The changing picture of greenhouse gas reporting for landfills


With the implementation of Federal Mandatory Greenhouse Gas (GHG) reporting in 2010, landfill owners can find themselves subject to GHG reporting regulations at the federal level, and in some cases, also at the state or local level.

This article will review the Federal Mandatory Reporting Rule (MRR) requirements for municipal solid waste (MSW) landfills subject to mandatory reporting under 40 Code of Federal Regulations (CFR), Part 98, Subpart HH, including recent changes to the reporting rule, reporting and monitoring requirements for those landfills subject to reporting, and what landfills need to do to prepare for reporting. The rule will be treated like any other Clean Air Act (CAA) program with self-reporting and fines for non-compliance, so non-compliance could be a very serious issue.

Who Does the Rule Affect?

The final Federal MRR was signed on September 22, 2009, and was published as 40 CFR Parts 86, 87, 89, et al., “Mandatory Reporting of Greenhouse Gas; Final Rule,” on October 30, 2009. It has undergone continuous changes throughout 2009 and 2010 as the U.S. EPA has issued Frequently Asked Questions (FAQs) and modifications to the rule. On October 7, 2010, the EPA finalized technical corrections to the MRR. The FAQs are now available in a searchable tool on the EPA Web site. The technical corrections and FAQs did not substantially change the reporting requirements of the Federal MRR for landfills, but they addressed several common practices and may require modification of required Monitoring Plans.

The Federal MRR affects GHG sources with more than 25,000 metric tons carbon dioxide (CO2) equivalent (MTCO2e) emissions. The rule includes reporting for 31 source categories, including MSW landfills in Subpart HH and industrial landfills in Subpart TT. This article will focus on MSW landfills. It is expected that 2,551 MSW landfills will be affected by the EPA MRR out of the 10,000 facilities that are expected to report (EPA Office of Air and Radiation, 2009), which means landfills are disproportionally impacted compared to the other 30 source categories.

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