19119_Authority_April_2026
60 The Authority │ April unique aspects of data center discharge (related to pH, temperature, conductivity, chloride, total residential chlorine, and flow equalization). • Update your Headworks Analysis, Maximum Allowable Industrial Loadings, and local limits allocation assumptions. • Expand your sampling plan beyond typical metals, oils, grease, and Chemical Oxygen Demand (triggering potential investments in conductivity probes and lab capacity) • Add the facility to your slug control evaluation list, require the facility to produce a Slug Control Plan, and conduct periodic slug control inspections (due to the significant chemical storage and batch operations at data centers). • Update your Enforcement Response Plan, surcharge and penalty structures, and response protocols for acute events. If your authority doesn’t have an industrial pretreatment program, you should evaluate if it needs to develop one based on the volume and characteristics of the discharge. Residuals/Biosolids Permits (Sludge Management) Higher salts, metals, and chemical residuals can reduce land application options or increase testing. If your wastewater characteristics change, you may see impacts to your: • Biosolids land application permits • Composting permits • Landfill disposal approvals • Sludge quality monitoring requirements Step 3 – Plan for any necessary capital improvements. Now is the time to identify any upgrades that may be necessary based on your assessment in step 2. This could include: • New storage tanks. • New pumps and control equipment. • Pipe rehabilitation or replacement. • Sensors and meters to increase monitoring. • New treatment tanks and equipment. Create a detailed capital improvement plan (or update an existing one) with timelines, estimated costs, and potential funding strategies. Document how these upgrades are connected to data center demand. Step 4 – Calculate the financial impact and structure appropriate rates and fees to recover costs. In addition to the capital costs identified in step 3, data centers can increase ongoing expenses for power, chemicals, maintenance, staffing, and regulatory compliance, among others. Authorities should quantify these impacts to ensure the data center pays its fair share and existing customers are not subsidizing service. Cost-recovery mechanisms typically include: 1. One-time fees for up-front capital costs such as tapping, capacity, or impact fees. 2. Ongoing fixed charges to recover the cost of reserved capacity that must be maintained year-round, even if usage is seasonal or intermittent. 3. Variable usage charges tied to actual operating costs, including strength-based sewer charges and surcharges for incremental costs for chemicals, power, sludge handling, monitoring and sampling, and permit compliance. Costs associated with permit modification, compliance monitoring, and long-term risk exposure could be built into annual cost riders or contract-specific pass-throughs. Authorities may also consider creating a separate customer class for data centers and other large-volume and high-risk users to support transparent cost allocation, future rate adjustments, and regulatory defensibility. Minimum bills and take-or-pay provisions can protect the utility if usage is lower than projected, facility operations change, and/or the data center sits idle. Lines of credit and/ or bonds can protect against non- payment, early shutdown, and/or stranded infrastructure. Step 5 – Adjust your policies and procedures to reinforce your authority to regulate usage. Standard utility rules were written HRG article continued from page 6. ...data centers have unique requirements and present unique risks. With careful planning, clear financial frameworks, and enforceable agreements, utilities can serve data centers while protecting their systems, their finances, and their customers.
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