SWANA Seeks Solid Waste Exemption from EPA Tailoring Rule

The Solid Waste Association of North America (SWANA) is seeking an exemption from proposed U.S. Environmental Protection Agency (EPA) regulations on biogenic carbon dioxide emissions from combustion at landfill gas and waste-to-energy facilities.

The Silver Spring, Md.-based SWANA said in a news release it requested a categorical exclusion from the EPA’s Scientific Advisory Board (SAB) on CO2 emissions for municipal solid waste management in the Prevention of Significant Deterioration and Title V GHG (greenhouse gas) Tailoring Rule.

In arguing for the exemption, SWANA told the SAB that the solid waste management industry has reduced greenhouse gas emissions by 75 percent since the 1970s, while total generation of solid waste has more than doubled.

“These reductions have been achieved through an integrated system of solid waste management that includes landfill gas recovery, waste-to-energy and increased diversion from landfills through recycling and composting,” said John Skinner, SWANA executive director and CEO. “No other major industrial sector in North America can make a similar claim for the goods or services they provide.”

In the SAB Review of the EPA’s Draft Accounting Framework for Biogenic CO2 Emissions from Stationary Sources, SWANA agreed with two of its recommendations and disagreed with a third. The SAB recommended that EPA consider identifying those feedstock categories for which the biogenic accounting framework would automatically be set to zero. SWANA said it believes this should apply to both waste-to-energy and landfill gas combustion.  SWANA also agrees with the panel recommendation that the EPA should take into account the mix of biogenic and fossil carbon when waste is combusted.

SWANA disagreed with the SAB recommendation that for landfill gas combustion the EPA should incorporate emissions and partial capture of methane from landfills.  SWANA argues that there is no scientific or policy basis for regulating biogenic CO2 emissions based on methane collection efficiency.

SWANA also recommended that the EPA account for carbon sequestration of municipal solid waste disposed in landfills.

In 2011 the EPA deferred dealing with CO2 emissions from biogenic sources under the tailoring rule for a three-year period to provide time for the agency to develop an appropriate approach.