SWANA Calls for Permanent Exemption for Biogenic Carbon Dioxide Emissions
The Solid Waste Association of North America (SWANA), Silver Spring, Md., has requested that the Environmental Protection Agency’s (EPA’s) Scientific Advisory Board (SAB) support a categorical exclusion for biogenic carbon dioxide (CO2) emissions from the management of municipal solid waste from the Prevention of Significant Deterioration and Title V GHG Tailoring Rule. SWANA says the exemption should apply to biogenic CO2 generated from the combustion of landfill gas and from waste-to-energy facilities.
SWANA called for this exemption in May 18, 2012, comments submitted in response to the SAB review of EPA’s draft accounting framework for Biogenic CO2 Emissions from Stationary Sources. In support of the exemption, SWANA described the reductions of greenhouse gas emissions from solid waste management activities over the past several decades.
According to SWANA, since the 1970s, greenhouse gas emissions from this sector have been reduced by 75 percent, while total generation of solid waste has more than doubled.
“These reductions have been achieved through an integrated system of solid waste management that includes landfill gas recovery, waste-to-energy and increased diversion from landfills through recycling and composting,” says SWANA Executive Director and CEO John Skinner.
The SAB recommended that EPA consider identifying those feedstock categories for which the biogenic accounting framework (BAF) would automatically be set to zero. SWANA says it agrees with this recommendation and notes that the use of waste as a fuel source is widely accepted as carbon neutral and actually reduces greenhouse gas emissions on a life-cycle basis.
SWANA says the landfill gas combustion category warrants an automatic BAF of zero, given the extensive life-cycle analyses already conducted by EPA. For waste-to-energy, the panel recommended that EPA should take into account the mix of biogenic and fossil carbon when waste is combusted and SWANA agrees with this recommendation.
The SAB also recommends that for landfill gas combustion, EPA should incorporate emissions and partial capture of methane from landfills. SWANA disagrees with this recommendation and says there is no scientific or policy basis for regulating biogenic CO2 emissions based on methane collection efficiency, which has no impact on CO2 emissions from landfills.
SWANA also recommends that the EPA Framework account for carbon sequestration of municipal solid waste disposed in landfills. Carbon sequestration is quantifiable, the biological process is well-understood and described in agency documents and peer-reviewed scientific literature and its offsetting effects are easily assigned at the facility level.
SWANA’s comments to the SAB can be found at http://swana.org/portals/Press_Releases/SWANA_SABFramework_Comments.pdf.
ERC Applauds Senate Finance Committee Action
The Energy Recovery Council (ERC) and three other renewable energy trade associations commended a 19-5 vote by the Senate Finance Committee in August that extends and enhances production tax credits (PTCs) for all renewable energy sources. The tax credits are essential for the development of waste-to-energy and other clean energy-generating facilities by offsetting the high cost of construction, says the council in a news release.
The action by the committee will give renewable baseload technologies equitable access to this important program by allowing eligible facilities to qualify for the tax credits when construction is commenced, adds the council.
“The Energy Recovery Council commends the Senate Finance Committee for including important changes to the production tax credit that will allow all renewable technologies to benefit from this important program,” says Ted Michaels, ERC president. “Modifying the definition of placed in service will provide more opportunities for waste-to-energy facilities to utilize the renewable tax credit, which will in turn drive sustainable waste management practices in the United States.”
The Biomass Power Association, the National Hydropower Association and the Geothermal Energy Association joined ERC in the joint statement.
The U.S. Energy Information Adminstration estimates baseload energy sources produce almost 75 percent of the nation’s renewable electricity.