Environmental Groups Petition EPA to Refocus Methane Program

Date: April 9, 2010

Source: News Room

A coalition of 10 environmental groups are petitioning EPA to restructure its voluntary landfill methane capture program so that it aims to reduce production of the greenhouse gas (GHG) rather than emphasizing its use as an energy resource. The April 6 petition also argues that the program's current focus contradicts EPA's waste office's stated goal of waste minimization. Separately, The Environmental Defense Fund (EDF), which is not part of the coalition, is also suing EPA to force strict new source performance standards (NSPS) to cut landfill emissions. The coalition that signed the petition includes Sierra Club, Friends of the Earth, the Center for a Competitive Waste Industry, the City of Madison, WI, and others.

"Fugitive methane is only created when organics are buried in landfills, where anaerobic conditions prevail," the petition says." It argues that composting these wastes is a far better option that avoids methane emissions and restores nutrients to depleted soils.

The EPA lists landfills as the second-largest source of human-related methane in the US, accounting for 23 percent of these emissions in 2007. It says "methane emissions from landfills represent a lost opportunity to capture and use a significant energy resource." LFGTE projects are assumed to capture 75 percent of the gases. However, the coalition groups say that if energy capture is the goal, then controlled anaerobic digestion at dedicated facilities is a better solution.

Meanwhile, the EDF lawsuit, originally filed in October 2008, complains that the NSPS for landfills, promulgated in 1996, is out of date in part because higher energy prices have made capture of methane for use as fuel cost effective.

Peter Anderson of The Center for a Competitive Waste Industry says their petition is independent of EDF's effort to address NSPS but that both issues need to be addressed regardless of the outcome of the other.


US Composting Council
California Resource Recovery Association # Center for Biological Diversity
Center for a Competitive Waste Industry # City of Madison (WI)
Friends of the Earth # Grassroots Recycling Network
Recycling Organizations of North America
San Francisco Department of the Environment
Sierra Club # Texas Campaign for the Environment

April 6, 2010

Hon. Lisa P. Jackson, Administrator
U.S. Environmental Protection Agency
Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Re: Petition to Reorganize the Landfill Methane Outreach Program

Dear Ms. Jackson

Because of your strong commitment to reducing the risks of global warming, we are writing to formally petition the Environmental Protection Agency to reorganize and rename its Landfill Methane Outreach Program (LMOP) so it can better meet the overall objectives of the Agency.

At present, as one of EPA's lead programs to reduce methane from the waste sector, the LMOP has aggressively boosted efforts to capture methane at landfills. The basic assumption of this strategy is at odds with EPA's primary missions. For example, goals listed on the home page of EPA's OSWER program include waste reduction, land revitalization, and recycling. Landfill diversion of organics to compost facilities, potentially in combination with controlled anaerobic digestion offers the potential to help achieve these goals. Diversion should be the focus of EPA's waste management hierarchy.

Recent surveys indicate that 65 local programs in the U.S. have followed the alternative diversion model, first established in the European Union and later in three Canadian provinces, to separate the organic stream for composting. They, and the many more interested cities and states, need EPA to expand its repertoire of local assistance to comprehensively address fugitive methane from landfills by also including measures to avoid the problem in the first instance.

Landfilling is the waste management strategy that is the lowest on the Integrated Waste Management Hierarchy. The primary source of fugitive methane emissions are from landfilled organics. Fugitive methane is only created when organics are buried in landfills, where anaerobic conditions prevail. It is not a byproduct of decomposition when those organics are diverted to the other commercially available options, such as composting, which in addition to avoiding methane and producing a valuable soil conditioner, recovers the nutrients in those organics to help restore fertility to our depleted soils. Compost in turn can be used to rebuild soils and rebuild communities through urban agriculture.

The LMOP's work has championed landfill-gas-to-energy (LFGTE) by focusing exclusively on the minor gains from displacing electric generation on the utility grid, while disregarding all of the fugitive methane - one of the more aggressive greenhouse gases - that escapes in the process. Using all of EPA's landfill conventions, 87 pounds of CO2 will be avoided per wet ton of waste buried. However, the fact is that 430 pounds of CO2-equivalent - five times more - will be released into the atmosphere at the same time - something which LMOP's presentment fails to recognize. If one uses the Intergovernmental Panel on Climate Change's lower assumed landfill gas collection efficiency value, only 23 pounds of CO2 will be avoided, and 1,279 pounds of CO2-equivalent - 55 times more - will escape. Also, many other important adjustments would further widen the disparity between LFGTE and diversion.

If energy capture is truly a primary goal for waste management, controlled anaerobic digestion at dedicated facilities is the appropriate method to do this. Full scale facilities in North America and Europe have shown the efficacy of this approach. In addition, controlled anaerobic digestion both more effectively utilizes the carbon value in organic discards and also conserves the nutrients and a portion of the carbon from the feedstocks both of which have value for soils.

Through the LMOP's efforts, according to the Congressional Reference Service, $12.9 million in Stimulus funds were provided to LFGTE projects and none to the alternatives described above. Furthermore, the LMOP has previously been a major force in encouraging inclusion of LFGTE in state Renewable Portfolio Standards' programs (RPS), which provide far greater subsidies in many states where LFGTE facilities receive more than 10¢/kWh for electricity that costs less than a nickel to produce. These subsidies could be redirected to organics management industries that maximize the value of these materials including controlled anaerobic digestion and composting.

For these reasons, we respectfully ask that you:

(1) Rename the current Landfill Outreach Methane Program to be the new Organics Management Outreach Program (OMOP); and

(2) Charge the new OMOP to more effectively encourage reductions in methane emissions from the waste sector by prioritizing those strategies with the greatest potential to achieve that objective.

Your considered attention is appreciated.


by Wayne King, President

by Julie Moore, President

by Matthew D. Vespa, Senior Attorney

by Peter Anderson, Executive Director

by George P. Dreckmann, Recycling Coordinator

by Erich Pica, Chief Executive Officer

by Linda Christopher, Executive Director

by Marjorie Griek, President

by David Assmann, Acting Director

by Ed Hopkins, Director Environmental Quality Program

by Robin Schneider, Executive Director

cc: Office of Solid Waste and Emergency Response Office of Air and Radiation Office of the Administrator Policy, Economics and Innovation Regional Administrators

Correspondence in response may be sent to:
Mr. Peter Anderson, Center for a Competitive Waste Industry
313 Price Place, Suite 14 Madison, WI 53705
Phone (608) 231-1100
Facsimile (608) 233-0011
email: anderson@competitivewaste.org.

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