National Waste Associations Comment on Proposed Revision to U.S. EPA Landfill Regulations

National Waste & Recycling Association, Solid Waste Association of North America collaborate
Sep 17, 2014 4:05 PM ET

WASHINGTON, September 17, 2014 /3BL Media/ — The National Waste & Recycling Association (NW&RA) and the Solid Waste Association of North America (SWANA) 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.

The NW&RA/SWANA joint comments are available at http://bit.ly/NSPSComments.

NW&RA and SWANA 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. Sharon H. Kneiss, NW&RA president and CEO, and John Skinner, Ph.D., SWANA executive director and CEO, cosigned the submission to EPA.

“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.

“EPA’s proposed new rule and cost analysis substantially underestimates the number of existing landfills that will be affected,” Skinner added. “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.”

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. Full comments provided to the EPA by NW&RA and SWANA are available here.

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The National Waste & Recycling Association is the trade association that represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that collect and manage garbage, recycling and medical waste, equipment manufacturers and distributors and a variety of other service providers. For more information about NW&RA, visit www.wasterecycling.org.

The Solid Waste Association of North America is a professional education association with members working in the solid waste management industry across North America. For more information about SWANA, visit www.swana.org.