The Solid Waste Association of North America (SWANA) and the National Waste & Recycling Association (NW&RA) have jointly provided comments to the U.S. Environmental Protection Agency on its proposed rules to update the Standards of Performance for Municipal Solid Waste Landfills. SWANA and NW&RA represent the private and municipal (public) sectors of the waste and recycling industry in the United States and share concerns about unnecessary new regulations in EPA’s proposed rule. John H. Skinner, Ph.D., SWANA executive director and CEO, and Sharon H. Kneiss, NW&RA president and CEO, cosigned the submission to EPA. “EPA’s proposed new rule and cost analysis substantially underestimates the number of existing landfills that will be affected,” Skinner said. “Significant investments have already reduced methane emissions from existing landfills by more than 30 percent since 1996. Applying these new facility requirements to existing landfills could disrupt the progress already made and make it more difficult and expensive to achieve greater emission reductions.”
“Landfills are a critical component in the spectrum of waste management options in the United States, but the latest round of regulations proposed by the EPA create significant, undue burden that will prove harmful to continued development of renewable energy projects and efficient management of America’s waste,” Kneiss said. The joint comments express concern that the proposed rule establishes several unnecessary agency review processes and reporting redundancies that will hamper facility efficiency. These added processes and redundancies will slow operational changes, reduce efficiencies, increase costs and expose landfills to potential violations while not providing any environmental benefit. Further, the comments note that the EPA did not consider the financial impact of its proposed rule on existing facilities that expand or make site modifications, which are the vast majority of those that will be affected, when assessing programmatic costs. EPA’s cost analysis considered only the projected impact on landfills opening in 2014 or later, which is a relatively small number. The comments also warned that EPA’s proposed treatment standards would require highly expensive additions to and maintenance of renewable energy infrastructure, potentially damaging the momentum behind repurposing America’s waste as a resource. These new standards would dramatically increase costs and administrative oversight at modified waste facilities, possibly leading them to cease operations and precluding new renewable energy projects from being developed. It is anticipated that EPA will publish the final rule early next year after issuing its proposed rule July 17 of this year.
Comments provided to the EPA by SWANA and NW&RA are available here at http://bit.ly/NSPSComments. For more information, visit www.swana.org or www.wasterecycling.org.