The Federal Register recently published new landfill rules which fail to meet any of the goals that the White House and EPA have set forth to reduce landfill gas emissions. In July, US EPA鈥檚 鈥淔uels and Incineration Group鈥� (FIG) pushed through its final revisions to new rules regarding landfills in the United States. The rules state that landfill owners may receive greenhouse gas credits[1]聽that profit a landfill operation鈥檚 bottom line. 鈥淕arbage is Not Renewable.鈥澛爏tates Neil Seldman of the Institute for Local Self-Reliance.聽鈥淲hile we applaud the EPA for its public statement in support of food loss reduction,鈥澛爃e says,聽鈥渢his new landfill policy will do nothing to help move toward the food recovery goal. It will even hurt these efforts.鈥�
The new rules lower the threshold for controlling methane emissions from 50 metric tons per year to 34, but only for landfills built after July 17, 2014.[2] However, the 2016 rule will have no effect on landfills built after 2014, since these are overwhelmingly mega-landfills whose sheer size means that they would have聽already聽been required to install gas collection systems. 鈥淚n the new proposal, FIG leans heavily on the interests of landfill operators, and false statistics that they say would reduce emissions from methane鈥澛爏ays Monica Wilson of the Global Anti Incineration Alliance.聽鈥淭he rules will have no effect on methane release for the large landfills that are presently being built.
“EPA is using outdated science that understates the climate impacts of methane by three to four times,”聽says Mike Ewall with the Energy Justice Network.聽聽“Their proposal reinforces ‘business-as-usual’ at landfills, pretending to make a difference while still intensely warming the climate.聽 A true ‘zero waste’ approach would divert food waste and other clean organic materials for composting, and ensure that any remaining waste is digested before landfilling, to first capture the methane in an enclosed environment to reduce leachate and avoid having gassy, stinky landfills.”[1]
In September 2015 the EPA, USDA, and the White House came out with a forward-thinking goal of聽50 percent reduction in food waste over the next 15 years. By choosing to focus on minor alterations to regulations, as opposed to a plan for sustainable waste management that encourages preventative measures, The Institute for Local Self-Reliance and other organizations believe that the Fuels and Incineration Group fails to adequately respond to the 2014聽White House call for decisive action聽on methane. The Fuel and Incineration Group鈥檚 chosen course of action does not tighten controls or lower the amount of methane currently being generated in, and escaping from, landfills.
The EPA group should instead focus on waste management goals and the food hierarchies to prevent organic materials from reaching landfills in the first place, thus reducing the potential for landfill gas to be created.聽Disregard for truly sustainable waste processing systems is permitting the continuation of the methane problem, rather than redressing it.
Fact Sheet Highlights:
- Problems with landfills not only include the enormous loss of the resources embodied in landfill discards, but also the fact that systems used in attempt to capture methane and other hazardous air pollutants generated in landfills are inherently flawed. In particular, the effectiveness of landfill gas (LFG) capture systems is undermined when the landfill remains unsealed so as to actively receive materials.[3]
- Due to organic waste鈥檚 innate moisture content and unsealed landfills鈥� exposure to rainfall, waste management through landfilling does not control organic wastes鈥� decomposition in the same way as composting or anaerobic digestion, and thus continually releases fugitive emissions into the atmosphere.
- Factors affecting the amount of landfill gas generation are site-specific, due to high variability in, among other conditions, the moisture content and its movement within the site.[4] Landfills without leachate recirculating technology are estimated to have a moisture content of 20%, whereas those with recirculating systems (i.e. bioreactor landfills), have a moisture content of anywhere between 35 to 65%.[5]
- The monetary benefits of landfill gas capture in the short-term provide an incentive to continue to bury organic materials in landfills, rather than divert them. Another likely explanation of landfill operators鈥� motivation for burying organics wastes is to maintain income from abundant tipping fees,[6] rather than transfer the economic benefit to composting operations.
- The Intergovernmental Panel on Climate Change (IPCC) finds that, on a lifetime basis, landfill gas collection in even some of the most efficient systems is as low as 20%.鈥漑7]
- Leachate is largely generated by precipitation into the landfill & the leachate鈥檚 composition & nastiness is determined by what the individual landfill accepts.
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Notes
[1] 聽For further details on the impact of methane on climate change, see,聽
[1] 聽鈥淪tandards of Performance for Municipal Solid Waste Landfills: Proposed Rule.鈥� Federal Register 79, No. 137 (July 17, 2014): p. 41802. Available at:聽
[2] 鈥淓mission Guidelines and Compliance Times for Municipal Solid Waste Landfills.鈥� Federal Register 80, No. 166 (August 27, 2015): p.52102. Available at:https://www.regulations.gov/document?D=EPA-HQ-OAR-2014-0451-0076
[3] 鈥淎 comparison of the gas collection efficiency for open and closed landfills shows that the efficiency at closed landfills is 17 percentage points greater than open landfills.鈥� See: Powell, J. T., J. B. Zimmerman, & T. G. Townsend. 2016. 鈥淓stimates of solid waste disposal rates and reduction targets for landfill gas emissions.鈥澛燦ature Climate Change,聽6 (2): 162-165. Available at:聽
[4] Center for Disease Control, Agency for Toxic Substances and Disease Registry. November 2001. 鈥淟andfill Gas Primer: An Overview for Environmental Health Professionals 鈥� Chapter 2.鈥� Available at:聽
[5]聽US EPA, Office of Air and Radiation. June 2014. 鈥淓conomic Impact Analysis for the Proposed New Subpart to the New Source Performance Standards.鈥� Available at:https://www3.epa.gov/airtoxics/landfill/landflpg.html