On behalf of the Solid Waste Association of North America (SWANA), I appreciate the opportunity to submit this statement for the record on the Subcommittee's hearing regarding the proposed global warming treaty being negotiated under the auspices of the United Nations. SWANA urges the Subcommittee to recognize that collection and utilization of methane emitted from municipal solid waste landfills is an economically feasible method by which significant greenhouse gas emission reductions can be achieved, and considerable amounts of renewable energy can be produced, within the U.S., as well as within developing countries. SWANA, an association of over 6400 solid waste management professionals in the United States and Canada, has as its mission the advancement of environmentally and economically sound solid waste management practices. Consistent with that mission, SWANA urges the Committee to ensure that any federal policy intended to control the emissions of greenhouse gases recognize the important contribution landfill gas utilization projects can make in the economic implementation of such a policy. I have enclosed a copy of SWANA's Policy Statement on the role of landfill gas in efforts to control GHG emissions. The Policy cites the following reasons for supporting landfill gas utilization projects: - methane is 21 times more potent than carbon dioxide (CO2) in trapping heat in the "Advancing the practice of environmentally and economically sound municipal solid waste management in North America" SWANA - methane from domestic landfills represents an equivalent amount of CO2 equal to almost 5% of net CO2 emissions in the U.S, - the economic feasibility of technology to collect and utilize landfill gas is demonstrated by the solid waste industry's acceptance of this technology to comply with EPA's current New Source Performance Standards (NSPS) to control air emissions from landfills, - landfill gas control projects have been recognized as a key component of DOE's Global Climate Challenge program under which several electric utilities are voluntarily committing to offset their GHG emissions by working with SWANA members to reduce methane emissions through installation of such projects, - by utilizing the collected methane as a heating fuel or to generate electricity, GHG emissions are reduced not only from the landfills but by avoiding such emissions that would have occurred by combustion of fossil fuels, and - the potential of landfill gas utilization projects to generate a significant portion of the nation's electricity has been recognized (as far back as President Bush's National Energy Strategy), and these projects can provide developing countries with a cost-effective and local energy resource while also reducing their GHG emissions. SWANA's Policy Statement also sets forth principles, several of which have been proposed by the U.S. in the international treaty negotiations, that it believes should be incorporated in any policy intended to reduce greenhouse gas emissions. These principles can be summarized as follows: - all greenhouse gases, sources and sinks should be included, - maximum flexibility in implementation should be provided to ensure the greatest - a trading system for GHG emission reduction credits, on a carbon equivalent basis, should be established, and - trading of credits, for all post-1990 emission reductions, on both domestic and In conclusion, SWANA believes that landfill gas utilization projects are a cost-effective method by which GHG emissions can be significantly reduced and that the economics of any federal policy to reduce GHG emissions can be enhanced by instituting an emission reduction credit system and marketplace in which those credits can be bought, sold and traded. We encourage you and the Subcommittee to ensure that federal GHG reduction policies are harmonized with policies for energy utilization and production, electric utility restructuring, air quality improvement and other relevant environmental management programs so that benefits to SWANA our nation are optimized and economic costs are minimized. SWANA believes that landfill gas utilization projects should be supported as the paradigm example of how this harmony can be achieved. I appreciate very much this opportunity to present SWANA's views. Very Truly Yours, Joh H. Skinen John H. Skinner, Ph.D. & Chief Executive Officer of North America enclosure c: The Honorable Tim J. Roemer The Honorable F. James Sensenbrenner, Jr. THE ROLE OF LANDFILL GAS IN EFFORTS TO CONTROL Policy Statement The Solid Waste Association of North America The Solid Waste Association of North America (SWANA), a not-for-profit association of 6,400 public and private solid waste management professionals, urges the recognition of projects to control and utilize methane gas emitted from landfills in any federal policy whose goal is to control greenhouse gas emissions. Collection and utilization of landfill gas (LFG) is a low-cost method to limit the nation's greenhouse gas emissions and conserve fossil fuels. In addition to improving local air quality, this proven technology provides a two-fold reduction in greenhouse gas emissions: through the direct abatement of methane (CH4), a greenhouse gas 21 times more potent than carbon dioxide (CO2); and by providing a renewable energy source that can preclude the need for fossil fuel combustion, the largest source of greenhouse gas emissions in the U.S. Projects to collect and utilize LFG can play a significant role in U.S. compliance with the proposed international protocol for greenhouse gas emission reductions now being negotiated under the auspices of the United Nations Framework Convention for Climate Change. Landfill gas control projects offer a cost-effective option for meeting treaty objectives on an international and national basis. Specifically, SWANA strongly believes that any greenhouse gas emissions reduction policy supported by the United States must: provide comprehensive coverage of greenhouse gases (including methane); establish an allowance trading system for emissions reduction credits; and support trading of post-1990 emissions reduction credits on both domestic and international levels. Introduction to Landfill Gas The generation of landfill gas, or "LFG", occurs naturally in municipal solid waste (MSW) landfills as MSW decomposes. Landfill gas, primarily methane and CO2, constitutes the largest source of methane emissions in the U.S. Methane, as a greenhouse gas, is 21 times more potent than CO2. Human beings will always generate solid waste and, for the foreseeable future, dispose of such waste in landfills. Thus, LFG will continue to be a greenhouse gas of concern. This is true, Advancing the practice of environmentally and economically sound municipal solid waste management in North America" 2 SWANA notwithstanding, that today's integrated municipal solid waste management systems stress, as a priority, waste reduction, followed by composting, recycling and waste-toenergy projects. In 1995, according to the Environmental Protection Agency (EPA), nearly 11.1 million metric tons of methane gas was emitted from U.S. landfills. Based on methane's higher heat trapping potential, this release is equivalent to releasing over 233 million metric tons of CO2 into the atmosphere, almost 5% of net annual CO2 emissions in the U.S. (Solid waste in the landfill not yet decomposed into methane, on the other hand, is considered, under international protocol, as a store of sequestered carbon, thereby, reducing the overall "greenhouse effect".) Left uncontrolled, LFG, in addition to its greenhouse gas effects, can also impair air quality and create odor problems and potential fire hazards. The LFG impairs air quality by contributing to formation of ground-level ozone and it also contains hazardous air pollutants (HAPs). In view of these effects, EPA recently promulgated New Source Performance Standards (NSPS) under Section III of the Clean Air Act (CAA) to control LFG emissions from large landfills. The NSPS requires the gas to be collected and flared to destroy 98% of non-methane organic compounds (NMOCs). Control of LFG emissions is accomplished by installing wells and piping at the landfills to collect the gas. The fact that LFG control can reduce NMOCs, and thereby reduce ground-level ozone and HAPs, will make this technology more important as EPA implements its new, more stringent ozone standard and as it aggressively moves to eliminate hazardous pollutant emissions into the environment. EPA also has a program, the Landfill Methane Outreach Program (LMOP), which encourages collection of LFG on a voluntary basis at smaller landfills. Because LFG can be used as a fuel, it can replace the use of conventional fossil fuels for heating, industrial processes or to generate electricity. In 1995, 15% of the 11.1 million metric tons of methane gas emitted from landfills was recovered and used to produce energy. This utilization of LFG is recognized as an important energy resource in numerous national reports including President Bush's 1991 National Energy Strategy, the U.S. Department of Energy's 1997 Renewable Energy Annual Report and the 1993 EPA report to Congress on Opportunities to Reduce Anthropogenic Methane Emissions. It is also recognized that in the U.S., fossil fuel combustion is the single largest source of greenhouse gas emissions, primarily CO2 and nitrous oxide (N2O). Thus, with LFG utilization projects, greenhouse gas emissions are reduced not only from the landfills but by avoiding such emissions that would have occurred by combustion of fossil fuels. (Pursuant to international protocol, CO2 emissions from the combustion of LFG do not count as a greenhouse gas since the CO2 is biogenic in origin and its release merely closes the loop in the natural carbon cycle.) Existing Federal Greenhouse Gas Programs Which Recognize LFG Utilization LFG control projects are recognized as a key component of the President's Global Climate Change Action Plan and in the voluntary emission reduction programs of federal agencies. For example, EPA, under its Landfill Methane Outreach Program |