3 SWANA (LMOP), encourages landfill owners to reduce greenhouse gas emissions by collecting and utilizing the LFG as a substitute for fossil fuels. (As previously discussed, the utilization of LFG as a fuel provides additional greenhouse gas reductions not achieved by simply collecting and flaring the LFG, the baseline requirement for EPA's NSPS.) Under DOE's Climate Challenge Program, several electric utilities have voluntarily committed to reduce, avoid or offset greenhouse gas emissions by working with SWANA members to control methane emissions at MSW landfills. SWANA members with LFG collection projects are also voluntarily reporting methane reductions to DOE pursuant to Section 1605(b) of the Energy Policy Act of 1992. LFG Control and Utilization Projects Are A Cost-Effective Option Utilization of LFG is one of the most cost-effective methods to reduce greenhouse Principles for the Role of LFG Utilization Projects In Policies The various proposals to reduce greenhouse gas emissions, including those offered as part of the international treaty negotiations now being negotiated under the auspices of the United Nations, have typically set a goal of limiting those emissions in the next decade to a percentage of 1990 levels. In achieving such a goal, policy makers must recognize the significant and cost-effective greenhouse gas reductions that can be realized by collecting and using LFG. The following principles, several of which are proposed by the U.S. in the international treaty negotiations, must be incorporated in any policy intended to effectively reduce greenhouse gas emissions. These principles will ensure a workable and cost-effective reduction program, in addition to encouraging the use of LFG collection and utilization projects. These principles are: 1) Domestic policies to reduce greenhouse gas emissions must be harmonized with policies for air quality improvement, other relevant environmental management programs, deregulation of the electric utility industry, and energy utilization and production to achieve optimal environmental and economic benefits. 2) All measurable and verifiable post-1990 greenhouse gas emission reductions must be recognized and counted, including: reductions incidental to compliance with mandatory reductions for other pollutants (e.g., application of NSPS to reduce non-methane organic compound (NMOC) emissions); • reductions achieved as part of DOE's Climate Challenge Program and reported pursuant to Section 1605(b) of EPAct of 1992; • reductions directly produced in one country by capital investments originating in another country; and other voluntary reductions that are measurable and verifiable. 3) Maximum flexibility in reducing greenhouse gas emissions should be allowed through adoption of various direct and indirect means, including support of new or developing technologies that will lead to greenhouse gas reductions. 4) Reduction of greenhouse gas emissions should be achieved at minimum cost primarily through market mechanisms which provide monetary value to greenhouse gas emissions reductions and through priority implementation of proven reduction projects and measures. 5) If binding greenhouse gas emissions limits are adopted pursuant to an international treaty, an allowance trading system for greenhouse gas reductions should be implemented that is modeled after the U.S. acid-rain allowance, free market trading system. The allowance trading system should have the following elements: · all greenhouse gases, sources and sinks should be included; SWANA 5 • tradeable units should be based on tons of CO2 or carbon equivalent; accurate allocation of allowable tons per country should be based on standardized measurement and accounting methods; international and domestic trading should be allowed; allocation of a country's allowable tons to all domestic greenhouse gas emission sources should be based on potential to emit; and ownership of allowances should be tradeable to third parties. 6) An allowance trading system for greenhouse gas reductions should also: allow economic cross-trading of greenhouse gas reductions, SOX allowances or other tradeable air pollutant allowances; and provide weighted greenhouse gas reductions credits based on the level of negative environmental externalities that are avoided or offset (e.g., reduction by LFG energy production should have higher value than by LFG flaring). In summary, federal policy makers should encourage and support installation of LFG utilization projects, impose economic value on the consequent greenhouse gas reductions, and establish a market trading system for such reductions in any policy and programs that may be adopted to reduce greenhouse gas emissions. Because developing and developed countries will always generate solid waste and are expected to always landfill a portion of such waste, LFG will remain a major greenhouse gas of concern. LFG control and utilization projects are a proven and cost-effective technology that have been recognized as providing a multitude of environmental and energy benefits including reducing methane emissions, which are 21 times more potent as a greenhouse gas than CO2. John H. Skinner Work Experience The Solid Waste Association of North America (SWANA), Executive Director/Chief United Nations Environment Programme, Senior Advisor, Industry and Environment U.S. Environmental Protection Agency, Washington, DC Deputy Assistant Administrator, Office of Research and Development 1988-1992. Director, Office of Solid Waste, 1982-1985. Director, Land Disposal Division, Office of Solid Waste, 1978-1982. Deputy Director and Branch Chief Resource Recovery Division, Office of Solid General Electric Corporate Research and Development Center, Manager of Energy and Awards and Honors Presidential Distinguished Executive Award, 1992. A.J. Barnes Human Resources Leadership Award, EPA 1992. Gold Medal for Exceptional Service, US EPA. Silver Medal for Superior Service, US EPA. Honorary Fellow, UK Institute of Wastes Management, 1994. Distinguished Teaching Award, Hofstra University. Honorary Member, Institute of Solid Wastes. NASA Fellowship, Rensselaer Polytechnic Institute. Academic Scholarship, Hofstra University. Graduated cum laude and with honors, Hofstra University. Doctoral Thesis presented at international symposium on combustion in Professional Activities Education Past President, International Solid Waste Association (ISWA) 1996-1998. Chairman U.SJJapan Solid Waste Management Bilateral Agreement. President, Institute of Solid Wastes 1990-1991. Member, Pacific Basin Consortium for Hazardous Waste Research. Co-editor of International Perspectives on Hazardous Waste Management, Co-editor of Waste Minimization and Clean Technology: Waste Management Ph.D. Aeronautical Engineering, Rensselaer Polytechnic Institute, 1968. B.S. Engineering Science, Hofstra University, 1964. I am writing regarding John Skinner's testimony of October 1997 concerning the Kyoto Protocol and global |