*Summit To Be Held April 14, 2010 in Reno, Nevada in Conjunction with April Events
Silver Spring, MD - The Solid Waste Association of North America (SWANA) has announced that it will host the North American Carbon Credit Summit on Wednesday, April 14, 2010 in Reno, Nevada. The one day event will provide the most current information available on the constantly evolving carbon credit market as it applies to municipal solid waste professionals.
Developed to address the growing interest SWANA has observed in carbon credit markets, the Summit will present five sessions including an overview of the environmental commodities markets and legislative and regulatory developments as well as individual case studies. Presenters at the Summit will include representatives from organizations involved in credit verification, project consulting, greenhouse gas inventories, RECs and trading platforms, among others.
The Summit will be held in conjunction with SWANA’s 15th Annual Landfill Symposium and Planning & Management Conference, which will take place Monday, April 12 and Tuesday, April 13, 2010. Individuals who register for the North American Carbon Credit Summit will also receive complimentary registration to the Landfill Symposium and Planning & Management Conference. For more information on the Summit, visit http://lfpm.SWANA.org/Carbon.
Showing posts with label greenhouse gas emissions. Show all posts
Showing posts with label greenhouse gas emissions. Show all posts
Monday, February 1, 2010
Tuesday, January 19, 2010
SWANA Comments on EPA’s Tailoring Rule
Shannon Crawford, Manager of Legislative and Regulatory Programs
On Wednesday, December 23, 2009, SWANA submitted comments to EPA on their Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule. This proposal is targeted at facilities with emissions over 25,000 tons of CO2e annually and would require them to obtain permits that would demonstrate they are using the Best Available Control Technologies (BACT) to minimize GHG emissions.
Previously GHG were not subject to provisions of the Clean Air Act. However, EPA holds that GHG will be upon promulgation of the light duty vehicle rule, anticipated in the spring of this year, “regulated pollutants”, and as such would be subject to PSD and Title V requirements. We agree that if EPA were to move forward with this rulemaking, a “tailoring” of the thresholds for each of these programs must be performed to avoid the unintended consequence of subjecting a large number of small sources to the regimens of PSD and Title V.
In our letter we chose not to comment on EPA’s interpretation of their legal authority. We are aware that there are a number of challenges to this interpretation, which contain very convincing arguments that EPA may be over-stepping their legal boundaries. While we did not address this issue, our comments should not be misconstrued as acceptance of EPA’s interpretation of their legal authority.
We have a number of concerns with EPA’s proposal as currently written with our most significant being: 1) the alternative thresholds proposed by EPA for the first phase are too low and do not represent “major sources” and 2) the development of BACT must occur with the involvement of the solid waste industry.
We believe that the proposed threshold level of 25,000 tpy CO2e represents smaller sources and is not keeping with Congressional intent for PSD and Title V to be “major source” programs. There is no basis for such a low threshold and EPA has not presented enough rationale for choosing 25,000 tpy. EPA has chosen this threshold based on the number of facilities they believe will be impacted instead of using the Congressional intent of this provision to only regulate “major sources”.
Utilizing equivalent criteria pollutants from combustion sources yields CO2 emissions ranging from 100,000 to over 700,000 tpy CO2. Utilizing EPA’s existing PSD major source threshold for NMOCs, established for landfills, yields an equivalent CO2 level over 745,000 MTCO2e. Using these approaches as guidance, SWANA recommended that EPA provide an alternative threshold that truly represents a “major source”.
Workgroups are currently developing presumptive BACTs. BACT for CO2e are not well-established and therefore the solid waste industry must be represented on these workgroups. EPA themselves have said that landfills are one of the largest effected sectors, therefore it is inappropriate to not include representatives from this industry to participate in the development of BACT. This workgroup alone should not develop presumptive BACT; they should be promulgated as regulations with notice and opportunity for comment.
Additionally, there is the potential for unfair treatment of waste-to-energy under this ruling. Waste-to-energy operations would be affected during the second phase of the rule, the presumptive BACT implementation. Most plants operate with a Title V permit, so they would not need to apply for one during the initial phase of the rule. However these operations would be affected when EPA attempts to impose BACT on their GHG emissions. Waste-to-energy operations provide an essential public service and have been shown to be a net reducer of GHG on a life cycle basis. Additionally their emissions are largely biogenic. We strongly believe that raising the threshold and differentiating between anthropogenic and biogenic will help reduce the potential unfair treatment this proposed rule would have on this form of renewable energy.
To read our full letter to EPA please click here.
For more information on the Tailoring Rule, please see our previous memo dated October 7, 2009.
Please contact me directly with any questions.
Shannon Crawford
Manager of Legislative and Regulatory Programs
240.494.2241 - direct
Shannon Crawford, Manager of Legislative and Regulatory Programs
On Wednesday, December 23, 2009, SWANA submitted comments to EPA on their Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule. This proposal is targeted at facilities with emissions over 25,000 tons of CO2e annually and would require them to obtain permits that would demonstrate they are using the Best Available Control Technologies (BACT) to minimize GHG emissions.
Previously GHG were not subject to provisions of the Clean Air Act. However, EPA holds that GHG will be upon promulgation of the light duty vehicle rule, anticipated in the spring of this year, “regulated pollutants”, and as such would be subject to PSD and Title V requirements. We agree that if EPA were to move forward with this rulemaking, a “tailoring” of the thresholds for each of these programs must be performed to avoid the unintended consequence of subjecting a large number of small sources to the regimens of PSD and Title V.
In our letter we chose not to comment on EPA’s interpretation of their legal authority. We are aware that there are a number of challenges to this interpretation, which contain very convincing arguments that EPA may be over-stepping their legal boundaries. While we did not address this issue, our comments should not be misconstrued as acceptance of EPA’s interpretation of their legal authority.
We have a number of concerns with EPA’s proposal as currently written with our most significant being: 1) the alternative thresholds proposed by EPA for the first phase are too low and do not represent “major sources” and 2) the development of BACT must occur with the involvement of the solid waste industry.
We believe that the proposed threshold level of 25,000 tpy CO2e represents smaller sources and is not keeping with Congressional intent for PSD and Title V to be “major source” programs. There is no basis for such a low threshold and EPA has not presented enough rationale for choosing 25,000 tpy. EPA has chosen this threshold based on the number of facilities they believe will be impacted instead of using the Congressional intent of this provision to only regulate “major sources”.
Utilizing equivalent criteria pollutants from combustion sources yields CO2 emissions ranging from 100,000 to over 700,000 tpy CO2. Utilizing EPA’s existing PSD major source threshold for NMOCs, established for landfills, yields an equivalent CO2 level over 745,000 MTCO2e. Using these approaches as guidance, SWANA recommended that EPA provide an alternative threshold that truly represents a “major source”.
Workgroups are currently developing presumptive BACTs. BACT for CO2e are not well-established and therefore the solid waste industry must be represented on these workgroups. EPA themselves have said that landfills are one of the largest effected sectors, therefore it is inappropriate to not include representatives from this industry to participate in the development of BACT. This workgroup alone should not develop presumptive BACT; they should be promulgated as regulations with notice and opportunity for comment.
Additionally, there is the potential for unfair treatment of waste-to-energy under this ruling. Waste-to-energy operations would be affected during the second phase of the rule, the presumptive BACT implementation. Most plants operate with a Title V permit, so they would not need to apply for one during the initial phase of the rule. However these operations would be affected when EPA attempts to impose BACT on their GHG emissions. Waste-to-energy operations provide an essential public service and have been shown to be a net reducer of GHG on a life cycle basis. Additionally their emissions are largely biogenic. We strongly believe that raising the threshold and differentiating between anthropogenic and biogenic will help reduce the potential unfair treatment this proposed rule would have on this form of renewable energy.
To read our full letter to EPA please click here.
For more information on the Tailoring Rule, please see our previous memo dated October 7, 2009.
Please contact me directly with any questions.
Shannon Crawford
Manager of Legislative and Regulatory Programs
240.494.2241 - direct
Thursday, July 31, 2008
What's your MTCO2E?
No, it's not the latest pick up line.
No, it's not any of that new-fangled text messaging code.
MTCO2E is short for Metric Ton of CO2 (Carbon Dioxide) Equivalents. This is the standard measurement for carbon equivalent emissions. In the case of traveling, your mode of transportation and length of stay will create a certain amount of emissions. If you haven't already calculated your MTCO2E for your WASTECON travel, you can take a few moments and use our new online calculator. With the help of our WASTECON Carbon Advisors, HDR, we have created this online tool for each attendee to figure out his or her own emissions for travel to WASTECON.
But wait, I know what you're thinking! Aren't we supposed to be reducing our emissions? Yep! That's right. So, I thought about how we could reduce our emissions from our WASTECON Travel. One idea that I came up with is to start a Ride-Sharing thread on our new WASTECON Group site. Here you can offer a ride or get a ride to the event. You might also find other attendees who you could share a taxi to or from the airport.
That's one idea. What are some of your ideas??
No, it's not any of that new-fangled text messaging code.
MTCO2E is short for Metric Ton of CO2 (Carbon Dioxide) Equivalents. This is the standard measurement for carbon equivalent emissions. In the case of traveling, your mode of transportation and length of stay will create a certain amount of emissions. If you haven't already calculated your MTCO2E for your WASTECON travel, you can take a few moments and use our new online calculator. With the help of our WASTECON Carbon Advisors, HDR, we have created this online tool for each attendee to figure out his or her own emissions for travel to WASTECON.
But wait, I know what you're thinking! Aren't we supposed to be reducing our emissions? Yep! That's right. So, I thought about how we could reduce our emissions from our WASTECON Travel. One idea that I came up with is to start a Ride-Sharing thread on our new WASTECON Group site. Here you can offer a ride or get a ride to the event. You might also find other attendees who you could share a taxi to or from the airport.
That's one idea. What are some of your ideas??
Tuesday, July 29, 2008
An Interview with Dr. Jean Bogner, this Year's Lawrence Lecturer
I recently had an opportunity to chat with this year’s Lawrence Lecturer, Dr. Jean Bogner, about waste, energy and climate. Dr. Bogner served as the coordinating lead author of the Waste Management Chapter of the Intergovernmental Panel on Climate Change (IPCC) 4th Assessment Report “Mitigation of Climate Change”. The IPCC was awarded the 2007 Nobel Peace Prize with former Vice President Al Gore. Jean Bogner is the President of Landfills +, Inc., and a Research Professor at the University of Illinois Chicago.
SWANA - Dr. Bogner, thru your own studies and your work on the IPCC report, how have you seen waste impact energy and climate?
Dr. Bogner - There are two things to emphasize with respect to climate and energy. First is that waste is actually a small contributor to global greenhouse gas emissions. Less than three percent of global anthropogenic emissions are caused by the waste sector. On the other hand, there are also significant opportunities for greenhouse gas mitigation from the waste sector with respect to landfill gas recovery and to activities which either reduce greenhouse gas generation or reduce waste generation such as recycling and waste minimization. Secondly, energy from waste (via landfill gas utilization, waste-to-energy, or use of anaerobic digester biogas) is an important renewable energy resource.
SWANA - How would you recommend a solid waste facility to mitigate their emissions?
Dr. Bogner - Well of course for landfills, landfill gas recovery and utilization, which has been a fully commercial technology now for over thirty years, is a good strategy. Incineration reduces greenhouse gas generation. Also, waste minimization and recycling activities reduce waste generation in the first place. So, I think the “take home” message is that we must preserve all our waste management options and sensibly apply greenhouse gas mitigation strategies that best fit local situations and regulatory guidelines.
SWANA - Do you foresee any new mitigation techniques which are starting to evolve in the industry?
Dr. Bogner - One technique is landfill biocovers, which is a strategy to design and construct landfill covers so that methane is oxidized at high rates before it can be emitted to the atmosphere. The oxidation is accomplished by methanotrophic bacteria which are aerobic microorganisms that naturally live in the soil.
SWANA - How would you encourage those who are collecting the waste to mitigate their emissions?
Dr. Bogner - On the waste collection side there could be opportunities to reduce transport distances, reduce redundant routes, and improve fuel efficiencies.
SWANA - How would you recommend that a facility that is working with either landfill gas or incineration portray the benefits of these technologies to the general public?
Dr. Bogner - I think the tremendous benefits are on the energy side. Landfill gas is roughly fifty percent methane. So there are significant energy benefits to recovering and using the landfill methane for direct use in gas-fired broilers or onsite electrical generation, or for upgrading to a substitute natural gas. Incineration is the pathway where you get the most energy benefit from solid waste through direct combustion.
SWANA - As this years Lawrence lecturer for WASTECON in Tampa, what is one thing that you hope that attendees will really take away from your presentation?
Dr. Bogner - Well as I mentioned at the beginning of this interview, I think the fact that the waste factor is a small contributor to global anthropogenic greenhouse gas emissions but there are significant opportunities within the sector for cost-effective mitigation of greenhouse gas emissions. Thus, the sector is a small part of the problem but can be a larger part of the solution.
End
Don’t miss Dr. Bogner’s presentation at this year’s WASTECON Lawrence Lecturer Session, Wednesday October 22 at 9:30am as we continue to explore the connection between energy, climate and solid waste.
Member thoughts:
How is your facility mitigating its emissions?
What other mitigating techniques do you see coming down the pike?
Post your comments here.
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