supports proposed changes to reporting rule
The Solid Waste Association of North America
(SWANA) submitted comments to the Environmental Protection Agency
regarding proposed revisions to the mandatory greenhouse gas
reporting rule in September.
SWANA agreed with the following revisions proposed by EPA:
- Waste-to-Energy (WTE) units processing 600 tons per day
or less should be able to use the Tier 2 reporting method.
- Municipal Solid Waste (MSW) should be removed from the
definition of fossil fuel in the rule and MSW and tires should
be listed as “other fuels” not “fossil fuel derived”.
- Facilities should be able to use default moisture values
if they measure CO2 on a dry basis, consistent with requirements
under the Acid Rain Program.
“We encourage EPA to move ahead with these changes and to issue
a final rule as soon as possible so that waste-to-energy facilities
know for certain what is required of them” said John H. Skinner,
SWANA executive director and CEO. “Waste-to-energy facilities
can make an important contribution to reducing greenhouse gas
emissions and providing renewable energy” added Skinner.
SWANA was not in agreement with all of the revisions proposed
by EPA. One such revision was the requirement to report aggregate
carbon dioxide emissions, instead of separating out biogenic
emissions from anthropogenic ones. The majority of emissions
from WTE are biogenic in nature and for more accurate reporting
SWANA supports reporting them separately.
These changes are the result of a settlement between EPA and
the Energy Recovery Council, the national trade association representing
the waste-to-energy industry. The notice published on August
11, 2010 allows the opportunity for additional public comments
on the revisions. If EPA doesn’t make these changes final, ERC
can continue the lawsuit.