Apr 25 - ARB Early Action Measure to Target Landfill Methane

The ARB released its latest Early Action Measure (EAM) Report on Friday. The ARB is proposing to adopt a total of three discrete EAMs: Low Carbon Fuels, Automobile Refrigerants, and Landfill Methane Capture.

The proposed landfill EAM is focused on reducing GHG emissions from 41 landfills statewide that do not have landfill gas systems. According to the ARB, this represents 6% of the total waste in place in California. The EAM is actually a three part measure with capture from the 41 landfills being the first phase. The ARB has not quantified the GHG emission reductions associated with this first phase. Phases two and three will involve increasing capture efficiencies and conversion of LFG to energy. The three phases together are estimated to reduce GHG emissions by 2-4 MMTCO2E. By comparison, landfills statewide are estimated (by the CEC) to emit 8.4 MMTCO2E annually.

We support the ARB in recognizing landfills as a major contributor to GHG emissions, and devoting one of the three EAM to the waste sector. However, limiting the EAM to landfills without gas collection systems artificially limits the scope of the EAM and will greatly reduce its effectiveness. The majority of GHG emissions in CA from landfills are coming from landfills with gas collection systems, not from those without systems. Landfills are large complex facilities. Just because a landfill has a gas capture system within its permitted boundaries does not mean that all the waste in place is subject to the gas capture system.

Instead of focusing on landfills without gas systems, the EAM should focus on all waste in place in California that is not subject to the influence of a gas system--whether that waste is in a landfill with an installed system or not. CAW has urged the ARB to expand the scope of the EAM to include increasing gas capture for all waste in place in the state that is not subject to a landfill gas capture system.