Being a landfill operator or owner is a demanding job. Your position requires knowledge of engineering, biology, chemistry, business, technology, and psychology. Most people don’t realize the complexity of landfill operations and the systems, personnel, and equipment that keep everything in balance. That’s okay; it’s part of the job too. The public generates trash, and it is picked up, reused, recycled, or landfilled as communities dictate.
Right now, landfill operations are more challenging than ever – so we’re providing a bit of help from our SCS website library. We hope it helps, but you can always reach out to your project manager for additional assistance.
Strategies for EPA Regulation Limbo
Landfill owners and operators remain in a state of regulatory limbo. Some sites are complying with the New Source Performance Standards (NSPS) under Subpart XXX and dealing with the duplicate requirements from Subpart WWW and other issues. Several states have approved Subpart Cf Emission Guidelines (EG) rules, so landfills in those states must begin to comply with those state rules. Several other states have proposed state plan approvals and could see approved EG rules issued soon, as in Virginia. When EPA issues the federal plan for the EG, all of the remaining landfills in states without approved state plans will have to start to comply. This will put all NSPS/EG-applicable landfills into the same boat with the existing Subpart XXX sites. In addition, landfills are figuring out how the new National Emission Standards for Hazardous Air Pollutants (NESHAPs) rule overlays on top of the NSPS/EG requirements.
During this period of limbo, where multiple overlapping regulations exist, certain public and private landfill owners within the solid waste industry have endeavored to take a unified and consistent stand on compliance strategies with guidance coming from the Solid Waste Association of North America (SWANA) and the National Waste and Recycling Association (NW&RA). Gabrielle Stephens, Cassandra B. Drotman, and Patrick Sullivan of SCS provide a regulatory update and compliance strategies in their paper Uncertainty EPA has Created with New NSPS XXX and Cf Rules
Staff Shortages and Funding Dilemmas
Many of our clients are in their annual budget period. Needless to say, nearly all municipalities have concerns about the upcoming fiscal year expectations and anticipated medium-term impacts of COVID-19 on local government operations and revenue streams. They have shared goals to:
In response, our team of economists is helping our clients prepare for Fiscal Year 2020/2021, with a Micro-analysis for the near-term (1-2 year) budget/operational impacts. It’s free, and you’ll get results in 2-3 days.
SCS is offering free webinars to discuss revenue diversification alternatives, realistic cost projections, and funding opportunities. We will announce the first webinar in the next week, but if you’d like to get started now contact the SCS Management Services® Lead here for a private session.