On September 27, 2010, SWANA submitted comments to the Environmental Protection Agency regarding proposed revisions to the mandatory greenhouse gas reporting rule. 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.
SWANA agreed with the following revisions proposed by EPA.
• Units processing 600 tons per day or less should be able to use the Tier 2 reporting method.
• 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.
Unfortunately 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 we support reporting them separately.
Click
here for a copy of SWANA's comments.