California’s AB 32 legislation has proven to be one of the most successful legislation in the U.S. regarding statewide efforts to reduce GHG emissions. This has been started with the implementation of the early action measures stated in the Scoping Plan, which included early regulations to reduce GHG emissions in many different industry sectors, and then moved to the establishment of the MRP and C&T programs, which have created incentives for facilities to reduce their GHG emissions. The nine early action measures have been documented to reduce California’s GHG emissions with an estimated reduction of 13.16 percent from 1990 emissions in the year 201813. As a result of these programs’ implementations, California has met its goal to reach 1990 emissions levels by 2020 and had done so by 2016, four years before its proposed target year.
With the continued implementation of new programs at the state, local, and federal level, growing economic incentives to reduce emissions, and drive that led to the success of the emissions reduction goals of AB32, California is on a very promising path to achieving its latest goals to combat climate change.
Opportunities to Learn More
Utility Dive reports that Alliant Energy announced its commitment to net-zero carbon emissions from its electricity by 2050.
The “new aspirational goal” reduces carbon emissions by 50% below 2005 levels by 2030 and eliminates all coal-fired power by 2040, 10 years faster than previously planned. Alliant owns or partially owns eight coal-fired power plants across Wisconsin and Iowa — three of which are slated for retirement or conversion to natural gas.
Alliant’s announcement follows growing commitments by investor-owned utilities to move toward a more low-carbon fuel mix. Xcel Energy, Madison Gas, and Electric and Consumers Energy are among the other Midwest utilities to have made such a pledge.
Alliant reached its 30% renewables by 2030 goal this year and its “intention is [to] keep adding renewables to our energy mix,” utility spokesperson Scott Reigstad said in an email.
Alliant also said it may keep some natural gas-fired plants online, retrofitted with carbon capture or some other emissions-reducing technology, or it could also use carbon offsets to reach that goal.
Read the full article including solar and other renewables on Utility Dive’s website.
California leads the way in the United States with a GHG MRP and C&T program that continues to grow and link with other jurisdictions. The California Air Resources Board (CARB) Market Readiness Proposal initially started with basic facility reporting and has grown and adopted to include multiple non-facility specific sectors of the economy, as dictated by the growing initiatives and programs that CARB joins or creates. However, as the program applicability may change, the basics tenants of MRP stay the same with reporting and verification at the center of the program.
By having CARB’s C&T Program as a separate program, entities have to navigate if they have a compliance obligation and how they will meet that obligation in addition to complying with reporting requirements. Entities can reduce their emissions by switching to biomass-derived fuels or meeting their compliance obligation by using CARB-provided allowances or purchasing allowances and/or compliance offset credits.
As CARB’s programs grow, it will likely trigger similar growth in the western North American GHG programs and regional agreements. As discussed, Québec’s C&T system, which is linked with CARB’s program, has been growing and is being used to meet the Canadian federal GHG rules that are being put in place. Ontario’s program was annulled but shows that the discussion on how best to reduce GHG emission is a topic that continues to thrive, and we may see new programs developing even though some may hit some setbacks. The PCC shows that even if a Market Readiness Proposal and C&T Program is not the particular method chosen by a region to reduce emissions, many regions still see reducing GHG emissions as the future to create jobs, develop the economy, develop new infrastructure and maintain growth while protecting the environment.
About the Authors:
Cassandra Drotman Farrant is experienced in environmental consulting, specializing in environmental assessment and greenhouse gas (GHG) verification. She has participated in GHG verification projects throughout the U.S.
Raymond H. Huff is SCS Engineers’ National Expert on Greenhouse Gas. He specializes in landfill regulatory compliance; air quality/compliance issues, including GHG emissions quantification; and site assessment, remediation, and post-closure care.
Haley DeLong is experienced in greenhouse gas (GHG) emissions, sustainable energy, and climate dynamics. She specializes in air quality consulting and has been involved in numerous projects related to air permitting and compliance with solid waste regulations, including preparing Title V and Non-Title V permit-to-construct/operate permit applications.
This proposed MSW Landfills Federal Plan includes the same elements as required for a state plan: identification of legal authority and mechanisms for implementation; inventory of designated facilities; emissions inventory; emission limits; compliance schedules; a process for the EPA or state review of design plans for site-specific gas collection and control systems (GCCS); testing, monitoring, reporting and record-keeping requirements; public hearing requirements; and progress reporting requirements. Additionally, this action summarizes implementation and delegation of authority of the MSW Landfills Federal Plan.
This proposed action addresses existing MSW landfills and associated solid waste management programs. For the purpose of this regulation, existing MSW landfills are those that accepted waste after November 8, 1987, and commenced construction on or before July 17, 2014.
Tables 1 and 2 in the publication list the associated regulated industrial source categories that are the subject of this action and the status of state plans. The EPA tables are not intended to be exhaustive but do provide a guide for readers regarding the entities that this proposed action is likely to affect. The proposed standards, once promulgated, will be directly applicable to the designated facilities.
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By keeping open lines of communication between industry stakeholders and the U.S. EPA at a federal level, both parties have been able to improve the quality of GHG emissions data reported under the GHGRP while reducing the monitoring burden.
Read this SCS Engineer’s abstract that discusses the cooperation between the U.S. Environmental Protection Agency (EPA) and solid waste industry stakeholders in developing, revising, and implementing the landfill reporting requirements as part of the federal GHG Reporting Program (GHGRP) (40 CFR Part 98). The paper covers:
EPA is proposing a GHG SER of 75,000 tons per year (tpy) Carbon Dioxide equivalent (CO2e) and requesting comment on it as well as two lower levels, specifically 30,000 tpy and 45,000 tpy CO2e, respectively.
The Associations do not believe there is sufficient information to support lowering the GHG SER below the proposed 75,000 tpy CO2e level and provided a table utilizing equivalent criteria pollutants from combustion sources (i.e., NOx, CO) yields CO2 emissions as high as 780,000 tpy CO2.
EPA already concluded in USEPA, Proposed PSD Revisions Rule, 81 FR 68137 that the burdens of regulation at a GHG SER level between 30,000 and 75,000 tpy CO2e would yield a gain of trivial or no value from both a programmatic and individual project-level perspective. Therefore, NWRA and SWANA strongly recommend EPA retain proposed GHG SER of 75,000 CO2e (or higher), and resist pressure to lower the GHG SER.
On the Topic of Biogenic GHG Emissions, the EPA’s final rule requires clarification to remain consistent with previous documentation and research to prevent significant permitting delays and increased costs that will not result in meaningful emission reductions.
The Associations encourage the EPA to ensure that waste-derived biogenic CO2 (e.g., from municipal solid waste (MSW) landfills) is treated as carbon neutral under the final PSD Permitting Revisions Rule to be consistent with prior Agency determinations specified in this memorandum and documents as follows:S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014.
S. EPA, Memorandum Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources, McCabe, Janet, November 19, 2014. The documents highlight waste-derived, biogenic CO2 as a type of “carbon neutral” feedstock based on the conclusions supported by a variety of technical studies and conclusions of the Agency’s latest draft Framework for Assessing Biogenic Carbon Dioxide for Stationary Sources, which was released with the memo. The Agency memo stated that “the Agency expects to recognize the biogenic CO2 emissions and climate policy benefits of such feedstocks in [the] implementation of the CPP.”
US EPA, Emission Guidelines for EGUs, 80 FR 64855. Both the revised Framework, and the EPA’s Scientific Advisory Board (SAB) peer review of the 2011 Draft Framework, found “that the use of biomass feedstocks derived from the decomposition of biogenic waste in landfills, compost facilities, or anaerobic digesters did not constitute a net contribution of biogenic CO2 emissions to the atmosphere.”
S. EPA, Appendix N. of Revised Framework for Assessing biogenic Carbon Dioxide for Stationary Sources, November 2014, pg. N-25. In Appendix N. of the Framework, entitled Emissions from Waste-Derived Biogenic Feedstocks, EPA calculated negative Biogenic Accounting Factors (BAF) for various examples of treatment of landfill gas via collection and combustion. EPA explains, “Negative BAF values indicate that combustion of collected landfill gas feedstock by a stationary source results in a net CO2e emissions reduction relative to releasing collected gas without treatment.”
US EPA, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units; Final Rule [Emission Guidelines for EGUs], 80 FR 64885. “[T]he use of some biomass-derived fuels can play a role in controlling increases of [in] CO2 levels in the atmosph The use of some kinds of biomass has the potential to offer a wide range of environmental benefits, including carbon benefits.”
US EPA, Emission Guidelines for EGUs, 80 FR 94855. Types of waste-derived biogenic feedstocks may include: landfill gas generated through decomposition of MSW [municipal solid waste] in a landfill; biogas generated from the decomposition of livestock waste, biogenic MSW, and/or other food waste in an anaerobic digester; biogas generated through the treatment of waste water, due to the anaerobic decomposition of biological materials; livestock waste; and the biogenic fraction of MSW at waste-to-energy facilities.
NWRA and SWANA believe the final PSD Revisions document should follow the approach to waste-derived feedstocks enshrined in the Final Clean Power Plan, and as recommended by the SAB, and ensure that waste-derived biogenic CO2 is treated as carbon neutral. Based on EPA’s own lifecycle assessments for the Renewable Fuels Standard program, its U.S. GHG Inventory, and confirmed by the SAB, EPA has sufficient analysis to support exclusion of selected categories of biogenic emissions from PSD permitting, including those from managing landfill gas and organic components of MSW.
The EPA does not seem to consider the regulatory treatment of biogenic CO2 from stationary sources to be a key issue in the context of the PSD revisions rule, based on a comment found in a Summary of Interagency Working Comments on Draft Language. Instead, the EPA continues to believe this rulemaking to establish a GHG SER under the PSD program is not the appropriate venue to address the broader concern of the regulatory treatment of biogenic CO2 from stationary sources.
The Associations strongly disagree and are concerned that because EPA remains silent on this important issue, some permitting authorities might improperly require landfills to incorporate biogenic CO2 emissions in the PSD permitting process. Historically, few landfills triggered PSD because non-methane organics emissions rarely reached the threshold. However, if biogenic CO2 emissions become subject to PSD, many landfill projects, which are “anyway sources” due to renewable energy projects, would also be forced to do BACT analysis for GHG. Biogenic CO2 is emitted from:
From the perspective of developing new renewable transportation fuel or energy projects, subjecting biogenic emissions from landfills to PSD could be an enormous barrier. The Associations would like the EPA to clarify in its final rule that the emissions of biogenic CO2 from treating or controlling landfill gas does not increase the CO2 levels in the atmosphere, but instead, has positive emission reduction and climate benefits. Failing to clarify this important point could subject landfills to significant permitting delays and increased costs that will result in no meaningful emission reductions.
Questions? Contact SWANA, NWRA, Patrick Sullivan, or your local SCS office.
Our latest SCS Technical Bulletin summarizes the EPA federal mandatory greenhouse gas (GHG) reporting program (GHGRP) into two pages of the most vital information. The new reporting requirements for Subparts HH and A discussed in our bulletin are effective January 1, 2017.
Remaining updates will be phased in from 2017 to 2019. These updates include, but are not limited to, revisions to the reporting regulation for all reporters including Subpart A Administrative Requirements, Subpart C Stationary Combustion Sources, and Subpart HH Municipal Solid Waste Landfills the three most common reporting sectors for MSW landfills. SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed.
Use our resources for guidance or to answer questions.
Share, read, or print the Technical Bulletin
Greenhouse Gas Service Information
Dr. Dale W. Daniel, an Associate Professional with SCS’s Oklahoma City office, recently published a summary article of his dissertation research through the U.S. Department of Agriculture’s Conservation Effects Assessment Project. The primary goal of the research was to provide under-standing of the potential climate mitigation services provided through wetland conservation and restoration in the High Plains region of the United States. Focus was placed on greenhouse gas (GHG) emissions from wetlands and adjacent upland landscapes as well as identifying some of the drivers of GHG flux that are influenced by various land management practices. The project also sought to understand how sediment removal from wetland basins influenced Carbon and Nitrogen content as well as Carbon sequestration services.
In 2007, the Society for Ecological Restoration International (SER) stated that global climate change is a real and immediate threat that requires action, and ecological restoration is one of the many tools that can help mitigate that change (SER 2007). However, recent debate within the conservation science community has arisen concerning whether restoring ecosystems for C offset projects may shift focus away from other important benefits to society (Emmett-Mattox et al. 2010). Indeed, not all ecosystem restorations make viable ecological offset projects for industries seeking to reduce their C emissions, and those that do, may not always occur in areas where restoration funding is needed the most. This study demonstrated that management practices focused on restoring natural landscape functions, including native species plantings and basin sediment removal, can increase climate mitigation services provided by wetland and upland ecosystems within a region heavily impacted by land use change.
The National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA) returned comments and recommendations on the Environmental Protection Agency’s (EPA) draft Part 71 Operating Permit for Ocean County Landfill and MRPC Holdings LFGTE Operations, Permit Number: P71-0CMH-001 (Draft Permit) to EPA Region 2 Permitting Section, Air Programs Branch. The letter was sent on January 28, 2016, to Mr. Steven C. Riva of the EPA.
NWRA and SWANA expressed concerned that the EPA’s issuance of the Draft Permit, and the circumstances under which it has been prepared, represent a significant departure from practical permitting policies and will constitute a disincentive to expand existing and develop future landfill gas-to-energy (LFGTE) projects around the country.
The jointly submitted comments from both not-for-profit Associations on the Draft Permit were intended to convey their members’ strong interest in these projects, which represent an economic investment in alternative renewable energy sources and the reduction in greenhouse gas (GHG) emissions. Both Groups have expressed concern that the EPA’s actions should not undermine those investments and the benefits derived from these LFGTE projects.
The main points of the letter cover the Associations’ disagreement with the EPA’s approach to common control. NWRA and SWANA support the position that the OCL and MRPC are two separate sources that are not under common control, and they oppose the position proposed by EPA Region 2 in the Draft Permit. Both Groups are urging EPA to re-evaluate this decision and utilize an environmentally beneficial approach when making common control determinations for landfills and third-party LFGTE plants both now and in the future. Other portions of the letter address the uncertainty that EPA’s position would create for affected facilities and how it could re-open already settled compliance expectations.
Members of NWRA and SWANA have access to the letter and may continue directing comments and questions through either Association.
Questions directed to SCS Engineers should be addressed to Pat Sullivan, Senior Vice President and the SCS National Expert on the Clean Air Act.
Learn more about SCS Clean Air Act Services, or Greenhouse Gas Services, or
Landfill Gas to Energy Services
The Global Warming Solutions Act of 2006, or Assembly Bill (AB) 32, is a California State Law that fights climate change by establishing a comprehensive program to reduce greenhouse gas emissions GHG from all sources throughout the state. AB 32 is the first state regulatory program in the country to take a comprehensive, long-term approach to addressing climate change. A major component of the program, the Landfill Methane Rule, requires landfill owner/operators to reduce methane emissions through proper operation of landfill gas LFG collection and control systems and collect and report GHG emissions data in a timely manner. GHG emissions are defined in the AB 32 to include all of the following: carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons.
SCS is a pioneer in our nation’s efforts to reduce GHG emissions in order to combat global warming. We proactively pursue the development of markets in which major sources of methane (e.g., oil and gas industry, landfills, dairies, etc.) can generate and sell GHG credits by voluntarily installing methane recovery systems and selling the methane as fuel.
Methane is 25 times more powerful than carbon dioxide in terms of its greenhouse effect. Capturing and destroying these emissions can have significant environmental benefits. Simply destroying methane via power generation or sequestration can diminish its GHG potential by 95 percent. Even greater benefits are available if the methane is used as renewable energy in order to offset natural gas or coal-fired power generation.
