In written comments submitted on the Waxman-Markey discussion draft climate bill released March 31, 2009, the Solid Waste Association of North America (SWANA) agreed with the decision to exclude landfills as a regulated source and to treat landfill gas as a renewable energy source. However, the association disagreed with the bill’s proposal to regulate biogenic emissions from waste-to-energy facilities and its failure to include waste-to-energy under the renewable portfolio standard.
This draft legislation would establish an economy-wide cap-and-trade system for greenhouse gases as well as a federal renewable portfolio standard. SWANA stated that as drafted, some parts of this legislation would impose regulations affecting the viability of certain environmentally sound solid waste management practices and impair their ability to support real greenhouse gas reductions at these facilities.
John H. Skinner, Executive Director and CEO stated that: “SWANA agrees with the decision of authors of the draft bill to categorize landfill gas as renewable energy, eligible for greenhouse gas and inclusion in the RPS”. However, Skinner added “SWANA strongly believes that the biogenic emissions from waste-to-energy facilities should also be categorized as renewable energy and eligible for similar credits”.
SWANA made the following recommendations on the Waxman-Markey Discussion Draft:
- Landfills should not be a regulated source under the cap-and-trade system.
- Waste-to-energy facilities should not be a capped source in any greenhouse gas reduction program.
- Landfill gas and waste-to-energy are valuable sources of energy and should be included in any federal renewable portfolio standard.
- Drafted reporting requirements should be reconciled with EPA Proposed Reporting Rule for greenhouse gas emissions.
- Allow waste-to-energy to remain eligible in the federal renewable purchasing program.
- Source categories with promulgated NSPS standards which reduce GHG emissions should not be subject to additional NSPS standards.
- Exclude greenhouse gases from regulation under Clean Air Act programs.
- Identify modern solid waste operations as greenhouse gas offsets.
- A National GHG Credits Trading Program must be rule-based and transparent.
To view the letter SWANA sent to House Energy and Commerce Chairman, Henry Waxman and House Energy and Commerce Ranking Member, Joe Barton, visit www.SWANA.org/waxman-markey
For over 40 years, the Solid Waste Association of North America (SWANA), has been the leading professional association in the solid waste management industry. SWANA’s mission is “to advance the practice of environmentally and economically sound management of municipal solid waste.” SWANA serves more than 8,000 members and thousands more industry professionals with technical conferences, certifications, publications and a large offering of technical training courses. For more information, visit www.SWANA.org