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[ clean energy economy ][ clean energy economy ]
The Final Mile: Attracting Data Centers with Renewable Energy within Black Hills Energy Territory
Contents
Executive Summary .............................................................................................................................................. 6
The Details of Decarbonization ........................................................................................................................... 8
The Trend Toward Decarbonization .......................................................................................................................... 10
State Level Decarbonization Trends .......................................................................................................................... 12
Table 1: Study Area 2015 Renewable Generation in Thousand Megawatts ............................................................ 13
Figure 1: Current Status of Renewable Energy Portfolio Standard by State ............................................................ 13
What is Biogas? ..................................................................................................................................................... 14
Biogas to RNG Projects ........................................................................................................................................... 14
RNG Project Financials ............................................................................................................................................. 17
Potential Investment Structures ................................................................................................................................ 20
Sustainable Economic Development ........................................................................................................................ 21
The Example of Data Centers .............................................................................................................................. 23
Potential Biogas Availability in BHE Territory ............................................................................................................. 24
Figure 2: Existing Anaerobic Digestors in BHE Service Territory .............................................................................. 25
Black Hills Energy and Microsoft: Cheyenne Opportunity ................................................................................ 25
Cheyenne Wastewater Treatment Plant .................................................................................................................... 27
Table 2: Potential Electricity Provided from the Cheyenne WWTP ........................................................................... 27
Microsoft Data Center Power Consumption ............................................................................................................ 28
Table 3: Project Financial Estimates ...................................................................................................................... 29
Other Environmental Drivers ..................................................................................................................................... 31
POTWs and Economic Development ....................................................................................................................... 31
Agricultural Digesters and Nutrient Management ...................................................................................................... 31
Agricultural Digesters and Manure Management ....................................................................................................... 32
Iowa Water-Energy Nexus ........................................................................................................................................ 32
Biogas Potential in BHE Territory ........................................................................................................................ 36
Figure 3: Biogas Potential in BHE Service Territory ................................................................................................. 36
Study Area Population .............................................................................................................................................. 37
Table 4: 2010 Census State Population ................................................................................................................ 37
Table 5: 2010 Census City/County Population ....................................................................................................... 38
The Final Mile Report | 3
The Final Mile Report | 4
Contents
Biogas Feedstock Sources .................................................................................................................................... 39
Animal Feeding Operations .................................................................................................................................... 39
Table 6: Top 5 CAFO by Biogas Potential in Study Area .......................................................................................40
Table 7: CAFO Type by State in Study Area ........................................................................................................ 40
Table 8: Concentrated Animal Feeding Operations .............................................................................................. 41
Biodiesel Plants ..................................................................................................................................................... 41
Table 9: Top 5 Biodiesel Plants located in Study Area ......................................................................................... 41
Table 10: Biodiesel Plants located in Study Area ................................................................................................. 42
Ethanol Plants ........................................................................................................................................................ 42
Table 11: Top 5 Ethanol Plants located in Study Area .......................................................................................... 42
Table 12: Top 5 Ethanol Plants located in Study Area .......................................................................................... 43
Paper Manufacturers .............................................................................................................................................. 43
Table 13: Top 5 Paper Manufacturing by Number of Employees .......................................................................... 43
Table 14: Paper Manufacturing Sites by State ..................................................................................................... 44
Food Processors ................................................................................................................................................... 44
Table 15: Top 5 Food Processors in the Study Area ............................................................................................ 45
Table 16: Food Processor Sites by State ............................................................................................................. 46
Landfill Waste ..........................................................................................................................................................46
Table 17: Top 5 Landfill Sites by Annual Tonnage in Study Area ........................................................................... 46
Table 18: Landfill Sites by State ........................................................................................................................... 46
Municipal Wastewater Treatment Plants ................................................................................................................ 47
Table 19: Top 5 WWTP ADs in Study Area by Average Flow ................................................................................ 47
Table 20: WWTP ADs in Study Area by State ...................................................................................................... 47
End Notes ............................................................................................................................................................. 50
Conclusion .......................................................................................................................................................... 48
Next Steps .......................................................................................................................................................... 49
Appendix A: Energy Generation Data by State in Study Area ............................................................................... 51
Arkansas ............................................................................................................................................................... 52
Table 21: Arkansas 2015 Net Generation ............................................................................................................ 52
Colorado ............................................................................................................................................................... 52
Table 22: Colorado 2015 Net Generation ............................................................................................................ 53
Iowa ...................................................................................................................................................................... 53
Table 23: Iowa 2015 Net Generation ................................................................................................................... 54
The Final Mile Report | 5
Contents
Kansas .................................................................................................................................................................... 54
Table 24: Kansas 2015 Net Generation ................................................................................................................. 55
Montana .................................................................................................................................................................. 55
Table 25: Montana 2015 Net Generation* ............................................................................................................. 55
Nebraska ................................................................................................................................................................ 56
Table 26: Nebraska 2015 Net Generation ............................................................................................................. 56
South Dakota .......................................................................................................................................................... 56
Table 27: South Dakota 2015 Net Generation ....................................................................................................... 57
Wyoming ................................................................................................................................................................. 57
Table 28: Wyoming 2015 Net Generation* ............................................................................................................ 57
Table 29: Study Area 2015 Net Generation ........................................................................................................... 58
Appendix B: Potential Biogas Feedstock .............................................................................................................. 59
Table 30: CAFO Sites in Study Area ...................................................................................................................... 60
Table 31: Biodiesel Plants located in Study Area ................................................................................................... 64
Table 32: Top 5 Ethanol Plants located in Study Area ............................................................................................ 65
Table 33: Paper Manufacturers in Study Area ....................................................................................................... 65
Table 34: Food Processors in Study Area .............................................................................................................. 67
Table 35: Food Processor Categories in the Study Area ........................................................................................ 69
Table 36: Landfills in Study Area ........................................................................................................................... 70
Table 37: Wastewater Treatment Plants in Study Area ........................................................................................... 72
Demand for DecarbonizationInfographic ©2018
{ BHE is Home to a Wide Array of Feedstock Sources }
Demand for DecarbonizationInfographic ©2018
Executive Summary
EcoEngineers appreciates the opportunity to discuss potential renewable energy solutions for data centers and other corporate energy consumers within the Black Hills Energy (BHE) service territory. We believe the integrity, work ethic, and expertise found within EcoEngineers can help BHE to capitalize on the development of renewable energy sources and subsequent reduction of anthropogenic greenhouse gas (GHG) emissions.
BHE serves approximately 1.2 million natural gas and electric utility customers in eight states, located primarily in the central United States: Arkansas, Colorado, Iowa, Kansas, Montana, Nebraska, South Dakota and Wyoming. The study area has a relatively low population, with Colorado being the most populated based on the 2010 US Census. The study area is home to the metropolitan areas of Denver, Kansas City, Omaha, Des Moines and Cheyenne, with smaller metropolitan areas dispersed throughout the study area. Many U.S. cities and states have voluntarily committed to reduce carbon emissions, thereby aligning themselves with the objectives of the Paris Climate Accord. In addition to government cooperation, many Fortune 500 companies, including Microsoft, Cargill, Coca-Cola, General Motors and Wal-Mart, have taken significant steps towards low or zero carbon operations by adjusting business practices and converting to renewable energy sources, including renewable natural gas (RNG).
The BHE operating territory is home to a wide array of feedstock sources for RNG which are detailed in this report. The sources include landfills, municipal wastewater treatment plants and concentrated animal feeding operations (CAFO). Many of these facilities are currently equipped to capture biogas and convert it to RNG. However, a significant number of potential sites that are undeveloped or underdeveloped. With proper investment, food processing plants, grocery store chains, and paper manufacturers could also become significant sources of RNG.
The benefits of uniting companies that are committed to carbon reduction with local sources of RNG include:
1. Availability of locally-sourced of clean fuels 2. Economic development and job creation 3. Revenue from increased electricity sales
This report discusses the process of carbon reduction, including state incentives to advance this type of development, the financial implications of this development and potential energy production from various types of biogas to RNG.
The Final Mile Report | 7
Demand for DecarbonizationInfographic ©2018
{ Demand for Decarbonization is Increasing }
The Details of Decarbonization
By displacing higher carbon coal with lower carbon renewable and natural gas fuel sources, electric and natural gas
utilities can proactively reduce carbon or “decarbonize” their supply networks and lead the way toward
lower emissions.
This effort on the part of utility companies must be complemented with downstream behavior changes, including
meeting the increased demand for low carbon energy from large users, fuel switching and more efficient fuel use, to
achieve meaningful reduction in anthropogenic greenhouse gas (GHG) emissions from energy consumption. Often
indications of downstream behavior changes occur first and are a driver for a change in utility strategy.
The Paris Climate Accord, adopted in 2015, is a sustained is a sustained global effort to explore how
anthropogenic greenhouse gas (GHG) emissions can be reduced to levels that will limit the increase the
earth’s mean surface temperature to less than 2 degrees celsius (oC). Although the U.S. is not a signatory
to the Paris Accord, many U.S. states, cities and private corporations have voluntarily committed to
decarbonize their operations to align themselves with this global movement.
The Final Mile Report | 9
Companies with a 100% Renewable Energy target
The Trend Toward Decarbonization
According to the RE100 website, approximately half of the world’s electricity is consumed by the private sector. The
conversion of this demand to renewables will accelerate the transformation of the global energy market and aid the
transition to a low carbon economy. RE100 members have committed to converting their operations to use 100%
renewable energy sources by a specific year, many as soon as 2020. RE100 is comprised of over 120 companies
worldwide, including large multinationals such as IKEA, Anheuser-Busch, Adobe, Bank of America, Apple, Nestle,
Nike, Starbucks and Walmart.
Another example of carbon reduction initiatives among corporations is described on the website of CDP Worldwide,
formerly the Carbon Disclosure Project. This knowledge sharing organization has documented examples of the
internal price companies like Coca-Cola, BP and Unilever have placed on carbon to make appropriate long-term
investment and strategic decisions1.
According to a 2016 report published by Advanced Energy Economy (AEE), 71 Fortune 100 companies and 215
Fortune 500 companies (43%) have a sustainability target, renewable energy target, or both2. Of these, 22 have
committed to meet 100% of their electricity renewable energy. These companies are eager to invest in renewable
energy projects and locate their operations in regions that can help them achieve their renewable energy goals.
The 22 companies that have a 100% renewable energy target include Apple, Microsoft, Facebook, Amazon and
Alphabet (formerly Google) - Global technology companies with substantial data storage needs.
With this type of initiative already in place, BHE could pro-actively approaches these companies with a plan that
demonstrates the availability of renewable energy within its territory and tariff structures that will assure them
competitive and reliable power delivery.
The Final Mile Report | 10
Demand for DecarbonizationInfographic ©2018
{ Sales of Electricity are Flattening }
The Final Mile Report | 12
The cost of adopting new technologies and fuels can be managed more efficiently by timing new infrastructure
adoption with scheduled new construction or the retirement of existing infrastructure. In that context, all large
users who are building new facilities should include the availability of renewable power in their site selection
process. Whether they are building a warehouse, a shopping center, a coffee shop, a data center or a
manufacturing site, these companies should prefer locations with a supply of renewable energy provided
other decision factors are more or less equal.
State Level Decarbonization Trends
In the public sector, there are already 15 U.S. states3, including Colorado, and joined by numerous cities, have
formally established climate action goals to reduce their carbon footprint. State and local governments must
develop plans that will achieve their climate goals without impeding local economic development. If BHE can show
the communities within its territory the potential to attract energy intensive industry by offering renewable energy, it
could help the local governments achieve the twin goals of decarbonization and economic development.
Within the BHE service territory Colorado, Iowa and Montana have enacted renewable portfolio standards (RPS),
with Iowa being the earliest adopter in 1983.
The Kansas RPS, originally enacted in 2009, has been converted into a voluntary goal. South Dakota also has a
successful voluntary program, with over 75% of total electricity generation from renewable sources.
At this time, Arkansas, Nebraska and Wyoming do not have an RPS in place. Currently, coal and nuclear power
are the primary sources of electric generation. Table 1 (p. 13) lists renewable energy production by type for each
state in the BHE service territory.
The Final Mile Report | 13
Solar WindBiomass TotalHydroelectric
Iowa 960 256 17,872 19,088Montana 9,887 1,965 11,852Kansas 19 2 62 10,999 11,082
Colorado 1,620 251 80 7,475 9,426South Dakota 4,851 2,497 7,348Nebraska 1,684 3,180 4,935
Wyoming 868 3,757 4,625Arkansas 3,569 0.9 89 3,659
Table 1—Study Area 2015 Renewable Generation in Thousand Megawatts
Figure 1— Current Status of Renewable Energy Portfolio Standards by State
Total4,935
Megawatts
Total4,625
Megawatts
Total11,852Megawatts
Total52
Total11,85
Tota4,62
Megaw Total4 935TTTTotalal4,935
MeMMMMMMMM gawatts
l252
tt
al25atts
11,85Megawat
a2a
2ts
Megawattsa
Total11,082Megawatts
all
Standard in Place
State Renewable Portfolio Standard Status
Voluntary GoalsNo Standard
Total19,088Megawatts
Total3,659
Megawatts
Total7,348
Megawatts
Total9,426
Megawatts
Table 1: Study Area 2015 Renewable Generation in Thousand Megawatts
Figure 1: Current Status of Renewable Energy Portfolio Standards by State
The Final Mile Report | 14
What is Biogas?
Biogas is primarily a mixture of methane and carbon dioxide produced by the bacterial decomposition of organic
materials in the absence of oxygen. Depending on the source of organic matter, biogas typically contains 50-70%
methane, 30-40% carbon dioxide, and trace amounts of other constituents, such as hydrogen sulfide, hydrogen,
nitrogen, and siloxanes. Biogas is produced at landfills and at anaerobic digesters where wastewater biosolids,
animal manure and other organic feedstocks are processed.
Biogas to RNG Projects
Biogas production from the anaerobic digestion (AD) of residual organic feedstock is an established process
and can be implemented as an effective energy recovery and reuse strategy wherever there are wastewater
treatment plants, landfills and/or animal feedlots. Biogas is a mixture of methane, carbon dioxide, hydrogen
sulfide and other trace impurities. The methane from biogas (aka renewable natural gas or RNG) is chemically
identical to natural gas from fossil sources and can displace it to produce renewable electricity or compressed
natural gas (CNG). Via displacement, this natural gas consumption can be sourced from the RNG injected into the
pipeline from off-site production.
Gas
Green Energy
CO2/CH4
Historically, the feedstocks for most biogas systems have been livestock manure, wastewater sludge and, in the
case of landfills, municipal solid waste. While new projects continue to use these traditional feedstocks, many
projects are also using source-separated and industrial organics as either a primary or supplemental feedstock.
The primary biogas system feedstocks includes:
• Livestock manure – dairy, swine, poultry, and beef
•Municipalsolidwaste–mixedMSWdeliveredtolandfill(~30%organics)
• Wastewater biosolids and primary sludge – by-product from treatment of wastewater streams
• Food waste – post-harvest edible food that is not consumed
• Industrial waste – by-products of the commercial food production and processing industries
The Final Mile Report | 15
Livestock Manure Wastewater BiosolidsMunicipal Solid Waste Industrial WasteFood Waste
The Final Mile Report | 16
There are several different options for converting biogas to energy. Unlike intermittent renewable energy
alternatives such as wind and solar power, biogas delivers a continuous source of energy. Specific commercially
proven energy uses for biogas include:
• Thermal applications: Biogas is used directly on-site to heat digesters and buildings/maintenance
shops, to fuel boilers or kilns, and to generate heat or steam.
• Power generation: Electricity is produced through an internal combustion engine, gas turbine, or
micro-turbine technologies for on-site use or sale to the electric grid.
• Combinedheatandpower(CHP)systems: Increase overall energy efficiency of electricity systems by
producing heat and electricity at the same time.
• Vehicle fuels: Upgraded biogas can be converted to fuels including compressed natural gas, liquefied
natural gas, hydrogen, and liquid transportation fuels.
There is a growing trend towards integrated, regional biogas systems that are built to produce energy and high
value products. These can involve a suite of technologies and processes to more efficiently and effectively process
a variety of feedstocks to produce renewable fuels as well as other marketable and valuable commodities.
These systems can be municipally owned and/or privately owned, offering a good opportunity for public-private
partnerships.
Biogas systems can offer a wide range of potential revenue streams, create jobs and boost economic
development in the community. They can also improve rural infrastructure for waste management and distributed
energy delivery.
RNG Project Financials
Regulations governing carbon emissions from transportation fuels are increasing throughout the U.S.
The Renewable Fuel Standard4 was passed by the EPA in 2007 and then revised in 2010. It promotes energy
independence and domestic renewable fuel production and mandates the use of 36 billion gallons off renewable
fuel by 2022. In the summer of 2014, the EPA classified renewable natural gas from biogas as cellulosic biofuel,
awarding it a premium value under the program.
There are also a number of local and regional renewable fuel incentive programs in place across the U.S. These
programs range from blending incentives to state biofuel mandates similar to the RFS. The most prominent among
these is California’s Low Carbon Fuel Standard (LCFS), which has resulted in biogas from landfills and wastewater
plants displacing the majority of CNG retailed in California5. Among other things, it is the first low-carbon fuel
standard mandate in the world and calls for an 18% reduction of carbon in California transportation fuels by 2030.
The LCFS specifically identifies renewable natural gas from biogas as valuable renewable fuel eligible for the
standard.
The RFS requires petroleum refiners and importers (also known as obligated parties or OPs) to blend a portion of
renewable fuel into the transportation fuel mix that is commercially sold in the U.S. The minimum mandated levels
of renewable fuels (also known as Renewable Volume Obligations or RVOs) are calculated as a percentage of the
total refined product output of the major refining companies and importers of petroleum fuels. Obligated parties
under the RFS have to purchase Renewable Identification Numbers (RINs) corresponding to gallons of renewable
fuels in proportion to their RVOs to demonstrate compliance with the RFS.
While the primary focus of this report is the development of RNG for power generation, the availability of carbon
credits for clean transportation fuel has placed a high value on RNG injected into natural gas pipelines. As a result
of these renewable fuel mandates, the value of biogas injected into a natural gas pipeline has seen ranges
extending from $15 to $60 per MMBTU. These wide variances result from the regulatory frameworks within which
the projects operate and the overall carbon reduction potential of the projects.
The Final Mile Report | 17
The Final Mile Report | 18
For typical municipal wastewater treatment plant biogas, the value of the biogas is within a narrower range of $15
to $40 per MMBTU, of which about $3 can be attributed to the commodity price and $12-$37 can be attributed
to the renewable credit value.
Markets for green attributes are often created by regulations that can artificially produce a value for certain
feedstocks, technologies and fuels. Pricing the green attributes of the biogas in proportion to its GHG reduction
impact and other regulatory nuances cause the variance in credit values.
For example, a dairy farm that uses lagoons for manure management typically emits methane, a potent
greenhouse gas, into the atmosphere. If the manure is treated in an anaerobic digester and the methane is
captured and put to beneficial use, the project will have a very high GHG reduction impact. Relative to dairy
manure, methane from a landfill may have a smaller GHG reduction impact.
A large landfill could produce RNG in the range of 2,000 to 4,000 MMBtus per day. The manure from a 20,000
head dairy farm will produce about 1,000 MMBtus per day of RNG. Costs to capture the biogas, clean it up and
put the methane to beneficial use can vary widely depending on existing digester infrastructure and proximity and
size of natural gas pipelines.
For a large regional landfill with 4,000 MMBtus/day of RNG production, the value of energy credits resulting
from use of the RNG in the transportation sector can range from $12 to $47 per MMBtu resulting in project
revenues ranging from $17.5 million to $68.5 million per year.
There is an additional revenue stream from gas sales, which can be approximately $3.5 to $5 million annually
(assuming short-term gas prices in the $2.50 - $3.50 range per MMBtu). Thus, gross revenues from the project
could be in the $21 - $74 million range annually from the sale of green credits and the gas.
Capital outlay for biogas to RNG projects at landfills is primarily for equipment to clean the landfill gas to
pipeline quality and to connect the gas to a utility pipeline. In this example, the cost of cleaning the RNG and
pipeline injection is assumed to be within a range of $21 million to $32 million. The variance is due to the extent of
cleaning required, the distance to the nearest utility pipeline and suitability of existing infrastructure, such as power
and roads. Operating and maintenance costs are assumed to be within the $1 - $2 million range.
Payback periods with the most conservative assumptions – highest costs and lowest revenues - are less than
3 years, and the moderate scenario has a payback of less than 1 year. The primary risk in such projects results
from regulatory uncertainty. Typically, regulatory uncertainty is more manageable in the short term (1-3 years) and
follows election cycles. If a project payback falls within the manageable boundaries for uncertainty, the risk is
greatly mitigated. However, if the payback extends into a longer time frame, then other risk management measures
may be put in place.
The Final Mile Report | 19
Landfill producing 4,000 MMBtus/day of Renewable Natural Gas
Value of energy credits resulting from use of the RNG in the transportation sector can range from $12 to $47/MMBtu
Project revenues ranging from $17.5 million to $68.5 million/year.
The Final Mile Report | 20
Potential Investment Structures
An energy-intensive large user could provide the capital outlay required in the above example and secure a reliable
source of renewable energy. The end use that provides the greatest revenue to the project is currently CNG in
the transportation fuels sector. However, other uses of RNG – such as power generation, use in electric vehicles,
space heating or even extraction of renewable hydrogen for fuel cells, etc. – are all possible long-term alternatives.
RNG will have a premium value to an entity that wants to decarbonize it’s operations by replacing fossil
energy sources with renewables (voluntarily or due to regulatory pressure). The internal cost they place on this
decarbonization will drive the value they place on RNG over the long-term. Companies like BP have estimated
their internal price of carbon at $40 per metric ton (MT) equivalent of CO2e with a conservative limit of $90 per MT.
These prices correspond to a $2.50 - $5.50 premium for RNG over the price of natural gas6 .
Other entities may place a greater value in other regulatory jurisdictions such as cap and trade, etc. At a longterm
carbon price of $50 per MT, the premium on RNG is $3 per MMBtu and the payback period for the most
conservative scenario in our example is still less than 8 years for an asset that has an operating life of 20 years.
If the corporate entity seeking renewable energy does not wish to invest capital directly into the project, there are
other structures that can be explored. One such possibility is offering a minimum floor price for the biogas. This
floor price could be derived from an internal price for carbon, from regulatory requirements or from a price they are
willing to pay for renewable power. For example, an $0.08/kWh would translate into approximately $10/MMBtu
at a 7,900 Btu/kWh heat rate for power production. A floor price of $10/MMBtu will be triggered in a hypothetical
scenario where the value of clean transportation fuel credits decline.
Despite being a source of biogenic carbon, municipal landfills or wastewater treatment facilities can be risk averse
and may not maximize the full potential value due to unstable investment concerns. Volatile environmental credit
markets can also be a deterrent to those contemplating projects. A floor price backed by a large credit-worthy
counter party could provide the assurances to the municipality to move forward with the project.
Sustainable Economic Development
Unlocking biogenic carbon to its full potential can also be a long-term investment in regional infrastructure.
The EPA estimates $271 billion is needed for wastewater infrastructure over the next 25 years7. Revenues
from carbon assets can finance a large portion of this investment. A robust and reliable municipal wastewater
treatment plant that operates under a resource-recovery model is an anchor for regional economic
development. Lower wastewater treatment costs will stimulate expansion of existing industry and recruitment of
new industry. Thus, biogas to RNG projects at municipal wastewater treatment facilities is a strategic investment in
regional economic development.
The Final Mile Report | 21
Revenues from Carbon Assets Can Help Finance Wastewater Infrastructure Investment
EPA estimates $271 billion is needed for wastewater infrastructure over the next 25 years.
The Final Mile Report | 22
Regional economies that are dependent on agriculture and livestock production are often challenged to minimize
the environmental impacts of the industry: odor, methane releases from manure lagoons, pathogen in watersheds
from manure application on agricultural land, particulate matter in the air, etc. Manure management accounts for
about 15 percent of the total greenhouse gas emissions from the agriculture economic sector in the
United States8.
Manure digesters can ease environmental and social impacts of livestock production by addressing all the
above issues within an effective manure management system. These investments protect the environment
and strengthen regional economies. Other potential ancillary benefits from biogas to RNG projects include job
creation, investments in the natural gas grid, greater network of distributed generation assets, increased tax
revenues for the state, etc.
4,000 MMBtus/day =
Landfill Data Center
25%of energy use 185 million kwh/year
The Example of Data Centers
This report looks at the example of siting data centers at locations that have the potential to produce biogas.
The broader lessons of this analysis could potentially be applied to other renewable energy project types and other
large user profiles.
Many technology companies such as Apple, Microsoft, Facebook, Alphabet (formerly Google), Adobe, eBay,
etc. are also part of RE100 and have a 100% renewable energy target. Therefore, they are motivated to site
data centers in locations that provide a reliable supply of renewable energy. Due to their large power demand and
need for high reliability, data centers are good examples of large private sector users.
Due to a data center’s need to be continuously online, they typically rely on grid electricity purchased from the
local utility or from wholesale markets for their baseline power needs. They can offset 100% of their grid power
purchases with renewable carbon credits (RECs), which constitute the legal purchase of renewable power.
There is a preference to have projects originating RECs located near the data centers to maximize physical
proximity of renewable supply and consumption. Data centers typically also have 100%, on-site, back-up
generation capacity, typically powered by natural gas (or sometimes diesel). During a power outage, a data center
relies on its back-up generation assets to stay operational.
A large regional data center serving cloud-computing could have a power demand of 750 million kwh/year9.
Meeting this entire demand from renewables could require multiple renewable energy projects. Strategically
evaluating the regional availability of biogenic carbon and the economic and technical feasibility of capturing it as
source fuel should be an integral part of a comprehensive site selection process. The local utility is best positioned
to conduct this evaluation and provide a large user with a list of potential sites.
In the RNG example above, a regional landfill that generates 4,000 MMBtus per day can generate up to 185
million kwh per year, which is about 25% of a large data center’s energy demand.
The Final Mile Report | 23
The Final Mile Report | 24
Potential Biogas Availability in BHE Territory
Black Hills Energy (BHE) has several options to develop renewable energy from carbon assets to serve their 1.2
million natural gas and electric utility customers. In Iowa and Nebraska, there are nearly 15,000 concentrated
animal feedlots. BHE’s territory has over 330 landfills that accept over 91 million tons of waste each year
and 122 wastewater treatment plants with installed anaerobic digestion systems. There are also 2,466 food
processors in the 8-state region with high strength wastewater and associated solids that are potentially a
good source of feedstock for biogas production.
Making these projects serve corporate clean energy goals will have multiple beneficial impacts. It will provide
a reliable source of locally-produced clean energy to the companies. It could reduce the carbon footprint of
operations. It could improve local air and water quality, and stimulate local economic development.
122 Wastewater Treatment Plants with Anaerobic Digesters
2,466 Food Processors with high strength wastewater and associated solids
330 Landfills receive 91 million tons of waste/yearLandfill
Wastewater Treatment Plant
Food Processors
Figure 2 demonstrates the concentration of residual organics or biogenic feedstock in BHE service territory in
existing agricultural digestors, landfills and municipal wastewater treatment plants. The facilities displayed on
this figure have an existing AD system in place. The capture of biogas at a site with an existing AD would be less
costly than building a new digester, but there may be significant capital investments associated with functional
improvements or increased efficiencies.
Most landfills above a certain size will likely have a gas collection system in place; similarly, most wastewater
treatment plants above a certain sizer will have an AD system, but animal feedlots, regardless of size, may or may
not have an AD system in place. The costs related to putting a methane collection system at a landfill or building
an anaerobic digester can vary widely and is not explored in this report. All project economics are based on
capital costs limited to gas upgrading and pipeline injection.
The Final Mile Report | 25
Figure2:ExistingAnaerobicDigestorsinBHEServiceTerritory
CAFO Sites
CAFO, Landfill and WWTP with active AD
Landfill Sites
WWTP Sites
The Final Mile Report | 26
Black Hills Energy and Microsoft - Cheyenne Opportunity
Black Hills Energy (BHE) has led the response from utilities to meet the growing demand for renewable energy from
the tech sector. When Microsoft chose Cheyenne, WY, to site one of its data centers, BHE provided Microsoft the
ability to purchase Renewable Energy Certificates (REC) for 237 megawatt (MW) of wind energy, allowing the data
center in Cheyenne to be powered entirely by wind power12 .
BHE also signed a creative agreement with Microsoft that allows BHE to purchase electricity from Microsoft’s on-site
back-up generation assets to fulfill grid needs during peak demand. By using Microsoft’s back-up generators as a
distributed generation asset feeding power to the grid, BHE is able to not only lower costs for rate payers but also its
overall emissions footprint from power generation.
Microsoft has invested over $15 billion in building one of the world’s largest global cloud infrastructures. Microsoft
hosts over 200 cloud services, including Bing, Office 365, OneDrive, Skype, Xbox Live, etc. with 24x7x365
availability via an infrastructure of globally distributed data centers, networks, and applications and tools13. Microsoft
builds a megawatt of onsite backup generation for every megawatt of grid-supplied electricity consumed at its data
centers14. Currently, this need is met by on-site generators at its Cheyenne facility15.
Microsoft’s dependence on on-site generators for back-up power prevents it from reaching a 100% renewable
target in Cheyenne. Microsoft can potentially exploit local renewable energy resources to bridge the final mile in
renewables and secure renewable power for their back-up generation needs: specifically, it can utilize biogas from
the local wastewater treatment plant to act as the source of renewable power to fulfill the back-up generation needs
of Microsoft’s Cheyenne facility .
Cheyenne Wastewater Treatment Plant
The Cheyenne wastewater treatment plant processes on average 24,573 gallons of wastewater biosolids in its
primary digester/36,922 gallons transferred between primary and secondary digester. The capacity of the AD
system is a combined 1.07 million gallons (both primary and secondary digester are the same size). The facility
produces 378,000 cubic feet of raw biogas per day, which is about 61% methane. Currently, some of the biogas is
compressed and injected into the primary digester to achieve greater mixing and the excess is flared.
Assuming a production rate of 200 MBTUs per day of renewable natural gas at the WWTP, it could supply up to
9.2 million kWh of electricity annually with a generator efficiency rate of 7900 BTUs/kWh.
Table 2: Potential Electricity Provided from the Cheyenne WWTP
Microsoft Data Center Power Consumption
Assuming a server power demand of 7500 kWh/year16 and 100,000 servers in the data center, the total power
demand at the Microsoft Cheyenne facility is 750 million kWh/year. Microsoft offsets 100% of its grid energy
purchases with RECs, to constitute the legal purchase of renewable energy. The data center’s 100% back-up
generation requirement is met by on-site, gas-powered generators. Via displacement, some of this natural gas
consumption can be sourced from the RNG injected into the pipeline at the local WWTP. Having a renewable
natural gas source that supports back-up generation during grid unavailability will make the data center truly
100% renewable.
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73,000 / MMBtus
9,240,506 kWh
Annual Biogas Production
Annual Electricity Production
7,900 BTUs / kWh Heat rate
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The RFS and LCFS programs recognize the principle of displacement – the substitution of a source of natural gas
at one point for another source of natural gas at another point – as an eligible form of transporting the renewable
attributes of the biogas. Therefore, under these programs, RNG can be injected into the natural gas distribution grid
anywhere in the 48 contiguous states to qualify as an eligible renewable fuel as long as equivalent volume of CNG is
used as transportation fuel on the same interconnected distribution grid.
The same principle of displacement can be used to allocate the green attributes of the RNG to back-up power
generation at a data center. A unit of biogas injected into the natural gas pipeline at the Cheyenne WWTP can be
swapped for a unit of natural gas taken out of the pipeline at the data center to power its generating units. Pipeline
injection, therefore, gives the project owner the required flexibility to sell the fuel into multiple markets and even switch
from one market to another as need arises.
Thus, data centers do not have to physically connect the biogas source to their natural gas generators and virtual
swapping will be done in most cases. The volume of gas cannot be double-counted and used as transportation fuel
if it is allocated to power generation. The data center would have the first right to the green attributes for a set volume
of gas.
A high-level income statement for a project injecting 200 MM BTU/day of RNG into the pipeline is provided in
Table 3 on p. 29 or “on the next page”. Three scenarios are offered with conservative, moderate and aggressive
assumptions. The payback periods range from 1-13 years.
In a simple structure, Microsoft could invest about $3-$5 million into a pipeline injection project at the local
wastewater treatment plant and have full rights to the green attributes of the biogas from the project. Assuming
grid availability 99.95% of the time and the purchase of RECs to offset grid electricity purchases, the data center
will only need 14 days of biogas production for its back-up needs from a facility that produces 200 MMBtus/day.
Revenues from the project are from the sales of gas and carbon credits from use of biogas as clean transportation
fuel. This is currently the highest and best use of the biogas. The potential revenues from this project range from
$1 million to $5 million. The actual income will depend on the type of feedstock that is digested, the carbon
footprint of the project and any regulatory variance.
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Table3:ProjectFinancialEstimates
Conservative Moderate AggressiveCapital costsGas clean up $5,000,000 $3,750,000 $2,500,000 Pipeline injection $1,000,000 $750,000 $500,000 Total $6,000,000 $4,500,000 $3,000,000
RevenueValue of carbon credits/MMBTU $12.00 $32.00 $59.00 Annual revenue from credits $989,000 $2,656,000 $4,975,000 Value of natural gas $2.50 $3.00 $3.50 Revenue from gas sales $211,000 $253,000 $295,000 Gross revenue $1,200,000 $2,909,000 $5,270,000
ExpensesOfftake costs (% of revenues) 20% 15% 10%Total offtake agreement costs $(240,000) $(436,000) $(527,000) Operating costs (incl. compliance) $(500,000) $(400,000) $(300,000)
Net operating income $460,000 $2,073,000 $4,443,000 Simple payback years 13 2 1
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Operational costs are primarily electricity, labor and compliance costs and are estimated at $300,000 - $500,000
annually. An additional cost of 10% - 20% of total revenues is allocated for assistance in completing the biogas to
clean transportation pathway: i.e., monetization of the clean transportation fuel credits requires agreements with
consumers of the biogas in a transportation application. This means connecting with compressed natural gas
(CNG) and/or liquefied natural gas (LNG) end users. The cost of securing these offtake agreements can range from
10%-20% of project revenues. Finally, there is a deduction for the biogas that is allocated for the data center’s
back-up needs, which is therefore not used in a transportation application.
The net operating income from such a project ranges from $500,000 to $4 million and the payback periods range
from 1 year to 13 years. Despite the variance between the two ends, current credit pricing and financials of
comparable projects suggest that the moderate scenario, with a payback of 3 years, is achievable. Typical
projects tend to be larger with a biogas output in the 600 – 4,000 MMBtu/day range and they tend to achieve
economies of scale. An 800 MMBtu/day project with $9 million to $13 million in capital costs will have a 5-year
payback under conservative assumptions and a 1-year payback under aggressive assumptions. Each site
feasibility should be evaluated separately.
A slightly more complicated structure would involve the data center offering a minimum floor price for the biogas.
An $0.08/kWh would translate into approximately $10/MMBtu at a 7,900 Btu/kWh heat rate for power
production. A floor price of $10/MMBtu will be triggered if the value of clean transportation fuel credits decline.
Under this scenario, the project will have a guaranteed revenue stream and a maximum 14-year payback, which
may make it eligible for debt financing. In exchange for the guaranteed floor pricing, the data center could require
access to the biogas during grid unavailability and also rights to a portion of the project revenues after the debt is
repaid. Under expected outcomes, the debt could be repaid in 3 years.
These structures can take multiple forms and will need to be evaluated on a case by case basis. Often times,
municipalities are risk adverse and relying on the environmental credit market as the primary source of revenue can
be a deterrent to cities implementing these projects. A floor price backed by a large Fortune 100 company could
function in some fashion as a loan guarantee and provide the assurances to the municipality to move forward with
the project.
Other Environmental Drivers
Biogas utilization is an under-developed niche in America’s rural economy. There are over 12,000 undeveloped
sites which could support biogas production17. It is not uncommon to find biogas sources in rural America and the
Midwest. Wastewater treatment plants, landfills, food processing plants and animal feedlots produce large
volumes of waste organics. Finding a beneficial use for these organics will have multiple environmental and
public benefits.
POTWs and Economic Development
The EPA estimates $271 billion is needed for wastewater infrastructure over the next 25 years18. Investing in AD
and biogas to pipeline projects at public sewage treatment plants are critical investments in the nexus of the
nation’s clean water and clean energy infrastructure.
A robust and reliable municipal wastewater treatment plant is a regional economic development anchor. A
municipal AD system processing industrial waste will spur economic development by providing regional industry a
reliable place to send their wastewater for a low cost; lower wastewater treatment costs will stimulate expansion of
existing industry and recruitment of new industry. Distributed generation of natural gas injected into utility pipelines
also has the potential of creating new pipeline infrastructure in under served regions.
Agricultural Digesters and Nutrient Management
Eutrophication or nutrient over-loading in aquatic ecosystems has been a persistent environmental problem in the
U.S19. Nutrient leached from farmland is one of the key contributors to eutrophication. Winter cover crops and
vegetation strategically planted along riparian buffer zones can effectively mitigate the movement of sediment and
nutrients from farm fields to watersheds. An agricultural digester could create a market for cover crops and
perennial grasses and encourage their planting, which in turn will prevent soil erosion and nutrient loss and
improve watershed quality.
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Agricultural Digesters and Manure Management
Manure digesters are effective manure management systems and can ease environmental and social impacts of
livestock production by reducing odor, eliminating methane releases from lagoons and reducing the pathogen in
waterways from manure application, while still retaining and returning the nutrient value of the manure to
the farmer.
The way in which manure from livestock is managed contributes to greenhouse gas (GHG) emissions. Manure
management accounts for about 15 percent of the total greenhouse gas emissions from the agriculture economic
sector in the United States20. Anaerobic digestion of manure at animal feedlots and methane capture and reuse is
an effective strategy to mitigate the GHG impact of the agricultural sector.
BHE’s service territory (Study Area) spans multiple Midwestern states with concentrations of animal feed lots, food
processing and population centers. All states in BHE territory have commitments to managing the levels of
nutrients in surface waters. The following sections detail the availability of organic biomass and biogas potential in
BHE territory.
Iowa Water-Energy Nexus
In 2015, detailed site analyses were conducted at four sites to evaluate the economics of installing anaerobic
digestion and gas purification units. Two sites were at municipal wastewater treatment plants with large industrial
client bases. One site was dedicated to process industrial waste from two private companies. The last site was an
agricultural digester designed to process animal manure and energy crops.
At each site, the study conducted a detailed wasteshed analysis to determine the organic feedstock that is readily
available to be processed into biogas.
The majority of project revenues are from carbon credits created as a result of regulations governing
transportation fuels in the U.S. and were in direct proportion to the volume of gas produced. The costs did not
show a direct correlation with volume of gas produced due to variable factors, such as ease of co-locating with
existing infrastructure, added costs for biomass processing, access to a pipeline, etc. The boost to regional
economy from investments in new biogas infrastructure and the revenue from ongoing operations was analyzed
using IMPLAN’s I-RIMs model. Average benefits for the municipal-industrial sites are provided below.
• $17.6 million to construct or upgrade an anaerobic treatment facility and gas upgrading
• 462 million BTUs produced per day per site. Average gross annual revenue of $4.3 million
• $158 million per site in total economic output from capital investment and 20-year operations
• 188 jobs created per site during the construction phase
• 9 jobs created per site from the project operations
• $2.7 million increase per site in tax receipts over project life
Due to Iowa’s abundant availability of crop biomass, its potential to grow energy crops and the concentration of
livestock industry in Iowa, this study included an agricultural digester as a potential project type and evaluated its
impact on a rural economy. The agricultural digester also addresses the creation of new markets for
agricultural outputs and suggests a potential solution for non-point source nutrient runoff into Iowa’s watersheds.
The economic benefits from a typical agricultural digester producing 211 million BTUS of bio-methane per day
from manure and energy crops (Miscanthus) were as follows:
• $8.3 million to construct an anaerobic treatment facility and gas upgrading.
• 211 million BTUs per day per site biogas production
• $1.9 million in gross annual revenues from sale of gas and carbon credits from use of biogas as
vehicle fuel
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• $528,000 will annually flow through to Miscanthus suppliers
• $69.5 million in total economic output from capital investment and 20-year project life
• $20 million of the total economic output to the farm economy for Miscanthus cultivation
• 97 jobs created during the construction phase
• 7 jobs created from the project operations and revenues, of which 2 jobs will be dedicated to
Miscanthus cultivation
• $1.6 million increase in tax receipts over project life
The biogas systems have a variety of benefits for local industry and the environment. These can be broken
out into the following general categories:
Infrastructure benefits include:
• Improved waste management systems and distributed energy delivery
• Lower wastewater pre-treatment costs for area food processing industries
• Potential to create superior network of gas pipelines in underserved areas
Economic benefits include:
• Investments in new infrastructure, job creation and money circulation
• Production of high-quality, concentrated, liquid organic fertilizer for improved land management and
increased crop yield
• Reduced operational expenses or increased revenue for livestock producers through the production
and sale of animal bedding
• Reduced trade imbalance from local production of fuel and fertilizer and more efficient application of
nutrients through digestate management
• Lower wastewater treatment costs and resulting expansion of existing industry and recruitment of
new industry
• Increased revenues to farmers from the sale of biomass
Environmental and social benefits include:
• Improved quality of life through superior manure management practices, including reduced odor and
pathogen levels from manure treated through an anaerobic digestion system
• Improved soil and water quality resulting from growing perennial energy crops
• Increased recreational use of the watershed and higher property values from reduced nutrient runoff
• Bio-diversity from planting perennials or native prairie grasses
• Decrease in air pollutants achieved through the end use of Renewable Natural Gas as a substitute
for diesel
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Biogas Potential in BHE Territory The following section details the various facilities with feedstock for potential biogas development. In general, the
highest biogas potential sites in a given area are located near higher population centers. The highest biogas
potential site of the study area is in the Denver metropolitan area, as displayed in Figure 3, with the largest
landfills (based on tonnage) and WWTP (based on millions gallon daily (MGD) flow). CAFO sites are the exception
to this trend, although many CAFO sites are now within a short distance from food processing plants to improve
efficiencies between the growing locations and processing plants.
Figure3:BiogasPotentialinBHEServiceTerritory
Low Potential
Biogas Potential
High Potential
Study Area Population
The study area offers a diverse amount of feedstock for biogas development. Based on 2010 US Census Bureau
data, the study area has a population over 18 million.
Table 4 lists the total population of each state included in the study area. The study area is unique in landforms,
with the Mississippi River on the eastern border and the Rocky Mountains to the west. Population is primarily
centered in large metropolitan areas of Denver, Kansas City, Omaha and Des Moines surrounded by smaller cities
and towns throughout the region. The region is home to three of the ten least populated states in the
United States.
Table 4: 2010 Census State Population
A population break-down of counties, cities and large metro areas within the study area is included in Table 5.
State Total State Population (2010)Arkansas 2,915,918Colorado 5,029,196Iowa 3,046,355Kansas 2,853,118Montana 989,415Nebraska 1,826,341South Dakota 814,180Wyoming 563,626
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Table 5: 2010 Census City/County Population
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State City/County within Study Area County/City
Population (2010)Arkansas Little Rock 193,524
Fort Smith 86,209Fayetteville 73,580
Colorado Denver Metro Area 2,543,482Colorado Springs Metro Area 645,613Fort Collins 143,986
Iowa Des Moines Metro Area 569,633Cedar Rapids Metro Area 257,940Davenport Metro Area 379,690
Kansas Wichita 382,368Johnson/Wyandotte Counties 701,684Topeka 127,473
Montana Billings 104,170Missoula 66,788Great Falls 58,505
Nebraska Omaha/Douglas-Sarpy Counties
675,950
Lincoln/Lancaster County 285,407Grand Island 48,520
South Dakota
Sioux Falls 153,888Rapid City 67,956Aberdeen 26,091
Wyoming Cheyenne 59,466Casper 55,316Laramie 30,816
Biogas Feedstock Sources
The following section lists the total amount of potential biogas production by category and geographic study area.
The complete data set is extracted from ESRI Geodatabases and will have data for each site. The summarized
Excel file will be electronically distributed as well. The tables below summarize the feedstock categories by state.
Each category will be summarized by the “Top 5” for biogas potential within the BHE service territory. Individual
state breakdown of each category with applicable information specific to the waste type are included in
Appendix B.
Animal Feeding Operations
A significant amount of the study area is rural, which leads to a high number of concentrated animal feeding
operations (CAFO) throughout the region. Swine CAFOs dominate the region, with over 10,000 permitted
facilities. The biogas potential is estimated for the permitted facilities and is based on total manure numbers per as
animal provided by the United States Department of Agriculture (USDA). Actual recoverable manure is dependent
on the collection systems in place at the individual facilities. The CAFO sites located in the study area are displayed
in Figure 2 p. 25. The top 5 CAFO locations by biogas potential in the study area are displayed in Table 6. The
summary of permitted CAFO by type and state is listed in Table 7.
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Table 6: Top 5 CAFO by Biogas Potential in Study Area
Facility Name Location Permitted # Biogas Potential Capacity (Mcf)
JBS Five Rivers Cattle Feeding, LLC dba Yuma Feedlot
Yuma, CO 125,150 861,829
Herd Co. Wheeler County, NE
122,425 843,063
JBS Five Rivers Cattle Feeding, LLC dba Kuner Feedlot
Kersey, CO 100,100 689,325
JBS Five Rivers Cattle Feeding, LLC dba Gilcrest Feedlot
LaSalle, CO 100,100 689,325
Sunrise Farms, Inc Harris, IA 80,000 649,790
Table 7: CAFO Type by State in Study Area Facility State State Total # Primary Type (#) Secondary Type (#)Iowa 8,989 Swine (8,069) Beef (392)Kansas 3,635 Beef (2,950) Swine (656)Montana 873 Beef (700) Dairy (91)Nebraska 671 Beef (383) Swine (170)South Dakota 388 Beef (158) Swine (102)Colorado 206 Beef (119) Dairy (63)Arkansas 158 Swine (144) Poultry (9)Wyoming 49 Beef (44) Sheep (4)
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Biodiesel Plants
There are 19 existing biodiesel plants in the study area and 5 plants under construction or proposed. Iowa has the
highest number of existing plants. Ag Pocessing,Inc., located in Algona, Iowa, and FutureFuel Chemical
Company, located in Batesville, Arkansas, have the highest capacities at 60 million-gallons of production per
year. Capacity of production for the top five facilities is displayed in Table 27 (p. 57). Glycerin is a byproduct of the
biodiesel production process and is generated at 0.66 lbs per gallon of biodiesel per published information from
the American Society of Agricultural and Biological Engineers.
Table 9: Top 5 Biodiesel Plants located in Study Area
Facility Name City, State Capacity (in Millions)Ag Processing Inc. Algona, IA 60FutureFuel Chemical Company Batesville, AR 60Cargill Inc. - Iowa Falls Iowa Falls, IA 56Delta American Fuel LLC Helena, AR 40Western Dubuque Biodiesel LLC Farley, IA 33
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Table 8: Concentrated Animal Feeding Operations STATE CAFO # Permitted Animal # Estimated Annual
Biogas Potential (Mcf)Estimated Annual Manure (Tons)
Arkansas 158 1,687,516 640,251 542,109Colorado 206 8,804,766 19,573,870 23,728,414Iowa 8,989 141,319,941 67,986,912 55,975,403Kansas 3,635 9,732,919 58,116,631 80,391,123Montana 873 1,227,976 6,277,945 8,920,028Nebraska 671 32,412,968 33,263,532 42,445,650South Dakota 388 8,770,752 23,204,854 29,573,667Wyoming 49 194,120 986,827 1,374,778
Two additional facilities, with a combined capacity of 110 million gallons/year are under construction by Duonix,
LLC in Beatrice, NE and REG Emporia, LLC in Emporia, KS. Figure 3 displays the location of the biodiesel plants
in the study area.
Ethanol Plants
The study area is home to 108 active ethanol plants and 6 proposed plants. The largest two are the Archer
Daniels Midland Company sites in Cedar Rapids, Iowa and Columbus, Nebraska. Both sites have an annual
capacity of 275 million gallons/year. Table 11 displays the production capacity for the Top 5 sites, by capacity, in
the study area.
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Table 11: Top 5 Ethanol Plants located in Study Area
Facility Name City, State Capacity (in Millions)Archer Daniels Midland Co. - Dry Mill Cedar Rapids, IA 275Archer Daniels Midland Co. - Dry Mill Columbus, NE 275Archer Daniels Midland Co. - Wet Mill Cedar Rapids, IA 240Archer Daniels Midland Co. Clinton, IA 237Cargill, Inc Blair, NE 195
Table 10: Biodiesel Plants located in Study Area
State Plant # Gallons Produced (millions)Arkansas 3 115Colorado 1 11.5Iowa 13 336Kansas 4* 4.7 Active (60 Under Construction)Nebraska 3** 60 Under Construction/Proposed* (1) 60 MMGY Plant Under Construction** (1) 50 MMGY Plant Under Construction, (1) 10 MMGY Plant Proposed
Paper Manufacturers
Paper manufacturing sites typically generate a large amount of waste from the production or recycling processes.
By products will differ depending on the fabrication process and product types manufactured. Due to the large
variety of processes involved, estimates of waste amounts produced is difficult without an in-depth review of site
specifics. Table 13 displays the top 5 facilities in the study area, all of which are located in Arkansas.
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Table 12: Top 5 Ethanol Plants located in Study Are State Plant # Gallons Produced (millions)Colorado 4 153Iowa 48* 4,203 (including 160 proposed gallons)Kansas 14 545.5Montana 1 70 (Proposed) Nebraska 28** 2,083 (including 104 proposed gallons)South Dakota 18*** 1,156.3 (including 120 proposed gallons)Wyoming 1 10* (46) Active, (2) Proposed** (27) Active, (1) Proposed*** (16) Active, (2) Proposed
Table13:Top5PaperManufacturersbyNumberofEmployees Facility Name City, State Type of Production # of EmployeesGeorgia-Pacific Crossett LLC Crossett, AR Paper & Pulp Processing 1,108Evergreen Packaging Group Pine Bluff, AR Bleached Paperboard &
Coated Paper1,100
Domtar Industries, Inc. Ashdown, AR Paper & Pulp Processing 925Vestcom International, Inc. Little Rock, AR Price Labels and Strips 850Kimberly-Clark Corp. Conway, AR Sanitary Paper Products 600Glad Mfg. Company Rogers, AR Plastic Bags & Food Wrap 600Rockline Industries, Inc. Springdale, AR Sanitary Paper Products 600
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Food Processors
Food processing typically produces high-strength wastewater high strength wastewater with associated solids
that require treatment prior to disposal at a wastewater treatment plant (WWTP). Alternatively, processes can be
put in place to redirect this waste for various uses, including feedstock for anaerobic digesters. As a result, the
amount of discharge from various sites can be minimized to potentially reduce the overall cost associated with
wastewater treatment and disposal. Lowering wastewater and solids disposals costs for a food production facility
is a large incentive to participate in a regional AD project. Waste production from food processing varies widely
based on the products being produced, pre-treatment equipment installed, and the size of the facility. Based on
data from previously completed projects, EcoEngineers estimates that a food processing facility will generate 0.3
tons of waste per employee per day, and 109.5 tons of waste per employee per year.
The study area includes 2,466 food processors. Table 6 (p. 40) displays the food processing sites within the
region. Table 15 identifies the top 5 Food Processors, within the study area based on number of employees, and
Table 16 provides information about all facilities according to each state.
Table 14: Paper Manufacturing Sites by State
State Plant # Employees Estimated Annual Biogas Potential (Mcf)
Arkansas 72 12,186 302,240Colorado 46 1,459 36,186Iowa 56 4,251 105,434Kansas 44 3,578 88,742Montana 1 27 670Nebraska 26 2,078 51,539South Dakota 14 1,351 33,508
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Table 15: Top 5 Food Processors in the Study Area Company Name Location # of
Employees
Annual Biogas Potential (Mcf)
Food Category
Tyson Fresh Meats, Inc. Dakota City, NE 4,000 448 Meat ProcessingSmithfield Foods Sioux Falls, SD 3,500 392 Meat ProcessingJBS Grand Island, NE 3,500 392 Meat ProcessingJBS USA Greeley, CO 3,200 358 Meat ProcessingTyson Fresh Meats, Inc. Holcomb, KS 3,100 347 Meat Processing
Table 16: Food Processor Sites by State State Plant # Employees Estimated Annual Biogas Potential (Mcf)Arkansas 254 49,218 5,510Colorado 461 26,593 2,977Iowa 651 58,064 6,500Kansas 372 32,938 3,687Montana 171 2,617 293Nebraska 349 37,603 4,210South Dakota 153 11,465 1,283Wyoming 55 968 108
LandfillWaste
There are 172 active landfill sites within the study area and 76 closed sites. Annual tonnage information, acquired
from the individual state regulatory agencies is displayed in Tables 17 & 18. Landfill tonnage is typically related to
population surrounding the facility. Table 17 lists the top 5 landfill sites according to annual tonnage in 2016. 51
sites currently have a landfill gas (LFG) collection system in place. The location of the landfill sites are displayed in
Table 7 (p. 40).
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Table18:LandfillSitesbyState State Landfill # Active Sites Closed Tonnage (year tonnage)Arkansas 23 19 4 36,129,253*Colorado 61 48 13 25,554,478 (2016)Iowa 50 42 8 2,808,638 (2016)Kansas 52 42 10 1,331,136 (2016)Montana 5 4 1 14,808,713*Nebraska 31 22 9 2,080,933 (2012)South Dakota 15 13 2 281,472 (850,000**)Wyoming 94 57 37 8,028,256**Tonnage in place** Permitted Amount
Table17:Top5LandfillSitesbyAnnualTonnageinStudyArea
Site Name City 2016 Tonnage Owner NameDenver Arapahoe Disposal Site Aurora, CO 6,698,358 City of Denver, COFront Range Landfill Erie, CO 4,888,997 Waste Connections Inc.Tower Landfill Inc Commerce City, CO 2,640,116 Republic Services, Inc.North Weld SLF Ault, CO 1,213,822 Waste Management, Inc.Foothills Landfill Golden, CO 1,099,361 Republic Services, Inc.
Municipal Wastewater Treatment Plants
Municipal Wastewater Treatment Plants (WWTP) provide a consistent waste stream to feed anaerobic
digesters. Sludge and biosolids are byproducts of the aerobic treatment process which are typically dewatered
and land-applied. 127 WWTP sites within the study area have anaerobic digestion systems in place. A direct
relationship exists between the population of an area and the size of the local WWTP plant, as demonstrated by
the highest average flow facilities in the large cities of Denver, Des Moines and Omaha. The average amount of
sludge generated by a WWTP is 0.18 pounds of waste per person per day per recognized engineering data.
Table 19 displays the top 5 WWTP sites within the study area according to average flow in MGD.
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Table 19: Top 5 WWTP ADs in Study Area by Average Flow
Facility Name Facility City Average
Flow MGDDesigned Flow MGD
Metro Wastewater Reclamation District Denver, CO 130 220Des Moines WRA Des Moines, IA 70 134Papillion Creek WWTF – Omaha City Bellevue, NE 60 140Theresa Street WWTP – Lincoln Lincoln, NE 30 35Wichita Lower Arkansas River Plant Wichita, KS 30 54
Table 20: WWTP ADs in Study Area by State State WWTP # w/ AD WWTP # Over Five MGD All Sites Flow Average (MGD)Arkansas 5 3 41Colorado 20 11 246Iowa 52 13 250Kansas 18 5 108Montana 8 4 47Nebraska 7 3 129South Dakota 9 2 41Wyoming 3 2 20.2
Conclusion Local, state, and national governments, as well as large corporations and small businesses are recognizing that
using renewable energy is good business practice. EcoEngineers believes that opportunities exist for the public
and private sectors to implement mutually beneficial solutions that create a bridge for the final mile that leads to
100% renewable energy.
Biogas production from the anaerobic digestion (AD) of residual organic feedstock is an established process and
can be implemented as an effective energy recovery and reuse strategy wherever there are wastewater treatment
plants, landfills and animal feedlots. Methane from biogas can displace fossil natural gas to produce renewable
electricity. Biogas from wastewater treatment plants, landfills and agricultural digesters is a renewable energy
source and can be source fuel for a data center’s back-up generation needs.
Black Hills Energy serves a large portion of the Midwest. Within BHE service area, there are concentrations of crop
and animal agricultural and populations centers with landfills and wastewater treatment plants. These regions have
high biogas potential. Siting corporate operations near some of these sites will provide the company renewable
natural gas to meet its energy requirements.
Biogas pipeline injection projects have strong revenues over the short term due to very attractive prices for clean
transportation fuel credits and short payback periods- usually less than 3 years. A large corporate user could in-
vest in a biogas to RNG project and sell the RNG into the higher value transportation fuel market in the short term.
After the capital costs are recouped, the asset could be repositioned, as needed.
Investing in the wastewater and waste management infrastructure in these communities is an investment in rural
America. These investments go well beyond the immediate benefit of clean fuel production. The overall benefits
of these investments include distributed generation infrastructure, economic development, water and air quality
improvement and job creation. These spread like ripples from the corporate user’s commitment to sustainability.
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Next Steps
• Meeting with large energy users and technology companies to review their overall sustainability goals and
commitment to support rural economic development is the first step in developing a formal strategy to
attract them to site their operations in BHE territory.
• Existing AD systems within BHE territory should be targeted first and feasibility studies conducted for
specific projects. Expanding existing digestion capacity to produce more gas to be reserved for data
center usage may be possible. For regions with high biogas potential, but no AD system, typical costs,
paybacks, and revenues may be significantly different if constructing an AD system is included.
• The strongest potential sites within BHE service territory should be evaluated more closely to measure
all the environmental services that can be provided by a biogas to pipeline project. The environmental
services delivered by these projects are often more valuable than the aggregate green attributes that can
be monetized. Some, such as economic development, may be realized only over a longer term. The full
economic value of biogas to pipeline projects should be measured and quantified.
• Financing a biogas to pipeline project can sometimes be challenging due to the absence of long-term
purchase agreements for clean transportation fuel credits. Debt financing prefers offtake agreements
with secure, minimum revenues over the amortization period. Alternate financing structure and their
applicability to specific situations should be explored further. For example, instead of an outright
investment, a corporate power purchaser could offer a guaranteed floor price for the green attributes of
the biogas in exchange for some value.
• A key next step would be to support the installation of a pilot project to closely study the full
environmental, social and economic impact of Anaerobic Digestion systems. A pilot project will act as a
showcase to attract new customers to this model.
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End Notes
1 https://www.cdp.net/en/campaigns/commit-to-action/price-on-carbon 2 https://info.aee.net/hubfs/PDF/F100_F500.pdf?t=15113901141013 https://www.usclimatealliance.org – includes Colorado in BHE territory4 https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-pathways-ii-final-rule-identify-
additional-fuel5 https://www.arb.ca.gov/fuels/lcfs/lcfs.htm6 Based on GREET models and the LCFS compliance curve7 https://www.infrastructurereportcard.org/wp-content/uploads/2017/01/Wastewater-Final.pdf8 https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions#agriculture9 Assuming a server power demand of 7500 kwh/year and 100,000 servers in the data center11 Landfill biogas potential is based on waste tonnage in place and LFG system collection, as reported to the
USEPA Landfill Methane Outreach Program (LMOP). Animal Feedlot biogas potential is calculated based on
permitted animal head total numbers, as reported by individual state departments of agriculture and USDA
estimates for typical animal weight and percentage of volatile solids by animal type.12 https://blogs.microsoft.com/on-the-issues/2016/11/14/latest-energy-deal-microsofts-cheyenne-datace
ter-will-now-powered-entirely-wind-energy-keeping-us-course-build-greener-responsible-cloud/13 Cloud_Infrastructure_Operational_Excellence_and_Reliability_Strategy_Brief.pdf14 https://www.utilitydive.com/news/how-microsoft-and-a-wyoming-utility-designed-a-data-center-tariff-that
work/430807/15 Microsoft has already implemented a pilot project at the Cheyenne WWTP to generate power from biogas via
fuel cell technology. This report does not include an evaluation of fuel cell technology or a comparison of pipeline
injection versus alternative uses such as fuel cells.16 http://www.zdnet.com/article/toolkit-calculate-datacenter-server-power-usage/17 American Biogas Council18 https://www.infrastructurereportcard.org/wp-content/uploads/2017/01/Wastewater-Final.pdf19 https://oceanservice.noaa.gov/facts/nutpollution.html
20 https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions#agriculture
Appendix A:Energy Generation Data by State in Study Area
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Energy GenerationThe following section focuses on the type of power generation currently utilized in each state and future
development options, including potential renewable resources. The primary source for the information is the U.S.
Energy Information Administration website.
Arkansas
2015 net generation information shows coal, natural gas and nuclear combine for over 90 percent of
non-renewable generation of electricity in Arkansas. Hydroelectric is the primary renewable resource source of
generation, while wood and wood-derived biomass is a fuel source for electric generation.
Arkansas does not have a renewable portfolio standard. The Arkansas Alternative Energy Commission was
established in 2009. The Arkansas Energy Office was directed to develop a plan to reduce energy use in
state-owned facilities by 30% from 2008 levels by 2017. Other initiatives have focused on energy efficiencies by
the state’s investor-owned utilities.
Colorado
2015 net generation information shows coal and natural gas combines for over 80 percent of
non-renewable generation of electricity in Colorado. Wind is the primary renewable resource source of
generation, with over 14% of the state’s production, making it 10th in the country for wind power generation
capacity.
Table 21: Arkansas 2015 Net Generation Non-renewable RenewableCoal Natural
Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
21,740 14,866 13,838 60 3,569 0.9 89 - 54,163 40.1% 27.4% 25.5% 0.1% 6.6% <0.1% <0.2% - 100%
Source: https://www.eia.gov/electricity/state/arkansas/index.php
Renewable energy is considered a key industry in Colorado. In 2004, Colorado became the first state with a
voter-approved renewable portfolio standard (RPS). The legislature has increased requirements several times
since, and the RPS now requires 30% of electricity sold by investor-owned utilities to come from renewable energy
sources by 2020, with 3% from distributed generation. Colorado has negotiated a pioneering agreement with the
U.S. Federal Energy Regulatory Commission to speed the permitting process for low-impact hydropower.
Iowa
2015 net generation information shows coal, nuclear and natural gas combines for approximately 65 percent of
non-renewable generation of electricity in Iowa. Wind power generation accounts for over 30% of the state’s total
energy production, making it second in the United States in total wind energy production. Iowa’s energy policies
and regulations promote energy efficiency and renewable resources. In 1983, Iowa became the first state in the
nation to adopt a renewable portfolio standard (RPS). State regulations required Iowa’s two investor-owned
electric utilities to own or to contract for a combined total of 105 megawatts of renewable generating capacity and
associated production, from facilities approved by the Iowa Utilities Board (IUB). Capacity from eligible renewable
resources has exceeded the RPS goals. In 2008, the IUB, at the direction of the state legislature, established
energy efficiency standards for each regulated electric and natural gas utility in the state. Municipal and
cooperative utilities were required to set their own energy efficiency goals. In addition to energy efficiency
standards, the Mandatory Utility Green Power Option requires all electric utilities operating in Iowa, including those
not rate-regulated by the IUB, to offer renewable-sourced power options to their customers.
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Table 22: Colorado 2015 Net Generation
Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
31,540 11,644 - 7 1,620 251 80 7,475 52,617 59.9% 22.1% - <0.1% 3.1% 0.5% 0.2% 14.2% 100%
Source: https://www.eia.gov/electricity/state/colorado/index.php
Table23:Iowa2015NetGeneration Non-renewable Renewable
Coal Natural Gas NuclearPetroleum Liquids
Conventional Hydroelectric Solar Biomass Wind Total
29,811 2,398 5,243 110 960 - 256 17,872 56,650 52.6% 4.2% 9.3% 0.2% 1.7% - 0.5% 31.5% 100%
Source: https://www.eia.gov/electricity/state/iowa/index.php
The Final Mile Report | 54
Kansas
2015 net generation information shows coal and nuclear combines for approximately 65 percent of non-renewable
generation of electricity in Kansas. Wind accounts for nearly 25% of the state’s total energy production, placing it
in the top five nationally in total wind energy production.
In 2015, the Kansas legislature converted the state’s renewable portfolio standard (RPS), enacted in May 2009,
into a voluntary goal for the state’s investor-owned and cooperative electric utilities. The RPS originally required
electricity providers to obtain 10% of their peak demand capacity from eligible renewable resources from 2011
through 2015, 15% from 2016 through 2019, and 20% each year from 2020 onward. The Kansas RPS is based
on generating capacity rather than retail electric sales.
Technologies that meet the goal include wind, solar thermal and photovoltaic applications; generation fueled by
crops grown for energy production and some agricultural wastes; and hydroelectric facilities of less than 10
megawatts. Additional legislation has established net metering for customers of investor-owned utilities. In 2014,
Kansas legislators reduced the sizes of distributed (customer-sited, small-scale) facilities that are eligible for net
metering and limited net-metered connections to 1% of peak load. Grid-connected distributed facilities may be
counted by electricity providers in meeting the providers’ RPS goal.
Table 24: Kansas 2015 Net Generation Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
24,593 1,174 8,630 49 19 2 62 10,999 45,528 54% 2.6% 19% 0.1% <0.1% <0.1% 0.1% 24.2% 100%
Source: https://www.eia.gov/electricity/state/kansas/index.php
Table 25: Montana 2015 Net Generation*
Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
16,013 599 - 496 9,887 - - 1,965 28,960 55.3% 2.1% - 1.7% 34.1% - - 6.8% 100%
Source: https://www.eia.gov/electricity/state/montana/index.php
Montana
2015 net generation information shows coal accounts for 55 percent of non-renewable generation of electricity in
Montana. Hydroelectric energy production accounts for nearly 35% of the state’s total energy production, placing
it seventh nationally in hydroelectric energy production. Drought conditions in 2015 lowered their
national rankings.
Montana’s renewable resource standard (RRS) requires retail electricity suppliers to get at least 15% of the
electricity they sell in-state from renewable energy sources beginning in 2015. Power must come from renewable
facilities that began operation after January 1, 2005. The RRS recognizes renewable energy from wind, solar,
geothermal, biomass, small hydroelectric facilities, landfill gas, anaerobic digesters, and fuel cells that use
renewable fuels as qualifying renewable resources. The standard requires electricity suppliers to buy a set amount
of power from smaller community-based renewable energy projects.
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Nebraska
2015 net generation information shows coal and nuclear accounts for over 85 percent of non-renewable
generation of electricity in Nebraska. Wind and hydroelectric energy production accounts for approximately 8 and
4 percent of the state’s total energy production, respectively.
Nebraska does not have a renewable energy standard. The state does have a number of renewable energy tax
credits, as well as interconnection and net metering rules for distributed (customer-sited, small-scale) solar
photovoltaics, landfill gas, wind, biomass, hydroelectric, geothermal electric, anaerobic digestion, and small
hydroelectric power generation. Net metered connections are limited to 1% of each utility’s average monthly peak
demand. Nebraska also has a statewide building energy code.
South Dakota
2015 net generation information shows hydroelectric and wind accounts for over 75 percent of total electricity
generation. It is the highest percentage of renewable generation of electricity by state in the study region.
Non-renewable energy sources coal and natural gas make up the remaining 23 percent of the states total
energy production.
In February 2008, South Dakota’s legislature established a voluntary renewable portfolio objective with the goal
of obtaining 10% of all retail electricity sales from renewable and recycled energy sources by 2015. In 2009, the
policy was amended to allow conserved energy as a component. The legislation applied to all retail providers of
electricity in the state.
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Table 26: Nebraska 2015 Net Generation Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
24,185 431 10,325 6 1,684 - 71 3,180 39,882 60.6% 1.1% 25.9% <0.1% 4.2% - 0.2% 8% 100%
Source: https://www.eia.gov/electricity/state/nebraska/index.php
Table 27: South Dakota 2015 Net Generation
Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
1,495 773 - 17 4,851 - - 2,497 9,633 15.5% 8% - 0.2% 50.4% - - 25.9% 100%
Source: https://www.eia.gov/electricity/state/southdakota/index.php
Table 28: Wyoming 2015 Net Generation* Non-renewable RenewableCoal Natural Gas Nuclear Petroleum
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
43,091 722 - 45 868 - - 3,757 48,483 88.9% 1.5% - <0.1% 1.8% - - 7.7% 100%
Source: https://www.eia.gov/electricity/state/wyoming/index.php
Most of the electricity providers in the state have met the goal. Other providers noted barriers that limited their
ability to meet the objective. Those barriers included lack of transmission capacity for renewable projects,
intermittent supply, availability of low-cost natural gas, and physical location. South Dakota has additional
regulatory policies, financial incentives, and technical resources aimed at encouraging energy efficiency and the
expanded use of renewable sources for electricity generation in the state.
Wyoming
2015 net generation information shows coals makes up over 88 percent of total electricity generation. Coal is an
abundant resource in Wyoming, with 8 of the 10 largest U.S. coal mines in the United States. Wind accounts for
over 7 percent of the renewable electricity generation.
The state does not have a renewable portfolio standard or other requirement for renewable energy, but it does
provide net metering for residential, commercial, and industrial customers with renewable energy systems smaller
than 25 kilowatts, including solar photovoltaic panels, wind turbines, biomass plants, and hydroelectric generators.
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* “Other Gases” source generation is 405 (Reported in thousand megawatt hours), which is 0.8% of the total production when included in total production. This includes: blast furnace gas, and other manufactured and waste gases derived from fossil fuels.
The Final Mile Report | 58
Table 29: Study Area 2015 Net Generation
Non-renewable RenewableCoal Natural Gas Nuclear Petro
LiquidsConventional Hydroelectric
Solar Biomass Wind Total
Arkansas 21,740 14,866 13,838 60 3,569 0.9 89 - 54,163 Colorado 31,540 11,644 - 7 1,620 251 80 7,475 52,617 Iowa 29,811 2,398 5,243 110 960 - 256 17,872 56,650 Kansas 24,593 1,174 8,630 49 19 2 62 10,999 45,528 Montana 16,013 599 - 496 9,887 - - 1,965 28,960 Nebraska 24,185 431 10,325 6 1,684 - 71 3,180 39,882 South Dakota 1,495 773 - 17 4,851 - - 2,497 9,633 Wyoming 43,091 722 - 45 868 - - 3,757 48,483
Source: https://www.eia.gov/electricity/
Appendix B:Potential Biogas Feedstock
Table30: CAFO Sites in Study Area
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Concentrated Animal Feeding Operations (CAFO)
CAFO STATE CAFO # Permitted Animal #
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (tons)
Arkansas 158 1,687,516 640,251 542,109.8Colorado 206 8,804,766 19,573,870 23,728,414.3Iowa 8,989 141,319,941 67,986,912 55,975,403.2Kansas 3,635 9,732,919 58,116,631 80,391,123.1Montana 873 1,227,976 6,277,945 8,920,028.5Nebraska 671 32,412,968 33,263,532 42,445,650South Dakota 388 8,770,752 23,204,854 29,573,667.8Wyoming 49 194,120 986,827 1,374,778.5
ArkansasCAFO Type CAFO
Type #Permitted # Estimated Annual Biogas
Potential (Mcf)Estimated Annual Manure (Tons)
Swine 144 265,150 491,252 457,914.1
Chickens 9 1,413,675 129,801 62,435Dairy 8 1,220 20,077 23,725.5Arkansas: Top 5 CAFO by Estimated Biogas PotentialSite Name City Animal
TypePermitted Animals Estimated Annual
Biogas Potential (Mcf)Benton County Foods/Feemster
Siloam Springs
Poultry 525,000 48,205
Puckett, Mike/Redland Farms
Hope Poultry 340,000 31,218
Sandy River Farm Morrilton Swine 11,981 28,529Arkansas Egg Co, INC. Summers Poultry 300,000 27,545McNabb, Michael Hattieville Swine/
Poultry102,800 15,214
ColoradoCAFO Type CAFO
Type #Permitted # Estimated Annual Biogas
Potential (Mcf)Estimated Annual Manure (Tons)
Beef 119 1,706,759 11,753,368 17,046,255.5Dairy 63 256,176 5,478,830 4,981,854.7Swine 17 830,821 1,789,752 1,434,827.9Poultry 7 6,011,010 551,920 265,476.3
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Colorado: Top 5 CAFO by Estimated Biogas PotentialSite Name City Animal Type Permitted Animals Estimated Annual
Biogas Potential (Mcf)JBS Five Rivers Cattle Feeding, LLC dba Yuma Feedlot
Yuma Cattle 125,150 861,829
JBS Five Rivers Cattle Feeding, LLC dba Kuner Feedlot
Weld Cattle 100,100 689,325
JBS Five Rivers Cattle Feeding, LLC dba Gilcrest Feedlot
Weld Cattle 100,100 689,325
Seaboard Foods, LLC-8000
Yuma Swine 287,900 620,193
Murphy-Brown, LLC-7000 Yuma Swine 219,796 473,484
IowaCAFO Type CAFO
Type #Permitted # Estimated Annual Biogas
Potential (Mcf)Estimated Annual Manure (Tons)
Horses 2 1,410 26,988 14,082.4Beef 392 294,959 2,014,672 2,945,903Dairy 215 178,759 2,716,249 3,476,326.3Swine 8,069 25,513,041 52,727,868 44,061,021.8Sheep/Goats 16 10,095 1,227 7,369.4Poultry 179 110,276,999 8,957,118 4,870,383.7Turkeys 116 5,044,678 1,542,790 600,316.7Iowa: Top 5 CAFO by Estimated Biogas PotentialSite Name City Animal Type Permitted Animals Estimated Annual
Biogas Potential (Mcf)Hawkeye Pride Egg Farms, L.l.p.
Corwith Poultry 8,000,000 551,087
Rembrandt Enterprises, Inc.
Thompson Poultry 7,630,000 530,067
Daybreak Foods Eagle Grove Complex
Eagle Grove Poultry 6,801,920 477,850
Center Fresh Egg Farm, Llp
Sioux Center
Poultry 6,784,800 396,892
Southwest Iowa Egg Massena Poultry 6,526,000 202,637
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KansasAnimal Type Farms > 1,000
Head #Animal # from Farms > 1,000 Head
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (Tons)
Beef (Cattle/Calves) 1,724 4,066,974 28,006,674 40,618,902.8Beef (Other Cattle) 1,226 3,459,631 23,824,287 34,553,064.6Dairy 23 104,387 1,717,860 2,030,014Swine 118 1,840,103 3,963,944 3,177,857.9Swine (Breeding) 538* 174,810 574,123 929.1Poultry NA NA** 3,132 NATurkeys 6*** 87,014 26,611 10,354.7Data received from 2012 USDA Ag Census * Total Farms, regardless of population **Estimated 34,000 Layers in 10 Counties ***All farms located in Cherokee County, KSKansas : Top 5 Counties by Estimated Biogas PotentialCounty Name Animal # Estimated Annual Biogas Potential (Mcf)Haskell 795,576 5,478,628Gray 437,307 3,445,994Grant 425,261 2,928,503Finney 399,731 2,753,754Wichita 262,938 1,810,687
MontanaAnimal Type Farms > 1,000
Head #Animal # from Farms > 1,000 Head
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (Tons)
Beef (Cattle/Calves) 491 554,199 3,816,417 5,535,062.5Beef (Other Cattle) 209 308,188 2,122,296 3,078,027.7Dairy 91 8,248 135,734 160,400.5Swine 16 68,413 147,375 118,174.1Swine (Breeding) 25* 9,270 30,445 16,012.7Poultry (Layers) 41** 279,658*** 25,678 12,351.1Data received from 2012 USDA Ag Census * 25 sites with over 100 animals ** Sites with 400 or more ***Total from 208 farms in six countiesMontana : Top 5 Counties by Estimated Biogas PotentialCounty Name Animal # Estimated Annual Biogas Potential (Mcf)Beaverhead 196,881 1,355,795Yellowstone 157,106 1,081,889Custer 141,780 976,349Powder River 80,362 553,402Phillips 62,976 433,676
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NebraskaCAFO Type Farms > 500
Head #Animal # from Farms > 500 Head
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (Tons)
Beef (Cow-Calf) 100* 37,611 259,003 375,643.8Beef (Feeders) 283** 3,601,072 24,798,302 35,965,706.6Other Cattle 4 2,975 20,487 29,712.8125Dairy 45 77,608 1,277,168 1,509,242.8Swine 170*** 1,896,916 4,086,330 3,275,973.9Chickens (Broilers, Pullets)
48 16,833,586 1,545,630 743,455.3
Chickens (Layers) 7**** 8,554,900 845,918 377,827.2Turkeys 14 1,408,300 430,694 168,087.6*100 sites with over 200 animals **283 sites with over 1,000 animals ***170 sites with over 5,000 animals **** Seven sites with over 1,000 animals
Nebraska: Top 5 CAFO by Estimated Biogas PotentialSite Name County
NameAnimal Type Permitted Animals Estimated Annual
Biogas Potential (Mcf)Herd Co Wheeler Beef Cattle 122,425 843,063
Husker Pride Dixon Poultry 6,867,400 679,056Adams Land & Cattle Co South
Custer Beef Cattle 85,000 585,341
North Platte Livestock Feeders
Lincoln Cattle 81,800 563,305
Oppliger Feeders LLC Lincoln Cattle 69,000 475,159
South DakotaCAFO Type Farms > 500
Head #Animal # from Farms > 500 Head
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (Tons)
Beef Cattle 158 516,069 3,553,840 5,154,239.1Dairy 42 121,109 1,993,048 2,355,206.7Swine 102 466,040 1,003,942 804,851.1Chickens 5 3,989,660 366,323 176,203.3Turkeys 1 80,000 24,297 9,520Multiple Animals 80 3,597,874 16,263,404 21,073,647.5*** Biogas Potential based on 128m3 per animal **Estimated Annual Manure (lbs) based on 11,714 per animal
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South Dakota – Top 5 CAFO by Estimated Biogas PotentialSite Name County Name Animal Type Permitted Animals Estimated Annual Biogas
Potential (Mcf)Spring Creek Colony McPherson Multiple 221,225 999,999Spring Lake Colony Kingsbury Multiple 175,114 791,565Platte Colony Charles Mix Multiple 120,208 543,374White Rock Colony Roberts Multiple 96,028 434,074New Elm Springs Colony
Hutchinson Multiple 95,576 432,030
WyomingCAFO Type Farms > 500
Head #Animal # from Farms > 500 Head
Estimated Annual Biogas Potential (Mcf)
Estimated Annual Manure (Tons)
Beef Cattle 44 132,120 909,827 1,319,548.5Swine 1 10,000 21,542 17,270Sheep 4 52,000 55,458 37,960Wyoming : Top 5 CAFO by Estimated Biogas PotentialSite Name County
NameAnimal Type Permitted Animals Estimated Annual
Biogas Potential (Mcf)Dinklage Feed Yard, Inc. Torrington Beef Cattle 27,000 191,415Fornstrom, Leonard A. Pine Bluffs Beef Cattle,
Sheep33,500 121,487
Burnett Land and Livestock, LTD, LLP
Carpenter Beef Cattle 10,000 70,894
Washakie Feeders, Inc. Worland Beef Cattle, Sheep
9,000 56,071
Griemsman Livestock, LLC, a Wyoming Limited Liability Company
Worland Beef Cattle 7,000 49,684
Table31:BiodieselPlantslocatedinStudyArea
Facility Name City, State Capacity (in Millions)Ag Processing Inc. Algona, IA 60FutureFuel Chemical Company Batesville, AR 60Cargill Inc. - Iowa Falls Iowa Falls, IA 56Delta American Fuel LLC Helena, AR 40Western Dubuque Biodiesel LLC Farley, IA 33
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Table32:Top5EthanolPlantslocatedinStudyArea
Facility Name City, State Capacity (in Millions)Archer Daniels Midland Co. - Dry Mill Cedar Rapids, IA 275Archer Daniels Midland Co. - Dry Mill Columbus, NE 275Archer Daniels Midland Co. - Wet Mill Cedar Rapids, IA 240Archer Daniels Midland Co. Clinton, IA 237Cargill, Inc Blair, NE 195
Table33:PaperManufacturersinStudyArea
Paper ManufacturersArkansas : Top 5 Paper Manufacturers by Number of Employees 72 paper manufacturing sites in ArkansasFacility Name City, State Type of Production # of EmployeesGeorgia-Pacific Crossett LLC
Crossett, AR Paper & Pulp Processing 1,108
Evergreen Packaging Group Pine Bluff, AR Bleached Paperboard & Coated Paper
1,100
Domtar Industries, Inc. Ashdown, AR Paper & Pulp Processing 925Vestcom International, Inc. Little Rock, AR Price Labels and Strips 850Kimberly-Clark Corp. Conway, AR Sanitary Paper Products 600Glad Mfg. Company Rogers, AR Plastic Bags & Food Wrap 600Rockline Industries, Inc. Springdale, AR Sanitary Paper Products 600
Colorado: Top 5 Paper Manufacturers by Estimated Biogas Potential46 paper manufacturing sites in ColoradoFacility City Type of Production # of EmployeesPacking Corporation of America – Denver East
Denver, CO Corrugated Boxes 150
International Paper Wheat Ridge, CO Corrugated Boxes 130All Packaging Co. Aurora, CO Paperboard Cartons 125High Country Container Denver, CO Corrugated Boxes 115Packaging Corporation of America - Denver
Denver, CO Corrugated Boxes 100
International Paper Co. Golden, CO Corrugated Boxes 100
Iowa: Top 5 Paper Manufacturers by Estimated Biogas Potential56 paper manufacturing sites in IowaFacilities City Type of Production # of Employees3M Co. Knoxville, IA Industrial Tapes 550Coveris Sibley, IA Bags: uncoated paper 300Bemis Co., Inc Centerville, IA Bags: plastics, laminated 250WestRock Co. Clinton, IA Corrugated Boxes 227International Paper Cedar Rapids, IA Paper Mills 210
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Kansas: Top 5 Paper Manufacturers by Estimated Biogas Potential44 paper manufacturing sites in KansasFacilities City Type of Production # of EmployeesHuhtamaki Americas, Inc. DeSoto, KS Converted Paper Products 350Stouse, Inc. New Century, KS Paper coated and laminated 331Pitt Plastics, Inc. Pittsburg, KS Bags: plastics 320Lawrence Paper Company Lawrence, KS Corrugated Boxes 300Envision Industries, Inc. Wichita, KS Bags: plastics 263
Montana: Paper Manufacturers by Estimated Biogas Potential1 paper manufacturing site in MontanaFacilities City Type of Production # of EmployeesMontana Container Corp. Bozeman, MT Corrugated Boxes 27
Nebraska: Paper Manufacturers by Estimated Biogas Potential26 paper manufacturing sites in NebraskaFacilities City Type of Production # of EmployeesMalnove, Inc. Omaha, NE Boxes – Folding Paperboard 260Midlands Packaging Corp. Lincoln, NE Boxes – Folding Paperboard 170Cenveo, Inc. Omaha, NE Paper coated and laminated 168FLEXcon Company, Inc. Columbus, NE Paper coated and laminated 160PaperWorks Packaging Group Hastings, NE Corrugated Boxes 150
International Gamco, Inc. Omaha, NE Paper Mills 150Packaging Corp. of America Omaha, NE Corrugated Boxes 150
South Dakota: Paper Manufacturers by Estimated Biogas Potential14 paper manufacturing sites in South DakotaFacilities City Type of Production # of EmployeesBell, Inc. Sioux Falls, SD Paperboard Mills 300Graphic Packaging Interna-tional Mitchell, SD Boxes – Folding Paperboard 230
Berry Plastics Sioux Falls, SD Bags: plastics 220WestRock Co. Sioux Falls, SD Corrugated Boxes 135Cimarron Label Sioux Falls, SD Paper coated and laminated 100
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Table 34: Food Processors in Study Area
Food ProcessorsArkansas : Top 5 Food Processors by Number of Employees254 food processor sites in ArkansasCompany Name City Food Category # of EmployeesTyson Foods, Inc. Springdale, AR Poultry Processing 3,000Pilgrim’s Pride Corp. De Queen, AR Poultry Processing 1,450Tyson Foods, Inc. Berryville, AR Poultry Processing 1,445ConAgra Foods, Inc. Russellville, AR Frozen Specialties 1,400Cargill Turkeys & Cooked Meats
Springdale, AR Turkey Processing 1,400
Tyson Foods, Inc. Clarksville, AR Poultry Processing 1,400McKee Foods Corp. Gentry, AR Snack Cakes & Granola Bars 1,400Tyson Foods, Inc. Green Forest, AR Poultry Processing 1,400
Colorado: Top 5 Food Processors by Number of Employees 461 food processor sites in Colorado Company Name City Food Category # of EmployeesJBS USA Greeley, CO Meat Packing Plant 3,200Cargill Meat Solutions Fort Morgan, CO Meat Packing Plants 2,000Steven Roberts Original Desserts Aurora, CO Cakes and Cookies 800
Anheuser-Busch Inbev Fort Collins, CO Beer 700
Pepsi Beverages Co. Denver, CO Bottled and Canned Soft Drinks 650
Iowa : Top 5 Food Processors by Number of Employees 651 food processor sites in Iowa Company Name City Food Category # of EmployeesTyson Fresh Meats Waterloo, IA Meat Processing 2,700JBS Ottumwa, IA Meat Processing 2,400JBS USA Marshalltown, IA Meat Processing 2,300Tyson Fresh Meats Storm Lake, IA Meat Processing 1,850Kraft Heinz Foods Co. Davenport, IA Meat Processing 1,700
Kansas: Top 5 Food Processors by Number of Employees 372 food processor sites in Kansas Company Name City Food Category # of EmployeesTyson Fresh Meats, Inc Holcomb, KS Meat Processing 3,100National Beef Packing, Co. Dodge City, KS Meat Processing 3,000National Beef Packing, Co. Liberal, KS Meat Processing 3,000Cargill Meat Solutions Dodge City, KS Meat Processing 2,400SFC Global Supply Chain Salina, KS Frozen Specialties 1,300
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Montana: Top 5 Food Processors by Number of Employees 171 food processor sites in Montana Company Name City Food Category # of EmployeesSidney Sugars Inc. Sidney, MT Beet Sugar 245Wheat Montana Bakery Three Forks, MT Bread, Cake and Related
Products180
Daily Premium Meat Missoula, MT Meat Processing 109Western Sugar Co-Op Billings, MT Beet Sugar 100Pasta Montana Great Falls, MT Pasta 90
Nebraska : Top 5 Food Processors by Number of Employees 349 food processor sites in Nebraska Company Name City Food Category # of EmployeesTyson Fresh Meats, Inc. Dakota City, NE Meat Processing 4,000JBS Grand Island, NE Meat Processing 3,500Tyson Fresh Meats, Inc. Lexington, NE Meat Processing 2,300Cargill Meat Solutions Schuyler, NE Meat Processing 2,200Smithfield Farmland Corp. Crete, NE Meat Processing 2,150
South Dakota: Top 5 Food Processors by Number of Employees 153 food processor sites in South DakotaCompany Name City Food Category # of EmployeesSmithfield Foods Sioux Falls, SD Meat Packing Plants 3,500Link Snacks, Inc. Alpena, SD Meat Packing Plants 997Dakota Turkey Growers Huron, SD Poultry Slaughtering and
Processing974
Tyson Fresh Meats Dakota Dunes, SD Poultry Slaughtering and Processing
650
Interbake Foods, LLC North Sioux City, SD Cookies and Crackers 500
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Wyoming: Top 5 Food Processors by Number of Employees 55 food processor sites in WyomingCompany Name City Food Category # of EmployeesAdmiral Beverage Corp Worland, WY Bottled / Canned Soft Drinks 300Western Sugar Co-Op Lovel, WY Beet Sugar 110Snake River Brewing Jackson, WY Malt Beverages 85Wyoming Sugar Company Worland, WY Sugar Processing 50Hi Mountain Jerky, Inc Riverton, WY Food Seasonings 40
Table35:FoodProcessorCategoriesintheStudyArea
Food Processing Category # of Sites Food Processing Category # of Sites
Feeds - Prepared 504 Dry/condensed/evaporated 21Meat Packing 493 Dehydrated Fruits, vegetables 21Malt / Malt beverages 136 Liquors 20Wines / brandy / brandy spirits 108 Frozen Specialties 19Flour and Grain Mill Products 108 Flavoring extracts and syrups 19Bread, cake and related products 103 Chocolate 18Poultry 81 Wet corn milling 18Sausages / Prepared Meats 65 Flour Mixes 16Bottled / Canned Soft drinks 61 Cookies and Crackers 15Dog/cat food 51 Nuts/seeds 14Candy 44 Cereal Breakfast Foods 10Coffee-roasted 42 Fish - Fresh/Frozen 7Canned Fruits and vegetables 36 Canned Specialties 7Soybean Oil Mills 36 Fats and Oils – Edible 6Ice 32 Macaroni 6Milk 29 Fruits and Vegetables – Frozen 6Potato chips 28 Butter 4Rice Milling 25 Bakery Products – Frozen 4Ice Cream 24 Sugar Refining / Raw Cane 3Fats and Oils - Animal and Marine 22 Cottonseed Oil Mills 3Cheese 22 Fish and Seafood – Canned 2Pickles/sauces/salad dressing 22 Vegetable Oil Mills 2
Table 36: Landfills in Study Area
LandfillsLandfill State Total Landfill # Active Sites Tonnage (year tonnage)Arkansas 23 19 36,129,253*Colorado 61 48 25,554,478 (2016)Iowa 50 42 2,808,638 (2016)Kansas 52 42 1,331,136 (2016)Montana 5 4 14,808,713*Nebraska 31 22 2,080,933 (2012)South Dakota 15 13 281,472 (850,000**)Wyoming 94 57 8,028,256**Tonnage in place** Permitted Amount
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Arkansas: Top 5 Landfills by Tonnage Site Name City Tonnage Owner NameTwo Pines Landfill – Phase 1 (Closed) North Little Rock, AR 8,910,336 Waste Management, Inc.
Fort Smith SLF Fort Smith, AR 8,552,007 City of Fort SmithModelfill Landfill Little Rock, AR 4,403,751 Republic Services, IncTontitown Landfill Springdale, AR 3,500,000 Waste Management, Inc.Rolling Meadows Landfill Hazen, AR 3,000,000 WCA Waste Corporation
Colorado: Top 5 Landfills by Tonnage Site Name City 2016 Tonnage Owner NameDenver Arapahoe Disposal Site Aurora, CO 6,698,358 City of Denver, CO
Front Range Landfill Erie, CO 4,888,997 Waste Connections Inc.Tower Landfill Inc Commerce City, CO 2,640,116 Republic Services, Inc.North Weld SLF Ault, CO 1,213,822 Waste Management, Inc.Foothills Landfill Golden, CO 1,099,361 Republic Services, Inc.
Iowa: Top 5 Landfills by Tonnage Site Name City Tonnage* Owner NameMetro Park East Landfill Mitchellville, IA 589,948 Metro Waste AuthorityCedar Rapids Linn County SWLF #2 Marion, IA 185,019 Cedar Rapids - Linn County
SWABlack Hawk County SLF Waterloo, IA 169,284 Black Hawk County SWMC
Scott Area SLF Davenport, IA 161,190 Waste Commission of Scott County
Loess Hills Regional SLF Malvern, IA 145,866 Iowa Waste Systems* Tonnage from 2016 Iowa DNR Solid Waste Report
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Kansas: Top 5 Landfills by TonnageSite Name City 2016 Tonnage Owner NameJohnson County Landfill Shawnee, KS 1,052,923 Deffenbaugh Industries, Inc.Seward County Landfill Liberal, KS 88,939 Seward County, KansasSalina MSWLF Salina, KS 57,554 City of Salina, KansasAllen County LF La Harpe, KS 27,928 Allen County, KansasBarton County LF Great Bend, KS 25,238 Barton County, Kansas
Nebraska: Top 5 Landfills by TonnageSite Name City 2015 Tonnage Owner NameDouglas County – Pheas-ant Point Bennington, NE 482,237 Waste Management, Inc.
Butler County Landfill David City, NE 397,462 Waste Connections Inc.Bluff Road Landfill Lincoln, NE 328,488 City of LincolnL.P. Gill Landfill Jackson, NE 234,252 L.P. GillSarpy County Landfill Springfield, NE 209,843 Sarpy County, Nebraska
South Dakota: Top 5 Landfills by TonnageSite Name City Tonnage Owner NameSioux Falls Regional SLF Hartford, SD 10,180,000 City of Sioux Falls, SDRapid City Landfill Rapid City, SD 3,000,000 City of Rapid City, SDCity of Mitchell Landfill Mitchell, SD 746,864 City of Mitchell, SDWatertown Regional Landfill Watertown, SD 486,908 City of Watertown, SD
Brookings Landfill Brookings, SD 322,471 City of Brookings, SD
Wyoming: Top 5 Landfills by TonnageSite Name City Tonnage Owner NameCheyenne Landfill Cheyenne, WY 4,189,263 City of Cheyenne, WYCasper Balefill Casper, WY 3,438,356 City of Casper, WYSheridan Landfill Sheridan, WY 400,637 City of Sheridan
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Table37:WastewaterTreatmentPlantsinStudyArea
Wastewater Treatment PlantsWWTP State WWTP #
w/ AD
WWTP # Over Five MGD All Sites Flow Average (MGD)
Arkansas 5 3 41Colorado 20 11 246Iowa 52 13 250Kansas 18 5 108Montana 8 4 47Nebraska 7 3 129South Dakota 9 2 41Wyoming 3 2 20.2
Arkansas : Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDFayetteville – Westside WWTP
Fayetteville, AR 12 16
Hot Springs Regional WWTP
Hot Springs, AR 12 16
Little Rock – Fourche Creek WWTP
Little Rock, AR 11.5 12
Stone Dam Creek WWTP Conway, AR 4 6City of Decatur Decatur, AR 1.6 2.2
Colorado: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDMetro Wastewater Reclamation District Denver, CO 130 220
Littleton/Englewood WWTP Englewood, CO 22 50
Drake WRF Fort Collins, CO 14 23City of Boulder WWTF Boulder, CO 13 25James R Dilorio WRF Pueblo, CO 11 19
Iowa: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDDes Moines WRA Des Moines, IA 70 134Davenport WWTP Davenport, IA 25 26Dubuque Water Recovery Center
Dubuque, IA 14 40
City of Sioux City STP Sioux City, IA 13 30City of Waterloo WMS Waterloo, IA 13 47.1
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Montana: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDBillings WWTP Billings, MT 14.38 26City of Great Falls Great Falls, MT 11.4 21Missoula WTF Missoula, MT 8 12Bozeman WWTP Bozeman, MT 5.5 8.5City of Helena WWTF Helena, MT 3 5.4
Nebraska: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDPapillion Creek WWTP – Omaha
Bellevue, NE 60 140
Theresa Street WWTP Lincoln, NE 30 35Missouri River WWTP Omaha, NE 27 132Fremont WWTP Fremont, NE 4.5 20Hastings Utilities Hastings, NE 4.5 4
South Dakota: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDSioux Falls Water Reclamation
Sioux Falls, SD 15 30
Rapid City Water Reclamation
Rapid City, SD 9.5 15
Aberdeen WWTF Aberdeen, SD 4 9Watertown WWTF Watertown, SD 3.99 4Brookings Municipal Utilities
Brookings, SD 3 6
Gillette WWTF Gillette, WY 3.2 5.2
Wyoming: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDCheyenne Dry Creek WTP Cheyenne, WY 9.5 17Casper Regional WWTP Casper, WY 7.5 10Gillette WWTF Gillette, WY 3.2 5.2
Kansas: Top 5 WWTP by Average Flow (MGD)Facility Name Facility City Average Flow MGD Designed Flow MGDWichita Lower Arkansas River Plant
Wichita, KS 30 54.4
Kansas City WWTP #1 Kansas City, KS 25 50Topeka Oakland WWTP Topeka, KS 12 16Lawrence WWTP Lawrence, KS 7 12.5Hutchinson WWTP Hutchinson, KS 4.1 8.3
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The information contained in this report provides general guidance on matters discussed. The interpretation and application of environmental regulations are subject to specific facts involved. Given the changing nature of these regulations and the unique set of facts related to each project, there may be inconsistencies between the information contained in this report and a specific interpretation or application of a rule at a specific site by a federal or state agency. While we have made every attempt to ensure that the information contained in this report is accurate and reliable, EcoEngineers is not responsible for any errors or omissions, or for the results obtained from the use of this information. The information on this report is provided with the understanding that the authors are not herein engaged in rendering legal, accounting, tax, or other professional advice and services. As such, it should not be used as a substitute for consultation with professional accounting, tax, legal or other competent advisers.