Keeping the Lines of Communication Open Between Industry and the Federal EPA
December 20, 2017
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:
Outreach in early stages of the GHGRP development through recent decisions to utilize GHG emissions data from the GHGRP in the EPA’s current draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015 (GHG Inventory).
The initial implicit assumptions made by both the EPA and Stakeholders, using the reporting of “back-up devices” and the calculation of the fraction of time a destruction device was operating as an example of the assumptions made and an illustration of how those assumptions were implemented implicitly in the GHGRP.
How stakeholders have reached out to the EPA to address incorrect or misleading assumptions.
A summary of how stakeholders work to provide the EPA with additional data necessary to justify changes to the regulation, including revisiting oxidation factors that were rejected in the initial GHGRP and reducing methane measurement frequency at landfills.
How changes have improved landfill reporting under the GHGRP to make it more representative of actual emissions and more reflective of the sites that are reporting.
The unintended consequences of stakeholder outreach and revisions to the GHGRP for landfills.
2016 GHG emissions reports due on March 31, 2017, must be completed in accordance with the updated Rule.
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.
Ray Huff, Vice President and National Expert on Greenhouse Gas
Patrick Sullivan, Senior Vice President and National Expert on the Landfill Clean Air Act and the New Source Performance Standard (NSPS). or your SCS Project Manager in the SCS office