCU has established its intent to promulgate enforceable FWCUGC Terms of Enrollment for brokering maintenance on behalf of participating FSEs separate from any language in the R&R.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.11.8 Recommendations No modifications to FWCU’s SUO are recommended at this time. FWCU has made initial draft revisions to its R&R, which can be used as a starting point for considering and incorporating recommended revisions. 1. Establish specific and enforceable criteria for extractor cleaning frequency and procedures. Criteria could include boilerplate frequencies for interceptors and traps (e.g., 90 and 30 days, respectively), performancebased criteria for gravity grease interceptors (e.g., 25% rule for gravity interceptors or manufacturer’s specifications), or tailored frequencies based on calculated FOG production using metrics on type of FSE and sales volume. BlueBridge strongly recommends the use of tailored frequencies, as they allow flexibility in sizing and cleaning frequency, but achieve the optimal combination for effective FOG recovery with the most business-friendly result. Frequency criteria should be established at the time of development approval for new FSEs, and after baseline inspections and calculations for existing FSEs. Rules and procedures must identify frequency criteria and alternative ways, if any, of calculating requirements. Additionally, the R&R Section 9(f ) requirement to conduct maintenance within 30 days should be replaced by a timeline for complying with ongoing frequency requirements. Cleaning procedures should be consistent with industry best practices for extractor cleaning and maintenance, as outlined in IPS’s Outreach Manual. 2. FWCU should embrace established authorities to compel compliance other than the use and enforcement of effluent limitations. Consistent with (1), enforceability and authority to issue civil penalties for failure to comply with cleaning frequency and procedure requirements as well as other requirements unrelated to effluent sampling are established in SUO §51.038, and SUO §51.110. These authorities, and specific requirements, should be re-

expressed in the R&R. Consideration should also be given to specific civil penalties schedules for violations of cleaning and other non-sampling requirements. 3. FWCUGC authorities and terms of enrollment should be developed and incorporated into a stand-alone Terms of Enrollment authority to be approved by the Board of Public Works separately but in parallel with recommended rule revisions. Additionally, FWCU’s authority to establish incentives for currently unenforceable best practices, such as retrofitting indoor traps to outdoor interceptors, should be established in the terms of enrollment to support the goals of the FWCUGC. 4. FWCU should strongly reconsider the use of sampling and enforcement of discharge limitations as its sole or even primary enforcement criteria. Sampling could be discretionary to inform IPS and FSEs on the effectiveness of certain measures, or could be used as one of several alternatives for assessing compliance, but the efficacy of depending on sampling and limits as the only enforcement criteria should be re-evaluated. 5. Distinctions for high maintenance portions of the collection system and expressed or implied differential criteria that limits FOG to being a collection system issue, or establishes requirements as only reactive to problems, should be removed from FWCU FOG authorities. FOG requirements should be preventative, system-wide, and related to all of FWCU’s objectives for FOG management and recovery. Specific authorities recommended for revision include R&R Section 5.2(b), Section 8(c), Section 9(c), and SA6.07(2). 6. Extractor sizing criteria should be more flexible, should be based on FSE-specific calculations of grease production, and should be coordinated with cleaning frequency criteria to ensure optimal FOG management and recovery without overburdening FSEs. This includes removing the 1,000 gallon minimum requirement, or establishing flexibility to utilize HCGIs with production based frequency requirements.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.12 Implementation and Enforcement The most fundamental prerequisite for implementation of a FOG recovery cooperative is effective enforcement of well-structured requirements for all FSEs. To compel participation in a program that advertises guaranteed compliance with effective FOG cleaning and maintenance practices as a value proposition to small business owners, effective self-managed compliance for FSEs must be the alternative. In summary, FSEs must expect that they will otherwise be required to comply in order to be compelled to achieve compliance by enrolling in the FWCUGC. More specifically, effective cleaning and maintenance of extractors, the foundational service provided through cooperative resource recovery systems and the service that secures codigestion feedstock, must be required and enforced.

2.12.1 Extractors Fort Wayne’s IPS program and DVS effectively utilize established authorities to require the installation of extractors for new construction and significant rebuilds at FOG-producing FSEs. For existing FSEs, IPS requires the installation of an extractor when an FSE is found not to have a functioning extractor during inspections, but the type and location of the extractor are deemed to be grandfathered. Inspections to assess compliance with FWCU’s extractor requirement for existing FSEs take approximately 15 minutes at the time of comprehensive inspections. However, due largely to the resource demands of sampling responsibilities and dye testing for compliance with plumbing requirements, IPS is able to conduct only 200-250 inspections of existing FSEs annually for compliance with the requirement to install an extractor with current resources. Between April 2018 and March 2019, IPS conducted initial and follow-up inspections of just over 200 FSEs. At this rate it would take over seven years to inspect each regulated FSE. Based on data in Linko, approximately

640 of 1,626 or over 39% of active regulated Fort Wayne FSEs are not documented as ever having been inspected for compliance with the requirement to install an extractor (see Section 9.5). Typical industry standard for inspections of extractors to effectively compel compliance is once every one to three years, with two years being the most commonly desirable inspection frequency. Very few utilities achieve this benchmark, many large ones going as many as 5-10 years between inspections. A differential between resource demands and utility investments is why so many sewer utilities still struggle to effectively manage FOG.

2.12.2 Plumbed Fixtures During routine inspections of existing facilities, the IPS program utilizes the SA6 criteria to ensure that required and prohibited fixtures are plumbed in compliance. Notably, very few like utilities deploy as thorough and effective a process for plumbing verification as FWCU’s IPS program does at inspected FSEs. FWCU’s FOG Program Coordinator is extremely knowledgeable and efficient in performing dye test inspections to ensure that fixtures are plumbed as required. A review of Linko inspection reports appears to reflect a moderate occurrence of plumbingrelated non-compliance at the time of initial inspection, but recidivism is low to nonexistent, demonstrating the effectiveness of inspections. In the last five years, 118 out of 566, or 21%, of total FSEs dye traced were determined to be out of compliance with plumbing requirements upon initial inspection but were brought back into compliance within reasonable time frames. Effective dye test inspections, however, are the most resource-intensive component of FWCU’s inspection process. Dye trace testing using two-person teams at fixtures, control manholes, and extractors typically takes between 60 and 90 minutes, or two to three staff-hours, to complete in addition to other inspection tasks, depending on the

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.12.4 Extractor Maintenance and Cleaning

Interceptor at a Fort Wayne McDonald’s showing thick grease layer due to inadequate cleaning frequency.

complexity of plumbing. During a site visit at a McDonald’s on Goshen conducted on April 25, 2019 on which BlueBridge accompanied IPS staff, the entire inspection was observed to have taken approximately two hours and fifteen minutes. Dye trace testing to assess plumbing compliance accounted for 90 minutes of the inspection. Based on a review of Linko inspection data, only 35% of facilities inventoried in Linko, excluding non-food based businesses, have been dye tested for compliance with plumbing requirements in the last five years (See Section 9.5 Below).

FWCU IPS staff recommends, but does not require, cleaning and maintenance when extractors are observed to be at or near capacity at the time of inspection. The only exception to this is when discharge samples exceed limits, and cleaning is required as a remedy to attempt to achieve compliance. FWCU’s FOG BMP Outreach Manual recommends quarterly cleaning for outdoor extractors and as needed for indoor extractors, but no enforceable requirements are established. Occasionally, FSEs are put on cleaning schedules as a result of sampling violations, but if an FSE complies with effluent limitations, cleaning schedules are not treated as enforceable requirements.

2.12.5 Enforcement and Resource Demands IPS’s collective sampling and inspection processes for installation, plumbing, outreach, and compliance with effluent limits are very time consuming compared with similar utilities. Procedures utilized are extremely efficient but are relatively resource-intensive because they are effectively thorough. Sampling and dye testing are the most timeintensive components of the IPS inspection and

2.12.3 Sampling and Effluent Limitations IPS implements compliance sampling by setting up automated samplers in control manholes to collect hourly discrete effluent samples over a 24-hour period. The sample that appears to be the most cloudy based on visual inspection is then analyzed at the WPCP’s Laboratory utilizing EPA Method 1664 for Oil and Grease. When violations occur on initial samples, repeat samples are collected within 30 days and fines are assessed based on the schedule established in R&R Section 5.2. IPS concentrates sampling activities in high collection system maintenance areas, but not exclusively. In calendar year 2018, 94 samples were collected at 80 FSEs over the calendar year. IPS expects to collect approximately 100 samples in 2019.

Sampling Set-up

Collection

Preparation (10 minutes)

Travel (20 minutes)

Collection (10 minutes)

Sampler set-up (5 minutes)

Clean Equipment (20 minutes)

Total 2.5 hours

Sample Analysis (20 minutes)

Administrative (45 minutes)

Figure 23. Sampling time requirements

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Inspections Scheduling/Prep (5 minutes)

Travel (20 minutes) X 2 FSE

Extractor Plumbing (75 minutes) Inspection (15 minutes) X 2 FSE

Outreach (10 minutes)

Administrative (45 minutes) Total 5.25 hours

Figure 24. Inspection time requirements

enforcement process. Setting up automated samplers, collecting and transporting samples, laboratory analysis, cleaning of sampling equipment and glassware, and administrative record-keeping typically takes an estimated 2.5 hours per sample collected. As described in Section 8.4, dye testing requires two employees to conduct, and can take between one and two hours per inspection for the plumbing component alone. Complete inspections, including dye testing of extractors and control manholes, visual inspections of extractors and plumbing, and outreach, documentation and recording of results, and travel time are expected to take over five hours. The plumbing compliance component accounts for over half of the time required for inspections. If return visits are required due to lack of access and/or manager inavailability for outreach, or to reinspect after initial findings, inspections for one FSE can take longer. The IPS Section is staffed with one manager who performs FOG program administration and oversight 75% of the time. Inspection and sampling responsibilities and administration are

fulfilled by a full time program coordinator and 1.6 Inspector FTEs, who spend the remainder of their time on other responsibilities. Additionally, field responsibilities have been supported by one intern, who assists with FOG inspection and sampling work 90% of the time. In total, FWCUâ&#x20AC;&#x2122;s IPS FOG program is staffed with 0.75 FTE for program administration and oversight, and roughly 3.5 FTEs for preparing, conducting, and documenting field sampling and inspection work. Conservatively, IPS operational expenditures for FOG, prorated proportionally by FTE, are approximately $385,000 annually. With current staffing levels, including one intern, IPS is able to conduct comprehensive initial inspections, and any follow-up inspections, of approximately 200 FSEs annually, and collect compliance and repeat samples at approximately 80 facilities annually. At current inspection rates, it would take eight years to inspect all regulated FSEs, and six to seven years if expected low FOG producers were excluded. Currently, compliance with extractor installation requirements has not been assessed at 453 of Fort Wayneâ&#x20AC;&#x2122;s 1,323 FSEs believed to be significant FOG producers, and at 123 FSEs believed to be lower FOG producers. An optimal visual and outreach inspection frequency is every two years, but that frequency is typically effective when pump out frequency and extractor integrity are the primary enforceable criteria. Based on the low rate of repeat non-compliance for plumbing requirements, dye testing could be effective if performed every five years. At current sampling rates, it would take twenty years to sample all regulated FSEs in Fort Wayne, and approximately ten years if sampling was only performed at FSEs located in highmaintenance portions of the collection system. Because of the variability in FSE effluent quality, and other challenges associated with enforceable sampling and limits, BlueBridge cannot provide an estimate of what an effective sampling frequency would be. Nonetheless, it

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

is fairly certain that utilizing sampling as the sole enforceable criteria for compelling best practices for FOG is challenging based on resource demands, as well as the practical and defensibility issues discussed in Section 2.11. Resource-constrained FOG programs, even with field protocol that is much less thorough than FWCU’s are unfortunately the norm rather than the exception in the sewer industry. Intriguing alternatives are emerging that bridge resource deficits by creating markets for third party performance of some inspection and enforcement responsibilities and transforming utility roles into training and certification of third-party vendors. The utility then licenses 3rd party inspectors to perform inspections and monitors their compliance with utilityestablished inspection procedures as a condition of licensure.

Nashville, Tennessee’s Grease Trap and Grease Interceptor Certification Program trains and certifies third-party plumbers, haulers, and installers to inspect traps and interceptors for operational integrity using utility-established inspection protocol and documentation forms, and then requires FSEs to procure an inspection by a certified inspector on an annual basis. For utilities like FWCU with thorough and effective dye test procedures, this certification process could be extended to include plumbing inspections and dye testing on a periodic basis. This structure is somewhat similar to how resource recovery cooperatives work for extractor cleaning, except the transaction for inspections remains between the FSE and the vendor in a Nashville-style program. This structure could help FWCU make significant progress toward effective inspection frequencies.

2.12.6 Recommendations Achieving inspection frequencies necessary to effectively manage compliance and compel participation in the FWCUGC will require FWCU to either: 1) commit significant additional resources to its current FOG program; 2) make modifications to its inspection procedures, particularly for plumbing/dye-testing; or 3) consider alternative service delivery models that leverage third-party service providers to bridge resource deficits. Section 2.11.8 recommendations for consideration include modifications to authorities that may reduce sampling workload but would require the addition of a more modest commitment to enforcing cleaning frequencies and criteria. BlueBridge does not recommend modifications to existing plumbing inspection and dye testing procedures – FWCU’s are very effective. BlueBridge recommendations include: 1. Re-stated from section 2.11, FWCU should strongly reconsider the use of sampling and enforcement of discharge limitations 2. FWCU should consider the development of a certification process for the utilization of third-party vendors for trap and plumbing inspections (Nashville structure). Vendor groups could be engaged concurrent with potential contracted FWCUGC vendors, and

some of the certified vendors would likely be the same companies that serve as FWCUGC vendors for extractor maintenance and line jetting. 3. Consider contracting with a third-party to conduct baseline informational and potentially plumbing inspections for FSEs for which data and information are needed to be able to fully populate extractor compliance status during pilot program implementation 4. Consider desktop self-inspections and e-reporting for low risk FSEs and/or FSEs with histories of compliance 5. Make better use of Linko functionality, and explore how Linko can be utilized to streamline data entry and management 6. Establish and implement specific goals for inspection frequencies that effectively ensure and document a high rate of compliance. Inspection frequencies should be strategic based on resource recovery and WPCP goals in addition to collection system considerations. For example, high FOG producers and FSEs with non-compliance histories could be inspected more frequently.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.13 Sewer Rates Sewer rates for FSEs are typically differentiated from rates for other user classifications by wastewater strength, specifically biological oxygen demand (BOD), chemical oxygen demand (COD), suspended solids (TSS), etc., which are significantly higher in food service wastewater than in domestic wastewater. FWCU’s current sewer rate structure was effective January 1, 2015 with no adjustment for the last five 1-year periods. FWCU is currently undertaking a rate study to evaluate potential revisions for which it would seek approval in the next year. This rate revision process provides an opportunity for FWCU to consider alternative rate structures for FSEs that may better compel effective management and recovery of FOG, and best reflect cost of service.

■

A uniform strength surcharge for all FSEs does not distinguish between FSE types and characteristics. For example, a fast food restaurant and a coffee shop may pay the same rate despite producing significantly different strengths of wastewater.

■

Relatedly, a uniform surcharge does not reflect distinctions between FSEs with effective and ineffective FOG practices. For example, an FSE with an undersized extractor, inadequate cleaning frequencies, and poor kitchen BMPs pays the same volumetric rate as an FSE with an efficient and right-sized extractor, proper cleaning frequencies, and good practices. To illustrate variations between FSEs, FWCU IPS observed discharges with less than 5 mg/L and as much as 7,958 mg/L O&G at different FSEs in 2018. Presumably, COD concentrations would be similarly different at these two FSEs.

■

Flat strength surcharges are typically established by sampling a limited cross section of commercial establishments to determine a total load among the user class and then distributing costs of service for the load equally among users based on proportional volume. BOD, COD and TSS concentrations are not typically sampled during O&G sampling. Accordingly a significant effort is required to collect an up-to-date load-based data set that can be defensibly used to establish rates for the class. BOD and TSS data for Fort Wayne FSEs was not available for analysis, so recommendations regarding the usefulness of FSE data for FWCU’s rate study cannot be provided.

Goals in assessing rate structures for this analysis included: ■

A best possible reflection of true cost of service in FWCU’s commercial sewer rate / restaurant surcharge

■

Rates should reflect the value / return to the utility for different FOG management and recovery practices by FSEs

■

Rates should compel desired FSE practices to achieve compliance and resource recovery goals, and incentivize desired outcomes such as retrofits to outdoor interceptors and enrollment in the FWCUGC

2.13.1 FWCU Surcharge Under its current commercial sewer rate structure, FWCU utilizes a uniform flat strength surcharge for all FSEs within Fort Wayne of $1.0129 per 100 cubic feet (ccf) of metered water usage pursuant to SUO § 51.074(A). A flat volumetric surcharge for FSEs based on strength is fairly common industry practice, and has the advantage of being easy to deploy and administer because all users within the same class are billed the same surcharge, but this structure has a number of disadvantages as well, including:

2.13.2 FWCU Strength Calculation Information on how FWCU calculated the current surcharge of $1.0129 per ccf was not available for this analysis. However, utilizing the strength surcharge calculation methodology in SUO § 51.074(B) to back-calculate BOD, COD and TSS for the FSE surcharge results

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

in either a BOD concentration of 1,700 mg/L, or a COD concentration of 3,400 mg/L, or a TSS concentration of 1,370 mg/L. These concentrations seem high based on industry averages, which typically range from approximately 400 mg/L to 1,400 mg/L for BOD and 300 to 900 mg/L for TSS. Other studies validate this conclusion, establishing an FSE mean of roughly 1,000 – 1,100 mg/L for BOD and 300 - 400 mg/L for TSS.13,14

2.13.3 Alternative Rate Structures The variety of alternative high-strength rate structures reviewed for this analysis ranges from uniform flat rates such as FWCU’s that are fairly simple to administer, to those that increasingly differentiate between FSE characteristics whether those distinctions are based on type or volume of the FSE, or on compliance status. 2.9.3.1 Differential Rate for FSE Types Distinctions can be made to create tiers within FSE flat sewer rates with varying levels of resolution. For example, Phoenix, Arizona establishes a two-tiered rate for restaurants with and without in-house retail dining. Nashville establishes a three-tiered smallmedium-large commercial rate structure based on water use. Portland has 11 FSE rate classes as a baseline, including sit-down restaurants, fast food, donut shops, coffee shops, etc., for which rates were calculated on baseline BOD and TSS loading data.15 2.13.3.2 Differential Rate for Compliance and/or FOG Best Practices Increasingly, utilities are turning to rate structures that internalize differential costs of service based on FOG management and compliance. Madison, Wisconsin has established a three-tier system for 1) ineffective FOG maintenance (non-compliance), 2) effective FOG management (compliance) and 3) an even lower rate for FSE’s that are in compliance and also participate in a food waste recycling program, which has been shown to reduce loading. Scottsdale, Arizona passed a

50% surcharge on volumetric sewer rates for FSE’s determined to be out of compliance with FOG authorities. Lawrence, Kansas reported differential rates for FSEs with and interceptor, and those without, and Tacoma, Washington incentivizes best FOG practices using a rate differential. 2.13.3.3 Combined Differential Rate Structures Perhaps the gold standard for combined recognition of differential FSE strength characteristics, and the differential costs of effective and ineffective FOG management, is the City of Portland’s Cut Through the FOG program. Portland takes each of the individualized rates for 11 baseline FSE subclasses, and applies incrementally greater rate reduction factors for: 1) having an indoor grease trap with proper cleaning frequencies; 2) having a properly cleaned outdoor interceptor; 3) also not having garbage disposals; and 4) also participating in a food waste recovery or donation program. Note that the second factor could be used to compel retrofits to outdoor interceptors in Fort Wayne, and the fourth could just as easily be used to promote FSE enrollment in the FWCUGC based on the value of long-term codigestion feedstock security to the utility. Restaurants in Portland can lower their volumetric sewer rate by between 28% and 42% by implementing the most effective practices. A high-volume sit-down Americanstyle restaurant in Portland can save more than $200 per month off of its sewer bill by implementing the highest tier of best practices, more than enough to cover the costs of proper cleaning frequencies in almost any market. A program such as Portland’s certainly requires additional resources to implement. Portland employs a staff of five just for site verification of best practices. As a result, the utility reports a remarkably effective FSE participation rate of 85% in a jurisdiction of over 3,000 FSEs. Robust participation, in turn, allows the utility to significantly reduce the resource demands of its baseline enforcement program.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

Combined Differential Surcharge Example $1.80 $1.64 $1.28 $1.03

$1.16

$0.94 $0.78

$0.71

$0.65

$0.59 $0.40 $0.37

Non-Compliant High FOG

Compliant High FOG

FWCUGC High FOG

Non-Compliant Medium FOG

■ Revenue Requirements (in $1,000s)

Compliant Medium FOG

FWCUGC Medium FOG

■ Volumetric Surcharge (per ccf)

Figure 25. Combined Differential Surcharge Example. Figure 25 illustrates how a combined differential rate structure based on FOG production factors for FSE types (high and medium displayed) and based on compliance status and FWCUGC membership could be structured.

service discounts to also help offset the costs of recommended new regulatory requirements.

2.13.3.4 Differential Rate Impacts on FSEs As described in Sections 2.7, 2.8, and 2.9, better FOG management and recovery yield value to the utility and to its FSE users – value that is summarized in Section 2.16. FWCU’s rate adjustment process provides the utility with an opportunity to internalize a share of the value of effective FOG management and recovery back into the FSE rate surcharge and disposal fee at the WPCP. The FWCUGC provides a similar opportunity to leverage

To illustrate, increased extractor maintenance frequencies may cost an FSE an additional $450 per year to comply with new requirements, assuming $300 per service and an increase from 2.5 services to four service per year (see green bar values in figure 26, below). If FWCU is able to negotiate a 15% service discount in extractor maintenance for the FWCUGC through negotiations with FWCUGC haulers, the added

Differential Surcharge – Total Annual Cost to FSEs

$750 $1.03

$1,200

$750

$750 $1,020

$1,200 $1,020

$1,796 $1,109

Current (All FSEs)

$1,029

Non-Compliant High FOG

Compliant High FOG

$1,270 $777

$646

FWCUGC High FOG

Non-Compliant Compliant FWCUGC Medium FOG Medium FOG Medium FOG

■ Surcharge

$405

■ Extractor Service

Figure 26. Differential Surcharge – Total Annual Costs to FSEs

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

cost to member FSEs for increased cleaning is only $270 per year. The resulting elimination of cleaning-related bypass may save the utility a calculated net $320 per year in loading/ treatment costs and $40 per year in degreasing costs. Additionally, if an FSE enrolls in the FWCUGC, guaranteed recovery of the FSE’s FOG may generate enough biogas to offset a net $70 in energy costs, bringing the total savings to the utility to $430. Using an incentivized rate structure similar to Portland’s, FWCU would still have a $160 annual margin in calculated benefits that could be used in part to roll into rate discounts for participating FSEs (see blue bar values, figure 26). Achieving this scenario would result in FWCU’s ability to establish more effective but more costly requirements for FSEs, while also offering an alternative that would ensure lower total operating costs.

2.13.4 Tipping Fees Including an administrative fee, FWCU collects a flat universal rate of $114.41 per 1,000 gallons of FOG or other liquid organics delivered to the WPCP for codigestion (SUO § 51.073). These costs are billed to waste haulers, who then bundle costs into FSE service pricing with or without a margin. Tipping fees provide FWCU another opportunity to differentiate disposal costs based on value to the utility. For example, a lower disposal fee could be established for FWCUGC member FSEs based on the value of long-term feedstock security to FWCU. Additionally, the structure of a FOG cooperative gives a utility the opportunity to contract with haulers for pumping costs alone by unbundling and reassigning disposal fees directly to FSEs enrolled in the FWCUGC as a base charge and billing them directly through the utility’s billing system.

2.13.5 Recommendations FWCU’s current rates analysis process gives the utility the opportunity to distribute costs of service more strategically and equitably among the FSE user class. FWCU’s current rate study will establish revenue requirements and determine costs of service for the FSE user class, and the analyses in Sections 2.7, 2.8, 2.9, and 2.16 of this report can be used to support that determination. Additionally, concurrent implementation of the FWCUGC and other recommendations in this report with a sewer rate adjustment provide FWCU with the timely opportunity to design a high-strength rate structure that supports the implementation of best practices and compels FSE participation in FWCU’s resource recovery program. The following rate strategies are recommended for consideration to support implementation of the FWCUGC and to achieve FWCU’s strategic goal of establishing rates, fees, and charges that meet FWCU’s objectives:

1. Adopt a combined differential tiered highstrength rate structure that considers FOG production based on FSE type and characteristics, and FSE practices such as plumbing, extractor location, compliance and enrollment in the FWCUGC 2. Establish a discounted WPCP disposal fee for FWCUGC members, and consider a billing structure in which disposal costs are billed directly to FSEs. A tiered rate structure does not have to be complex. A defensible point based system and calculator could be established that calculates FSE-specific tiers based on value-based criteria, including FOG production, extractor type and location, compliance with FOG requirements, and membership in the FWUGC.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.14 Program Structure and Staffing As an alternative and more business-friendly strategy for achieving compliance with FWCU’s regulatory requirements for FOG maintenance, the FWCUGC requires close coordination with administration of the City’s baseline FOG IPS Program. However, as discussed in Section 2.4, the need to market and deliver the FWCUGC from a position of advocacy creates challenges if the program is administered from the enforcement group. Tempe experienced roadblocks to overcoming trust issues based on a relationship that was historically regulatory but overcame those issues once the programs were administered separately. Additionally, the program is being driven primarily by FWCU’s goal to secure feedstock to meet its energy neutrality targets and is best branded as an energy and sustainability program.

2.14.1 Separate Roles and Interaction Lessons learned by Tempe from the interaction between the utility’s FOG IPS and grease cooperative programs that can be applied to the FWCUGC, include the following: ■

Communication of regulatory requirements to FSEs should come from the IPS group

■

All FSEs should be inspected for compliance with regulatory requirements prior to being approached about the FOG cooperative – engaging FSEs regarding the FWCUGC and then telling them they are out of compliance will be perceived as a “gotcha”

■

Compliance inspections for extractors and plumbing should be completed, then IPS should inform FSE operators about new service frequency requirements, once effective, and inform them that a FWCUGC representative will be contacting them about the enrollment opportunity and its benefits.

■

FWCUGC staff/representatives should contact FSEs independently, inform FSEs about the program benefits, and illustrate bottom-line benefits of the program.

2.14.2 Contracted Inspections Relatedly, Section 2.12 explains data gaps, inspection lags, and resource demands for FWCU’s IPS program. Prior to implementing recruitment activities for the pilot program, FWCU should complete inspections of all pilot area FSEs with outdoor extractors and should inspect FSEs with unknown extractor types and locations as well. If both the Downtown and North Pilot Areas are utilized for the pilot program, approximately 40 FSEs with outdoor extractors and 77 FSEs with unknown extractors should be inspected before they are approached about enrolling in the FWCUGC. Also recommended in Section 2.12, FWCU might consider third-party or contracted inspections in order to fill FSE data gaps and establish a compliance status for all FSEs.

2.14.3 Recommendations 1. Administer the FWCUGC from the utility’s Energy and Sustainability office, but establish clear lines of coordination between FWCUGC and IPS 2. Staff the FWCUGC with one FTE, and the equivalent of 2 full time interns, or four part-time, for recruitment during the pilot program, possibly expanding to two FTEs during full scale implementation

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.15 Data and Administrative Systems

Defensible Cleaning Frequencies

FWCUGC Recruitment Strategy

Differential FSE Rate Surcharge

Defensible Interceptor Sizing Criteria

FOG Bypass Calculation

FSE FOG Production

DATA GAPS & STRATEGIES INFORMED

Costs of Service - Loading/Treatment

Table 2

Cost of Service Impacts – Collection System

Energy Recovery Projections

Table 16-1 summarizes data gaps that will need to be addressed to implement the FWCUGC and recommended supporting strategies.

Tipping Revenue Projections

2.15.1 Data Gaps Summarized

Strategy Informed Feedstock Projections

Data gaps identified and recommendations established in previous sections of this report collectively create new needs for FWCU FOG related data and administrative management systems. Additionally, the FWCUGC has administrative tasks, like service scheduling with haulers and billing FSEs, that are not common to traditional FOG programs and for which FOG market software is not typically designed.

Data Gap/Need

Sources: DVS Plans; Field Verification Extractor type, size, location (over 600 FSEs)

Retrofit potential for indoor traps (445-plus)

Compliance w/plumbing/dye test (5-years – over 900)

Sources: Professional Judgement (type); Business Indices; FSE Financial Data; Utility Billing System Detail on FSE Type (fast, fine, burger, coffee, etc)

FSE Volume (meals, water use, sales)

Source: FWCU Administrative Records Data used to calculate $1.0129 FSE surcharge

2.15.2 Data Collection Strategies The first three major gaps in data for FSE extractors and plumbing compliance will unquestionably require a significant investment of time for field observation and inspections. Some information on extractors and site layout may be available in plans submitted to DVS. Options for field data collection include utilizing IPS’s FOG program coordinator and inspectors, program interns, FWCU’s inrecruitment Program Manager for Energy and Sustainability Services once the position is filled, and/or retaining contracted services to complete baseline data collection.

Information on FSE type (fast, fine, casual, chicken, burger, Italian, etc) may be deduced simply by restaurant brand but if not, may also be available from published business indices or in state, county or local business records and licenses. Identifying source and securing this information along with restaurant productionbased metrics such as meals served, sales revenue, and water consumption would be a meaningful desktop assignment for a program intern.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.15.3 Linko for Data Linko has robust ability to house FSE and inspection related data, but there are questions regarding its flexibility to add unique data fields that would support recommended strategies for FWCUGC without customization. Additionally, Linko advertises its “Flexible Reporter” module which appears to allow for broad reporting capabilities but extracting data with unique queries seems more cumbersome than advertised. This may have been partly due to BlueBridge’s remote VPN connection to FWCU’s locally hosted system. Nonetheless, Linko appears to be unique among industry systems in its integration of hauled waste and inspection functions, making it useful for reviewing the entire supply chain for feedstocks from FSE to digester and tracking resource recovery value back to individual FSEs.

2.15.4 Linko for Administration The implementation of recommendations in this report would require substantially more functionality from Linko than FWCU IPS is currently utilizing, including but not limited to: ■

FWCUGC service scheduling and coordination with FWCUGC contracted haulers

■

FWCUGC billing, or linkage to the utility’s billing system

■

Calculation of user rate subclasses and periodic billing

■

Remote access and data entry by FWCUGC contracted haulers

■

Potentially, remote access and data entry by third-party certified inspectors

■

Remote access and data entry for FSE selfreporting

■

Ideally, cross-communication with FWCU GIS, asset management, and billing systems

Linko advertises a number of add-on modules that appear to be able to perform many of these desired functions, including its “Outlook Sync” and “Pump Out Manifest” (POM) modules, which collectively may provide very good functionality for interactive service scheduling and data management with haulers and FSEs. Also of interest is Linko’s Surcharge and Loadings Calculator (LinkoSL), which appears to be able to support rate calculations based on FSE-specific data. Lastly, Linko also offers a “Remote Inspector” module, which allows for inspection data entry in the field and could save significant time on office data entry of inspection results. Linko also appears to be configurable with enterprise GIS systems. In summary, Linko appears to offer significant functionality that could be added to FWCU’s Linko suite to potentially support all desired functions to support the FWCUGC and supporting strategies. However, many of these add-ons, including all of the modules that support remote data entry and communication that would be necessary to support FWCUGC administrative functions would require a merge to Linko’s cloud-based hosted solution. While such a merge would have a cost, it would also improve system speed and performance, which was observed to be very slow and cumbersome using the local solution.

2.15.5 Market Alternatives A number of market software systems are available to support FOG program administration and data management, including WaterTrax, Aqua Backflow’s Track My FOG, and SwiftComply’s FOG Management system. While these systems all provide basic functionality for FOG inspection programs, only SwiftComply offers functionality that was designed to integrate with hauler practices and service and FSE operations, offering seamless FOG management and disposition management. SwiftComply is also the provider for Tempe’s FOG program and its Grease Cooperative and has developed functionality specifically designed for resource recovery cooperative administration.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.5.6 Recommendations 1. Establish a plan, using a combination of staff, interns and 3rd-party support, to: ■

Collect information on extractor type, size and location for all Fort Wayne FSEs prior to implementation of the FWCUGC and/or any FSE sewer rate adjustment

■

Assess retrofit potential at all Fort Wayne FSEs with indoor traps within five years

■

Conduct plumbing/dye test inspections at all Fort Wayne FSEs on a 5-year rotation.

2. Under direction from the Program Manager for Energy and Sustainability Services, assign a program intern to collect information and metrics describing FSE type and service volume. Linko appears to offer significant functionality that FWCU IPS hasn’t had the opportunity to explore, isn’t available without add-on-modules, or is only available with the hosted solution. As advertised, Linko may provide very compatible functionality for the FWCUGC and supporting strategies. 3. Engage Linko to discuss the full suite of data and administrative functions needed to support the FWCUGC and related goals, and solicit a quote for full migraton to the hosted solution and implementation of supporting modules.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.16 Summarized Projected Program Benefits and Measurable Goals 2.16.1 Projected Outcomes / Measurable Goals Projected outcomes based on FWCUGC growth rates form the basis of measurable goals for the FWCUGC, and include: ■

Recover an additional 2.1 million gallons of FOG for codigestion annually over current levels

■

Increase tipping revenues at the WPCP by $213,000 annually

■

Reduce collection system maintenance activities and costs for the prevention of FSE-related sewer obstructions by 25%, or $71,000 annually

■

Remove 7.3 million pounds of chemical oxygen demand (COD) from the City’s waste stream, resulting in savings in wastewater treatment costs of $423,000 annually, or over $300 per FSE

■

Generate an additional 144,500 kilowatt hours (KWh) of renewable electricity per month at the WPCP, or 26% over current levels, resulting in a savings of $123,500 per year in energy costs

■

Lower operating costs for 865 community restaurants and FSEs, and recognize those businesses as critical contributors to creating a sustainable community

2.16.2 Monetized Benefits Monetized benefits projected from implementation of the FWCUGC are summarized in Table 3. Table 3. FWCUGC Projected Annual Benefits 5 YEAR

10 YEAR

Projected Tipping Revenue Increase (an)

$117,762

$213,278

Projected Energy Offset (an)

$69,082

$123,253

Projected Collection System Cost Avoidance (an)

$42,035

$71,459

Projected Treatment Cost Avoidance (an)

$160,960

$273,632

Total

$389,839

$681,623

2.16.3 Costs Costs of program implementation are difficult to project until the details of adjustments like added software functionality and FTE costs are calculated, but general estimates include non-recurring costs for up-front consulting fees, costs for contracted services for baseline inspections and data collection, and costs for migrating administrative software to a hosted environment are estimated not to exceed $300,000. Recurring costs include labor and materials for FWCUGC administration and are estimated based on the assumption that one full-time employee and two fulltime-equivalent interns will be retained to administer the program. This staffing level is fairly consistent with what Tempe experienced for implementation. Annual recurring costs for program administration and materials are estimated not to exceed $200,000 annually, including management oversight.

2.16.4 Net Present Value Assuming linear program growth and using a discount rate of 3%, the estimated 10-year net present value for implementation of the FWCUGC is approximately $1.6 million.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

2.17 Conclusions Cooperative resource recovery is an innovation in urban governance that was design to help sewer utilities protect sewer infrastructure and recovery organic codigestion feedstock by managing the issue of FOG using a systems approach. Existing digester capacity and a baseline codigestion operation give Fort Wayne City Utilities the opportunity to be the first sewer utility to prove this concept throughout the supply chain without having to consider up-front capital investments at its WPCP. Implementation of the FWCUGC will be a bold strategy for a bold utility whose leadership understands the importance of the bottomline, but also understands that the benefits of cooperative resource recovery are greater than the bottom line. Cooperative resource recovery is about mobilizing the distributed small-business economic engines of a large and vibrant local economy to drive sustainability solutions by using business advocacy and partnership to help their businesses thrive.

The recommendations in this report provide FWCU with a roadmap to implement the FWCUGC in less than one year. Achieving the measurable goals established in the Plan is realistic but depends on the implementation of a number of critical initiatives, the most imperative being implementation and effective enforcement of cleaning frequency requirements. While new requirements can be challenging for any utility to deploy, the member benefits of the FWCUGC and new FSE sewer rates create opportunities to leverage fair and effective incentives to compel restaurants and FSEs to operate more sustainably while improving their business outlook. This last outcome is what will enable FWCU to use cooperative resource recovery as an innovative means of achieving the utilityâ&#x20AC;&#x2122;s strategic goals.

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN

ENDNOTES 1

2018 Utility Honorees, Water Resources Utility of the Future Today, NACWA 2018

2 2017-2022 Strategic Plan, Fort Wayne City Utilities, August 2017 3 Assessment of Grease Interceptor Performance, Water Environment Research Foundation, 2008 4 Codigestion of Organic Waste Products with Wastewater Solids, Water Environment Research Foundation, 2010 5 Co-digestion Economic Analysis Tool (CoEAT) - Tool to Evaluate Costs and Benefits of Processing Wasted Food, FOG and Other Organic Materials, May 2017, EPA/600/R-16/373 6 Fort Wayne, IN Code of Ordinances, Chapter 51: Sewers 7 City Utilities Design Standards Manual, Sanitary (SA), Chapter 6: Building Sewer and Appurtenance Design (SA6) 8 Hydromechanical Grease Interceptor Sizing and Selection Guide, IW Consulting, 2018 9 WERF, 2008 10 IW Consulting, 2018 11 General Rules and regulations, Fort Wayne Water Pollution Control Utility, as Amended December 4, 2013 12 WERF, 2008 13 WERF, 2008 14 Texas Restaurant Wastewater Analysis, TCEQ, 2003 15 Extra Strength Charge Program Administrative Rules, March 2019

FORT WAYNE CITY UTILITIES GREASE COOPERATIVE REPORT OF FINDINGS AND STRATEGIC BUSINESS PLAN