SWANA: Biogenic Gases from WTE Are Renewable Energy

In written comments submitted on the Waxman-Markey discussion draft climate bill late in March, the Solid Waste Association of North America (SWANA) agreed with the decision to treat landfill gas as a renewable energy source but disagreed with the bill's treatment of biogenic emissions from waste-to-energy facilities.

The legislation would establish an economy-wide cap-and-trade system for greenhouse gases as well as a federal renewable portfolio standard (RPS). SWANA stated that as drafted, some parts of the legislation would impose regulations affecting the viability of certain environmentally sound solid waste management practices and impair their ability to support real greenhouse gas reductions at these facilities.

John H. Skinner, executive director and chief executive officer stated that "SWANA agrees with the decision of authors of the draft bill to categorize landfill gas as renewable energy, eligible for greenhouse gas and inclusion in the RPS." However, Skinner added "SWANA strongly believes that the biogenic emissions from waste-to-energy facilities should also be categorized as renewable energy and eligible for similar credits."

The association recommended the following:

  • Landfills should not be a regulated source under the cap-and-trade system.
  • Waste-to-energy facilities should not be a capped source in any greenhouse gas reduction program.
  • Landfill gas and waste-to-energy are valuable sources of energy and should be included in any federal renewable portfolio standard.
  • Drafted reporting requirements should be reconciled with EPA Proposed Reporting Rule for greenhouse gas emissions.
  • Allow waste-to-energy to remain eligible in the federal renewable purchasing program.
  • Source categories with promulgated New Source Performance Standards (NSPS) that reduce GHG emissions should not be subject to additional NSPS.
  • Exclude greenhouse gases from regulation under Clean Air Act programs.
  • Identify modern solid waste operations as greenhouse gas offsets.
  • A National GHG Credits Trading Program must be rule-based and transparent.

The letter can be viewed at SWANA's Web site (link opens PDF document).

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