SWANA Recommends Changes To EPA Proposed Mandatory Reporting Rule

On Tuesday, June 9, 2009 the Solid Waste Association of North America (SWANA) submitted comments to the U.S. Environmental Protection Agency regarding their proposed rule on mandatory reporting of greenhouse gases. The rule calls for covered sources emitting over 25,000 tons of CO2e per year to report their emissions of a number of greenhouse gases.

This ruling would directly affect active and closed landfills and waste-to-energy plants. As currently written these solid waste operation would be required to begin reporting of their emissions starting January 1, 2010. In order to comply with these regulations many would have to install new continuous emissions monitoring equipment, a costly burden.

In its letter, SWANA expressed many potential concerns with the rule, but mainly focused on the continuous monitoring of emissions from solid waste operations as well as the relatively quick start date for reporting.

“Many solid waste operations are already reporting emissions data for a number of regulatory programs, including existing climate programs and registries,” said John Skinner, Executive Director and CEO of SWANA. “More integration and coordination is needed with other similar programs throughout the United States so that the burden of additional reporting and monitoring may be reduced,” Skinner added.

The reporting rule is written to require continuous emissions monitoring of CO2 from WTE plants and suggest the option of continuously monitoring methane from landfills. This monitoring method does not improve the accuracy of the information being reported and we request the EPA change their rule to allow for monthly reporting of emissions instead.

The proposed requirement to begin collecting data on January 1, 2010 may be appropriate for industries who are already reporting on other air quality emissions. However, it is too early for many facility operators who will need to train staff, and install new monitoring equipment, etc. SWANA recommends that EPA have a start date of January 1, 2011 with this first year constituting a phase-in period to establish and confirm sampling and analysis protocols, and January 1, 2012 the date when inventories will bear the full scrutiny of EPA. This is the approach that has been taken in the California AB-32 program.

To read our full letter to EPA please click here.