Regulating Wastewater Treatment Systems to Promote Shared Value

In the Harvard Business Review piece “Creating Shared Value” a secondary section really caught my attention. The section titled “Government Regulation and Shared Value” on page 14 discusses how government regulation can promote innovation and shared value or inhibit it. I have seen both regulatory methods in action during my time at the Washington Department of Health and would like to point out some inconsistency in how wastewater treatment systems are regulated based on size.

Wastewater regulation is fairly straight forward. All systems, big and small, are told where they can discharge, how much they can discharge, and what the allowable limits are for a variety of constituents. The difference between big and small systems is that big systems (>14,500 GPD) don’t necessarily have specifically prescribed methods of treatment whereas small systems (<14,500 GPD) are required to choose a treatment method from an approved treatment method list.

Large systems across the state are furthering wastewater treatment technologies. New and updated systems (i.e. Brightwater and Chambers Bay) are using membrane filtration, focusing on nutrient removal, and utilizing various resource recovery systems. (Solids, energy, water reclamation, etc.) Although these ideas may not be new, their implementation has recently become more common.

The same innovations are lagging behind in smaller systems. In order for a new system to make the approved treatment method list it must first go through a fairly extensive testing regiment. Obviously, systems installed in big treatment plants must also undergo extensive testing, but they can look at data from a multitude of sources to determine the systems viability whereas small systems must undergo a very prescribed and in my opinion cost prohibitive testing procedure. This has resulted in mainly proprietary systems being added to the list.  Now proprietary systems can be innovative as well, but with very little competition, and the prohibitively rigorous testing requirement for new systems, they have very little incentive to further develop their products.

One may argue that the size difference in treatment plants is what leads to the differences in regulations. Large and extremely expensive systems should look to new technologies to increase efficiency and lower footprint because doing so can save millions of dollars. I would like to think that if smaller systems were allowed the same leeway, we might see more of the big system ideas like resource recovery trickle down to the smaller systems.

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