Smith Gardner Inc

Menu

Revisions to the Greenhouse Gas Reporting Rule Increase Reporting Requirements for Landfills

EPA recently made amendments to 40 CFR Part 98, the Greenhouse Gas Reporting Rule. These changes may have major implications on emissions calculations and reporting across all sectors, including municipal solid waste (MSW) landfills (Subpart HH) and industrial landfills (Subpart TT). A pre-publication copy of the amendments was made public on November 15, 2013, and may be downloaded here, along with fact sheets and additional information.

This final rule is effective on January 1, 2014.

The most significant change impacts the likelihood of pollutant emissions to exceed reporting thresholds. A total of 23 global warming potential (GWP) values (100-year time horizon) have been revised in Table A-1 to Subpart A of the Rule. These values are used to convert calculated GHG emissions to carbon dioxide equivalent (CO2e) values, which are then compared to the reporting threshold of 25,000 CO2e. The most notable change affecting Subparts HH and TT is to the GWP for methane, which is increased from 21 to 25. The impact is felt by landfills that were previously below the reporting threshold.  Under the old GWP of 21, landfills that generated 1,190 metric tonnes of methane would not be required to report.  Now, with the new methane GWP of 25, landfills generating 1,000 metric tonnes of methane would be subject to the reporting rule.

In response to comments, landfills and other facilities that were beneath the reporting threshold for reporting year 2012 but now exceed the reporting threshold due only to the increase in GWP are not required to report 2013 emissions. For landfills specifically, the following conditions are in place for this exemption to apply:

  1. No waste was accepted on or after January 1, 2013;
  2. The landfill generated less than 1,190 tonnes of methane in 2013;
  3. The landfill was not required to report in any reporting year prior to 2013.

Landfills not meeting the above exemption that are newly subject to reporting as a result of the changes to GWP values are required to begin collecting data on January 1, 2014 for the 2014 reporting year. These reporters are required to submit their first reports, covering the 2014 reporting year, by March 31, 2015.

Additional changes are made to several factors used in calculating GHG emissions, including Degradable Organic Carbon (DOC) and density of methane. Data collection frequency requirements have also been relaxed from weekly to monthly for methane and other parameters.

For additional information, please send an email to matt@smithgardnerinc.com or call (919) 828-0577.

Share this