Advocacy

U.S. Drafts National Strategy for Reducing Food Loss and Waste and Recycling Organics

The Draft National Strategy for Reducing Food Loss and Waste and Recycling Organics was released on December 2nd, 2023 by the U.S. Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA), and the U.S. Food and Drug Administration (FDA). The goal of the strategy is to prevent the loss and waste of food to “help reduce greenhouse gas emissions (including methane), save households and businesses money, and build cleaner communities by reducing food loss and waste.”

The strategy describes four objectives:

1. Prevent food loss where possible.
2. Prevent food waste where possible.
3. Increase the recycling rate for all organic waste.
4. Support policies that incentivize and encourage food loss and waste prevention and organics recycling.

The strategy references the National Strategy to Advance an Integrated Greenhouse Gas Measurement, Monitoring, and Information System as well as the recent EPA reports, Quantifying Methane Emissions from Landfilled Food Waste and From Field to Bin: The Environmental Impacts of U.S. Food Waste Management Pathways.

The public comment period for the draft strategy opens on Tuesday, December 5, 2023 and will be open for 30 days, at Regulations.gov (Docket ID No. EPA-HQ-OLEM-2022-0415).

SWANA plans on submitting comments, and updates will be forthcoming. Feedback on comments can be directed to Kristyn Oldendorf, Director of Public Policy, at koldendorf@swana.org.

EPA’s Meaningful Involvement Policy

The United States Environmental Protection Agency (EPA) is now accepting public comments on its Achieving Health and Environmental Protection Through EPA’s Meaningful Involvement Policy which “guides EPA staff to provide meaningful public involvement in all its programs and regions.”

Comments can be submitted through the Federal Register. EPA will be hosting three public informational webinars to provide an overview of the policy and to allow the public to ask questions. The first webinar will be held on December 20th at 7:00 p.m. ET.

Please contact Kristyn Oldendorf at koldendorf@swana.org with any feedback.

Gas Upgrading Equipment Potentially Excluded from Energy Tax Credits

The United States’ Inflation Reduction Act of 2022 includes an energy credit for eligible energy property under Section 48 Investment Tax Credit (ITC). This tax credit applies to “qualified biogas property.”

However, the U.S. Treasury Department recently published a Notice of Proposed Rulemaking (NPRM), to amend the regulations for the energy credit which would exclude the gas upgrading equipment used to transfer the gas into the format for injection into the pipeline, effectively making such equipment ineligible for the tax credit.

The IRS is accepting comments until January 22, 2024, and a public hearing on these proposed regulations is scheduled to be held on February 20, 2024, at 10:00 a.m. ET.

SWANA is working with the Renewable Natural Gas Coalition to advocate for the gas upgrading equipment to be eligible for the energy credits. Please contact Kristyn Oldendorf at koldendorf@swana.org with any input on responding to this issue. We welcome examples of how this credit may impact RNG systems and any other feedback.

Letter of Support for RNG Tax Credits

SWANA recently signed onto a letter of support initiated by Natural Gas Vehicles for America in support of the Renewable Natural Gas Incentive Act of 2023, H.R. 2448, which proposes to establish a $1/gallon tax credit for the use of renewable natural gas (RNG) in vehicles. In this bill, renewable natural gas is defined as compressed or liquefied gas derived from biomass. SWANA will continue to monitor this bill for next steps and will keep members informed of any future progress.

U.S. National Strategy to Advance an Integrated Greenhouse Gas Measurement, Monitoring, and Information System

The United States government has released a National Strategy to Advance an Integrated U.S. Greenhouse Gas Measurement, Monitoring, and Information System which provides a conceptual framework and national objectives on GHG measurement, monitoring, and information systems, as well as a phased implementation approach.

Phase 1 of the Implementation approach seeks to “identify mature GHG observing, measurement, modeling, analysis activities and capabilities that, with targeted efforts, could be transitioned to sustained use to improve GHG information in the near term.” The approach plans sector-specific demonstration projects for several sectors, including waste. The strategy’s section on waste discusses the potential of improving the modeling of MSW landfills by using a combination of aircraft and satellite measurements and near-continuous, surface-based observations. It states that a better understanding landfill emissions over time can support the development of cost-effective strategies to manage emissions.

This has two supporting tasks:

1. “Establish measurement test beds that combine atmospheric observations of carbon dioxide and methane with activity data from landfill operations to improve Municipal Solid Waste landfill emissions models, emissions factors, and activity data.”
   • This landfill measurement test bed initiative is proposed to research the use of top-down approaches to measure carbon dioxide and methane concentration fields, such as an airborne hyperspectral imaging spectrometer, to be used in addition to the current surface-based EPA-recognized emissions measurement methods. This research will occur over multiple years and landfills, focusing on the Washington, DC and Baltimore, MD urban regions.
2. “Advance development of cost-effective measurement and monitoring approaches for landfill emissions”
   • The Environmental Protection Agency (EPA) is providing research grants for landfill monitoring methods.The Science to Achieve Results (STAR) Grant program recently awarded five grants to projects that will “demonstrate and validate approaches to quantifying emissions from various landfill characteristics.” See the November 30th IASN article for more details on these grant awards. The EPA is also collaborating with other government agencies and implementing an emerging intramural landfill research program to test and develop remote sensing and continuous measurement and monitoring methods for landfills.

SWANA will monitor the implementation progress of this plan.