National Water Reuse Action Plan Marks One Year of Advancing Water Recycling
Date: March 01, 2021
February 27, 2021 marked the one-year anniversary of the release of the national Water Reuse Action Plan (WRAP). The draft WRAP was...
Date: June 08, 2020
It’s often said that accounting is the language of business. Climate risk is forcing many companies to become bilingual.
That second language that executives need to learn? Sustainability.
Back in January, BlackRock CEO Larry Fink told clients that “risks presented by climate change are set to accelerate a significant reallocation of capital, which will in turn have a profound impact on the pricing of risk and assets around the world.”
In other words, BlackRock, the largest investment management company in the world with $6.2 trillion in assets under management, will be taking a hard look at sustainability when determining where to invest.
Fink’s comments are set to accelerate existing trends in corporate sustainability. But the trend toward a focus on sustainability hasn’t been universal. Some companies are on their third or fourth generation of sustainability planning, while others have yet to implement a program. The companies that have tried to address sustainability have tended to focus on power consumption over water usage – in part because of the connection between electricity usage, greenhouse gas emissions, and climate change.
Increased urbanization has stressed regional water basins, and the impacts of climate change are leading to seasonal fluctuations in water availability, if not outright scarcity. That makes water sustainability more critical than ever. Unfortunately, sustainability program managers, in many cases, aren’t prepared to tackle water challenges.
With that in mind, I want to discuss some of the key topics that executives will confront when setting sustainability goals for water.
Companies in the early stages of water sustainability should begin by launching the broadest data gathering program they can manage.
The focus shouldn’t only be on water usage. Other factors like revenue and production at various facilities should also be considered, as well as the levels of water stress in the surrounding areas where facilities are located.
At any reasonably-sized company, there will be some surprises. Many facilities that draw water directly from a local source may not be required to meter their water usage; often the only material cost associated with extracting and consuming water from these sources is the energy needed to convey it. These circumstances present challenges that make it more difficult to establish the all-important baselines.
Because sustainability means different things to different companies based on their operations and products manufactured, gathering data shouldn’t happen in a vacuum. There are several ways to assess water usage. In fact, the ultimate goals of a sustainability program might not be entirely clear until data collection has begun and its results have been digested.
Regulatory requirements for US-based publicly traded companies exist to ensure financial reporting obligations are performed in a transparent manner (e.g., 10-K reporting). In contrast, corporate sustainability reporting does not have the same obligations. For the most part, sustainability reporting is voluntary, creating a significant variation among reports.
My former GE colleague, Kris Morico, who now specializes in helping companies establish sustainability footprints at Jacobs Engineering, characterized some of these apparent reporting variations.
“I used to teach an environmental leadership class at Yale. One of the assignments I gave asked students to pick a company, any company, and study its corporate sustainability reports and other publicly available financial disclosures. Every year, students would be surprised at the inconsistencies in the reports and would share examples of how companies’ goals and criteria changed year to year. For example, a company may include criteria about what counts toward a sustainability water goal one year, then completely omit that information the following year.”
When launching a water sustainability program, think carefully about what and how you will report your results. Investors are unlikely to give credit for sustainability if it is not reported in a consistent and transparent manner.
Determination of a water sustainability goal varies based on the industrial sector. For example, it might make the most sense for a car manufacturer to look at water use per each car produced. A diversified conglomerate, however, likely has no common denominator for water use since its products vary. Consequently, it might want to select an absolute water use reduction metric company wide.
Sustainability reporting by industries, Morico says, will continue to become more transparent and rigorous with both its criteria for establishing sustainability goals and subsequent performance tracking, with a greater emphasis on reporting quality.
“It’s okay if your water usage goes up year-over-year, but you are going to have to be able to explain that — perhaps it’s the result of an acquisition or some other plausible reason,” Morico said. “But it’s going to take some thinking at the outset about how they want to report so it is transparent to the reader.”
There are some existing resources for setting data parameters, including the Water Disclosure Project, Global Reporting Initiative and the Sustainability Accounting Standards Board, but the standards continue to be a work in progress. Industry associations and even shop talk between competitors can also help when setting data parameters for your program.
One of the biggest questions confronting sustainability teams is how to make sustainability goals meaningful.
There are reputational factors involved. Set a goal too low and it looks like you aren’t really trying. Set it too high and you risk missing your target. In practice, you don’t know what you can and can’t do without a little bit of investigation first.
Companies in the early stages of water sustainability planning may find some very low hanging fruit, such as leaky pipes or slightly opened valves, which can be discovered easily using portable water monitoring devices. Fixing leaks or closing valves are simple adjustments that can result in a sizeable return on investment (ROI). Additionally, deploying a diverse team of operations and engineering staff to review water use at facilities can help identify immediate reduction opportunities, such as water-intensive machinery that is left on, as well as future opportunities to use recycled water at a facility.
Mature companies that are on their third of fourth generation of sustainability goals might find big gains harder to achieve. These companies might want to use kaizen teams that take a multidisciplinary approach to looking at water reduction possibilities from every angle and strive for continuous improvement. And in many cases, companies will want to achieve water sustainability results that go beyond their own fences, positively impacting the local communities where companies operate.
Water is an integral part of global business, used in everything from industrial cooling to agriculture and beyond.
Water isn’t just necessary to support human life, it also supports the global economy. And that’s the broader message underlying Fink’s position on sustainable investing. A deteriorating environment creates an unpredictable business climate. The big challenge over the next few years will be to implement sustainability goals that are meaningful, transparent, intentional, and to some degree, standardized in a way that investors and stakeholders can understand and act on.
National Water Reuse Action Plan Marks One Year of Advancing Water Recycling
Date: March 01, 2021
February 27, 2021 marked the one-year anniversary of the release of the national Water Reuse Action Plan (WRAP). The draft WRAP was...
Date: January 31, 2021
The Project WET Foundation and the WateReuse Association announce the release of a new Water Reuse booklet that introduces students...
WateReuse Members Profiled in EPA Water Workforce Compendium
Date: January 29, 2021
The U.S. Environmental Protection Agency (EPA) is showcasing the successes of several WateReuse Association members in recruiting and retaining a...
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West Virginia Department of Environmental Protection’s Water and Waste Regulations | West Virginia West Virginia Department of Environmental Protection
Washington State Department of Ecology, Reclaimed Water | Washington Washington State Department of Ecology
Reclaimed Water Use (Revised Code of Washington §90.46.005) | Washington State Legislature
Virginia State Law, Treatment and Standards for Reclaimed Water | Virginia Virginia State Law
Virginia State Law, Minimum Standard Requirements for Reuses of Reclaimed Water | Virginia Virginia State Law
Use of Reclaimed Water (Texas Administrative Code §30.1.210) | Texas Administrative Code
30 Texas Administrative Code Chapter 210- Use of Reclaimed Water | Texas Commission on Environmental Quality
30 Texas Administrative Code Chapter 321, Subchapter P | Texas Administrative Code
Texas Commission on Environmental Quality. §5.102 | Texas Administrative Code
Texas Commission on Environmental Quality. §26.011. | Texas Administrative Code
2015 South Carolina Plumbing Code- Chapter 13 Nonpotable Water Systems | South Carolina Plumbing Code
Oregon Department of Environmental Quality, Water Reuse Program | Oregon Department of Environmental Quality
Oregon Water Resources Department, Municipal Water Reuse | Oregon Water Resources Department
Recycled Water Use Rules (Oregon Administrative Rules 340-055-0005) | Oregon Department of Environmental Quality
3701-29-17 Gray water recycling systems and alternative toilets. | Ohio Administrative Code
North Dakota Water Commission, North Dakota State Policy/Procedure for Transfer and Reuse of Wastewater | North Dakota Water Commission
Local Water Supply Plans (General Statutes of North Carolina §143-355) |
New York Environmental Protection Department, Water Reuse Program | New York Environmental Protection Department
New York Environmental Protection Department, Water Reuse Guide 2018-2019 | New York Environmental Protection Department
New Mexico Energy, Minerals and Natural Resources Department, Oil and Gas Extraction Wastewater Management | New Mexico Energy, Minerals and Natural Resources Department
New Mexico Environment Department, Water Resources & Management | New Mexico Environment Department
Water Project Finance Section; Implementation of state water plan (New Mexico Statutes §72-4A-9) | New Mexico Statutes
Water Conservation Plans; municipalities, counties and water suppliers. (New Mexico Statutes §72-14-3.2) | New Mexico Statutes
State Water Plan Authorization (New Mexico Statutes §72-14-3.1) | New Mexico Statutes
New Hampshire Department of Environment Services, Land Treatment and Disposal of Reclaimed Wastewater: Guidance for Groundwater Discharge Permitting | New Hampshire Department of Environment Services
Advancing Safe and Sustainable Water Reuse in Minnesota -2018 Report of the Interagency Workgroup of Water Reuse | Minnesota Department of Health
Minnesota Pollution Control Agency – Municipal Wastewater Reuse Fact Sheet | Minnesota Pollution Control Agency
Massachusetts Department of Environmental Protection, Massachusetts Reclaimed Water Information | Massachusetts Department of Environmental Protection
Department of the Environment, Water Reuse Initiative | Maryland Department of the Environment
Department of the Environment, Maryland Water Reuse Laws, Regulation, and Guidelines | Maryland Department of the Environment
Department of the Environment, Water Reuse General Background Information
Kansas Water Office, Non-Traditional Sources and Uses of Water-Reuse | Kansas Water Office
567 Iowa Administrative Code Chapter 62: Effluent and Pretreatment Standards: Other Effluent Limits or Prohibitions | Iowa Department of Environmental Protection
Recycled Water Rules (Idaho Administrative Code 58.01.17)| Idaho Department of Environmental Quality
Florida Department of Environmental Protection, Florida’s Reuse Program | Florida Department of Environmental Protection
Study on the expansion of use of reclaimed water, stormwater, and excess surface water (Florida Senate Bill 536 (2015)) | Florida Department of Environmental Protection
Sewage disposal facilities; advanced and secondary waste treatment. (Florida Statutes §403.086)| Florida Department of Environmental Protection
Reuse of reclaimed water (Florida Statutes §403.0645)| Florida Department of Environmental Protection
Reuse of reclaimed water (Florida Statutes §373.250) | Florida Department of Environmental Protection
Reuse Feasibility Studies (Florida Administrative Code 62-610.820) | Florida Department of Environmental Protection
Required and optional elements of comprehensive plans (Florida Statutes §163.3177) | Florida Department of Environmental Protection
Connecticut Department of Energy and Environmental Protection, 2014 State of Connecticut Water Reuse Bill | Connecticut Department of Energy and Environmental Protection
Regulation No. 84 – Reclaimed Water Control Regulation | Colorado Department of Public Health and Environment, Water Quality Control Commission
Use of Recycled Water; Reclaimed Water Quality Standards (Arizona Administrative Code §18-9-7) | Arizona Department of Environmental Quality
Arizona Administrative Code Title 18, Chapter 9, Article 7. Use of Recycled Water. | Arizona Department of Environmental Quality
Arizona Administrative Code Title 18, Chapter 11, Article 3. Reclaimed Water Quality Standards. | Arizona Department of Environmental Quality
Reclaimed Water Reuse Program Chapter 335-6-20 | Alabama Department of Environmental Management
Regulations Related to Recycled Water | State Water Resources Control Board
Surface Water Augmentation Regulations (California Code of Regulations Title 22 § 60301.170) | State Water Resources Control Board
Model Water Efficiency Landscape Ordinance (California Code of Regulations Title 23 §490-495)
Water Quality Control Policy for Recycled Water | State Water Resources Control Board
Water Management Planning | Assembly Bill (AB) 1668 and Senate Bill (SB) 606-May 31, 2018