Lessons Learned from Federal Mandatory GHG Reporting Data Analysis for Landfills

摘要

Landfills are essential public services, which are not only one of the most regulated industries in the U.S. but also one of the only industry sectors which have reduced their emissions footprint way beyond 1990 levels. Many MSW landfills already have active GCCS which destroys GHG emissions under current regulations that are imposed by local air districts, states, and the federal government. The landfill industry is currently the only sector under U.S. EPA federal GHG reporting required to report fugitive emissions. Despite existing stringent regulations, the landfill industry was hit harder than any other industry under the federal MRR, with almost 1,600 landfills reporting. Only the power plants and the oil and gas sector have more reporters. The changes to the MRR proposed by the U.S. EPA reflect an appropriate weighing of burden and uncertainty. Monthly methane monitoring reduces the burden significantly and aligns the monitoring frequency with other regulations, while increasing uncertainty a very small amount. The updated oxidation calculation methodology is a small increase in the burden on reporters, but the updated methodology represents a significant reduction from the uncertainty associated with the flat 10 percent oxidation rate and creates more accurate GHG estimates. Industry and interested parties will continue to work with the U.S. EPA to achieve the appropriate balance of burden and uncertainty in GHG reporting. GHG reporting is still in its infancy in the U.S. and many states have already adopted many of the requirements of the federal MRR. And there is also uncertainty associated with what U.S. EPA plans to do with all of the reported information and whether it will result in future command-and-control regulations for landfills, resulting from and to further control the reported methane emissions.