Holmes Road Landfill, Houston, TX: A U.S. EPA Brownfields Sustainability Pilot 1

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1 Holmes Road Landfill, Houston, TX: A U.S. EPA Brownfields Sustainability Pilot 1 By Christopher De Sousa and Lily-Ann D Souza SITE HISTORY T he US Environmental Protection Agency (EPA) defines a brownfield as real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant." 2 In this regard, redeveloping a landfill requires careful consideration to avoid a) disturbing the layer of soil that seals, or caps, the waste area, and b) the uneven settlement of the landfill surface area due to the settlement of waste material below the cap. 3 As such, the Holmes Road Landfill can be classified as a brownfield, and it was selected as an EPA Brownfields Sustainability Pilot. The Holmes Road Landfill, situated 10 minutes from downtown Houston, Texas, was closed and later capped by the city sometime in the 1970s. 4 Closed Landfill Inventory reports from Figure 1, Aerial View of the Former Holmes Road Landfill. Source: Google Maps. the Houston-Galveston Area Council (H-GAC), indicate that the Holmes Road Landfill was used for disposal of brush, construction and demolition debris, household waste, industrial waste, tires and scrap. 5 Despite several proposals to redevelop the land, including one for a municipal golf course, the site remained unused until the mid-2000s, when the city began to explore the feasibility of the project summarized in this case study. 6 Native species of vegetation reclaimed the vacant 300 acres owned by the city during the elapsed time. 7 1 Methodological note: Information for the present case study was obtained from available project reports and from a telephone interview with the project coordinator. The project is ongoing and the information here is current through September For any questions, please contact Christopher De Sousa, Associate Professor and Director, School of Urban and Regional Planning, Ryerson University, chris.desousa@ryerson.ca. 2 US Environmental Protection Agency[a]. (July 2008). Brownfields Sustainability Pilot Fact Sheet, Houston Solar Project. Rob Lawrence, EPA Region 6. EPA-560-F SRA International. (2008). Technical Assistance: Solar Power Analysis and Design Specifications. EPA Contract No. EP-W , p US Environmental Protection Agency[a]; (October 2009). Brownfields Sustainability Pilots, Solar Power on Closed Landfill in Houston. Rob Lawrence, EPA Region 6. EPA-560-F SRA International, p US Environmental Protection Agency[a]; US Environmental Protection[b]. 7

2 The Holmes Road brownfield is surrounded by a mix of land uses including several other landfill sites, Houston s basketball and football stadiums, an old Six Flags amusement park, industrial lots and residential neighborhoods. The residential community in closest proximity to the brownfield has a higher proportion of African Americans compared to other residential communities in Houston. The average household income is 10 percent higher within this community than the city average owing to larger household sizes. Figure 2, Houston Solar Park Redevelopment The demographic data in Figure 2 illustrate the high proportion of African Americans that surround the landfill site. Indeed, the Holmes Road landfill and other landfills and incinerators in Houston feature prominently in Robert Bullard s seminal research on environmental justice. 8 Bullard argues that from the mid-1920s to the late 1970s, a form of de facto zoning contributed to all five, or 100 percent, of the city-owned municipal landfills being located in well-established African American neighbourhoods. A riot in 1967 at the predominately black Texas Southern University was precipitated by a death at the city's Holmes Road Dump. Given this history, efforts to revitalize the former Holmes Road Landfill would benefit from an approach that is socially, economically, and environmentally sustainable. PROJECT VISION T he City of Houston recognized that the size and location of the former Holmes Road Landfill presented several opportunities for redevelopment. A preliminary plan was put forward to redevelop the former landfill into three sections, each with a separate land use: a 100-acre, 10 megawatt (MW) solar farm; a 100-acre park that would connect to an existing municipal park (Sunnyside Park); and a 100-acre botanical garden. A $50,000 grant from the U.S. Environmental Protection Agency was provided to the city to help finance the technical assistance required to determine the project s feasibility. 9 Although Houston considers itself to be the energy capital of the country, the city wanted to diversify its energy portfolio to include more renewables as a hedge against the price volatility of conventional energy sources. Interest in developing a solar farm was motivated by an internal dialogue between the city s seven divisions concerning issues of energy efficiency and renewable energy production. A confluence of favorable factors made the Holmes 8 Robert D. Bullard. (1994). The Legacy of American Apartheid and Environmental Activism. St. John s Journal of Legal Commentary. 9 US Environmental Protection Agency[a]. Page 2

3 Road Landfill an ideal location for the solar farm that was being envisioned; namely, the land was owned by the city, it was underutilized, was of a substantial size and, like the city in general, it received plenty of sunshine. In addition to being an optimal location for a solar farm, the city was further motivated by the external benefits that redeveloping the land into a solar farm would produce. The city anticipated that the brownfield redevelopment would contribute to an improvement in local and regional environmental quality and resident safety, promote the site s heritage, and highlight the city s sustainability efforts at a highly visible location. Developing a solar farm on the landfill would also support local economic development objectives by providing Houston with the opportunity to enter the emerging solar energy market. 10 PROJECT CHARACTERISTICS AND DEVELOPMENT T he city presented its vision to redevelop the Holmes Road Landfill to the EPA and in turn secured technical assistance for the redevelopment through the EPA s Brownfields Sustainability Pilots program. SRA International (SRA) was commissioned by the EPA to provide the technical assistance to determine the feasibility of the envisioned project. The technical assistance provided by SRA included an on-site photovoltaic project assessment; regulatory assessment; site engineering assessment; determination of PV system size, conceptual design elements, and specifications; development of installed cost estimates for the solar farm; and economic analysis of the proposed solar farm s characteristics. 11 The analysis began with a site visit to the brownfield by both SRA and City of Houston staff in August The staff noted that the while the site was visible from the road, it was not accessible by car. Accessibility on foot was also limited due to the vegetation that had reclaimed the site. 12 Despite the limited accessibility of the site, several important observations were made that prompted SRA to recommend the southern half of the landfill for solar farm development. Reasons for this recommendation include: the identification of a high capacity distribution line, parallel to Reed Road, on the southern edge of the property 13 ; the absence of solar obstructions on the southern portion of the brownfield; the solar panels will be highly visible to the public on the southern edge and provide an added public relations benefit; siting the solar farm on the southern edge of the brownfield will eliminate the need to clear the natural boundary of trees and overgrowth in the northern portion US Environmental Protection Agency[a]; SRA International. 13 SRA International, p SRA International, p. 4. Page 3

4 The preliminary engineering report, prepared by SRA, considered the design, type and weight of a photovoltaic system against the brownfield s history and physical characteristics. Two constraints were identified through the site visit and study of previous reports: (1) landfill cap redeveloping the site without penetrating the soil cap into the waste area 15 ; (2) differential settlement this refers to the uneven settling of waste material below the landfill cap which affects the weight load restrictions of surface development. The preliminary engineering report maintains that preparing the landfill for redevelopment will require clearing, filling, grading and compacting the site. The overgrown vegetation and trees will need to be cleared without disturbing the landfill cap or exposing the buried waste material. This is complicated by the fact that the soil cap is deeper in some places than others. The site will subsequently need to be graded and filled to achieve a uniform cap depth at a minimum of four feet. 16 Finally, compacting the site will ensure a solid base for the solar infrastructure and mitigate potential settlement at the newly filled and graded site. 17 The preliminary engineering report by SRA recommended that the site be developed with fixed tilt (30 degree) mounting structures employing amorphous thin film panel. This system type and design will have the least impact on the landfill site, and require the least amount of mitigation of the site during the project development. 18 SRA also calculated an approximate footprint for the solar farm based on the recommended technology and its technical requirements. The development of a 10 MW solar farm on the former landfill would require 150 acres, or 50 more acres than the amount originally envisioned by the city. 19 With the aid of solar modeling software (PVWATTS), SRA estimated that the proposed 10 MW solar farm would generate approximately 12,526,260 kwh in an average weather year. 20 The electricity produced represents one percent of the city s yearly energy demand. The regulatory analysis pertaining to the brownfield was subcontracted to Tetra Tech, Inc. (Tetra Tech). 21 Tetra Tech surveyed the applicable federal, state, regional and local solid waste legislation and approval agencies pertaining to the project. The legislative documents consulted by Tetra Tech included the Resource Conservation and Recovery Act (RCRA) (federal level) and 30 Texas Administrative Code (TAC) Chapter 330, Subchapter T (state level). 22 The approval agencies included the Texas Commission of Environmental Quality (TCEQ) (state level) and the Houston- Galveston Area Council (H-GAC) (regional level). The regulatory assessment by Tetra Tech determined that since the proposed development is not an enclosed structure, many of the legislative rules do not apply to the project or are applicable in certain situations only. 23 Rule of the TAC Chapter 330, Subchapter T, mandates soil testing based on the project s objectives, however, this rule appears to have been satisfied by the environmental assessment performed by Terracon in Tetra Tech s final recommendation to the city was to carefully consider the TAC Chapter 330 rules and that an 15 SRA International, p SRA International, p SRA International, p SRA International, p SRA International, p SRA International, p SRA International. 22 SRA International, p SRA International, p. 8. Page 4

5 authorization request to the TCEQ is necessary given that the landfill cap will be cleared, graded, filled and compacted and, therefore, may be partially disturbed or penetrated during redevelopment. 24 The City of Houston planned to contract the design, construction and maintenance of the solar farm to a third party supplier and buy the renewable energy via a long-term purchase power agreement through its electricity provider, Reliant Energy. 25 As such the technical report by SRA also analyzed the economic scenarios that would benefit the city under this arrangement, particularly how much money it would save. The scenarios analyzed by SRA are summarized in Table Table 1, Cost Scenarios Associated with a 10 MW Solar Farm Blended cost of energy for city facilities in 2008 dollars (baseline for comparison): $0.1128/kwh Economic Scenario Estimated Cost of Solar Estimated Savings ($)** Crossover point (years)*** Energy ($/kwh)* Low ,936,179 6 Medium ,561, High , * The price is based on the levelized cost (energy produced based on lifecycle cost and estimated output over its expected life), plus a 10 percent profit margin for the utility supplier. ** These figures are calculated based on the assumption that utility prices for traditional energy sources will increase by 3.5 percent per year and a 20-year fixed cost per kilowatt hour purchase power agreement. ***The point at which solar power will cost less than traditional energy sources. Three cost scenarios (low, medium and high) provided by SRA indicate that while the city will be paying more for electricity generated by solar power than conventional sources (not shown), in the long run, the city can save money. SRA highlights that the negotiated purchase price of solar power is critical to the overall economics. 27 Shortly after the technical report prepared by SRA International was submitted to the City of Houston highlighting the technical feasibility of the envisioned solar farm, the city put out a request for proposals (RFP). In September 2009, NRG Energy Inc. (NRG) was awarded the contract to design, build, and maintain the solar farm, after which a longterm power purchase agreement between the city and NRG would be established. 28 As part of its RFP bid, NRG proposed an alternate location, on NRG-owned land, for the solar farm rather than the intended Holmes Road Landfill site, which accounted for a cost reduction in the bid. 29 The city effectually abandoned the plan to redevelop the landfill when the contract was awarded to NRG. 24 SRA International, p SRA International. 26 The table was created using data reported by SRA International, pp. 19, SRA International, p Joe Bourg. (December 2009). Renewable Energy on Contaminated Lands: Solar Feasibility Study for the Holmes Road Landfill, Houston, TX (PPT Webinar). SRA International, slide 26. Page 5

6 BENEFITS, BARRIERS, AND LESSONS LEARNED The motivation to redevelop the former Holmes Road Landfill into a solar farm was based on several projected benefits, including diversification of the city s energy portfolio, conversion of an underutilized space into a sustainable land use, local economic development, and community revitalization. While the first three benefits were addressed in the planning process, it was not clear how the city planned to achieve the latter. A project summary by the U.S. EPA states that frequent communication between stakeholders was essential to achieve positive results. 30 The stakeholders identified in this case were the City of Houston, State of Texas, U.S. EPA and the consultants. It is interesting to note that based on the projected benefits, the local community and surrounding residents were not considered to be stakeholders and were not included in the project s visioning or feasibility processes. To be a truly sustainable project, the social impacts should have been considered alongside economic and environmental ones. While there were few barriers identified as the brownfield redevelopment was being envisioned, constraints and challenges increased as the project progressed. The physical constraints presented by the landfill s uneven cap and differential settlement pattern, however, could be addressed by clearing, grading, filling and compacting the site, as well as in the design consideration of the solar PV infrastructure. Even so, external considerations, such as the financial and economic costs to be incurred by the city, appear to have been more important than the projected benefits. This was made obvious when the city awarded the contract to NRG Energy Inc. to design, build and maintain the solar farm on an alternative site owned by the company. Despite the feasibility of the project and its potential as a best practice example for others to follow, economic and political realities seem to have shelved the plan to redevelop the Holmes Road Landfill into a solar farm. The case study presented here, however, still provides a template for other brownfield redevelopment feasibility studies, particularly in relation to solar farms or brightfields, as they are sometimes referred to. A City of Houston official recently noted that the city continues to assess options for redeveloping the landfill and is working with the local community to discuss the viability of these options as they emerge. While solar and other ideas have not come off the table, the aim is to pursue a plan that is more economically practical. The city continues to be optimistic that a sustainability-oriented plan can transform the site into a community asset. 30 Page 6

7 TIMELINE YEAR 1970s 1970s to present September 2006 August 2008 October 2008 September 2009 November 2009 DESCRIPTION Holmes Road Landfill is closed (according to the City of Houston records) and capped Site is vacant and unused City of Houston contracts an environmental site investigation to Terracon SRA International conducts site visit Site visit and technical report provided to City of Houston by SRA Plan to redevelop landfill abandoned in favor of alternate site Public-private partnership between the City of Houston and NRG Energy Inc. suspended indefinitely REFERENCES Bourg, Joe. Renewable Energy on Contaminated Lands: Solar Feasibility Study for the Holmes Road Landfill, Houston, TX (PPT Webinar), December Bullard, Dr. Robert D. The Legacy of American Apartheid and Environmental Activism. St. John s Journal of Legal Commentary, Kilmer, Larry. Sustainable Brownfield Pilots - Houston Solar Project, Houston, Texas, SRA International. Technical Assistance: Solar Power Analysis and Design Specifications. EPA Contract No. EP-W , U.S. Environmental Protection Agency[a]. Brownfields Sustainability Pilot Fact Sheet, Houston Solar Project. Rob Lawrence, EPA Region 6. EPA-560-F , July U.S. Environmental Protection Agency[b]. Brownfields Sustainability Pilots, Solar Power on Closed Landfill in Houston. Rob Lawrence, EPA Region 6. EPA-560-F , October ACKNOWLEDGEMENTS This work was performed under a subcontract with the University of Illinois at Chicago and made possible by grant number TR from the U.S. Environmental Protection Agency. Its contents are solely the responsibility of the authors and do not necessarily represent the official views of the U.S. Environmental Protection Agency. The authors would like to sincerely thank Issa Z. Dadoush from the City of Houston for providing information about the project. The authors would also like to thank the following student assistants for their research support - Larry Kilmer, Kevin Duffy, Jason Tilidetzke, Laura Lynn Roedl, and Elizabeth Durkin. Page 7