SWANA and NWRA Submit Joint Comments to the EPA on Emissions Guideline Revisions
The Solid Waste Association of North America (SWANA) and the National Waste & Recycling Association (NWRA) submitted joint comments to the U.S. Environmental Protection Agency (EPA) on the proposed revisions of the Emissions Guidelines (EG) and Compliance Times for Municipal Solid Waste Landfills and to the supplemental proposal to the Standards of Performance for Municipal Solid Waste Landfills.
The proposed emissions guidelines will apply to landfills built on or before July 17, 2014, and will be the first major update since its promulgation in 1996. The supplemental proposal to the new source performance standards (NSPS) lowers the emissions threshold to 34 metric tons (megagrams) a year, keeping it in line with the emissions guidelines.
“SWANA supports many of the proposed revisions in EPA’s proposed rules governing emissions at municipal solid waste landfills, said SWANA Executive Director and CEO David Biderman. “Our comments provide a number of suggestions that would streamline the regulations and reduce compliance burdens; and we hope the EPA will consider incorporating them into the final rules.”
"NWRA's members, the private waste and recycling industry, many of whom also operate landfills, are hopeful that our constructive joint input with SWANA to EPA will result in achieving EPA's policy goals while reflecting the practical issues and the evolution of the waste stream over the past twenty years," said Anne Germain, Director of Technology for NWRA.
The joint comments highlight the impressive emissions reductions that the landfill industry has achieved over the past 20 years. Both organizations are concerned that the proposed lower threshold will not provide benefits sufficient to warrant the additional costs, but are supportive of the operational flexibilities proposed. The comments outline a number of specific actions that the EPA can take in the new emissions guidelines to advance economically and environmentally sound landfill gas collection and control.