Oct 23 - Mandatory Reporting Regs Released: Landfills Excluded

Despite CAW’s strong advocacy, the ARB has decided not to include landfills under their Mandatory Reporting program. We are discouraged that the Board is passing up on an opportunity to quantify emissions from the largest anthropogenic source of methane.

Last Friday, the ARB released its draft Mandatory Reporting regulations for an official 45-day comment period before they are taken up by the ARB at its December board hearing. These regulations lay out which industries will be among the first to report their emissions under the “Mandatory Greenhouse Gas Emissions Reporting” provision of AB 32, and landfills are not included.

CAW encouraged the inclusion of landfills among the first-reporting industries because of the significant climate-forcing impact of their methane emissions, but the staff cited a lack of resources and high levels of uncertainty in landfill gas models as reasons for delaying this reporting. CAW argued that the ARB could use this mandatory reporting program to gather information to substantially increase the certainty about landfill emissions. Nonetheless, the ARB decided not to include the landfill sector under this program this year.

The draft regulations give the following explanation for why landfills were omitted:

Landfill GHG Emissions Reporting. ARB staff gave strong consideration to inclusion of solid waste landfills in first-year reporting requirements. Several dozen landfills will beà´Šreporting combustion emissions from power generation or flaring because they meet the applicable thresholds. But California has over 200 landfills with sufficient methane generation to have gas collection systems in place, and ARB estimates that fugitive emissions of methane from landfills represents 1 to 2 percent of the statewide GHG inventory. The California Integrated Waste Management Board has pointed to data gaps in current models, and is working with the California Energy Commission on a three-year research project to help better understand methane formation and movement at California landfills. ARB staff is serving on the advisory panel to this study, which should improve the tools available to estimate landfill methane emissions. Staff consulted the principal investigator, who indicated that detail on waste-in-place and cover area by cover type would help with model estimation when the study is complete in 2010. In addition, ARB emissions inventory staff would like to routinely collect specific information on gas capture and control systems.

ARB has adopted methane capture from landfills as a discrete early action item, and a control measure is under development for adoption in 2008. ARB staff has decided to defer landfill information reporting requirements to further consideration in the development of the landfills early action measure, to avoid duplication of requirements and provide more time to consider what data are needed. For these reasons the current staff proposal does not require reporting by landfills, except when the landfill operator has operational control of electric generating facilities and general combustion sources using landfill gas. Landfill operators with electricity generators rated 1 MW or higher and emitting at least 2,500 metric tonnes per year of CO2 would be required to report emissions according to the methods prescribed in section 95111. Operators with flaring or other combustion emissions exceeding 25,000 metric tonnes per year of CO2 would report under the general combustion requirements specified in section 95115. Any landfills with cogeneration facilities would be subject to the separate requirements specified in section 95112.

CAW still feels that quantifying the emissions from landfills is a very important step towards achieving California’s AB 32 goals, and we will continue to work with ARB staff to ensure that reporting from this sector is included in the second year of this program and is substantially addressed in the Early Action Measure.

[Read the Draft Regulations that were released on Friday.]

[Read CAW’s letters regarding Mandatory Reporting.]