Cause for Concern

The Solid Waste Association of North America (SWANA) has submitted its concerns about a proposed federal greenhouse gas regulation to the U.S. Environmental Protection Agency (EPA). Specifically, the comments concern the agency's proposed Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule.

The proposal “is targeted at facilities with emissions over 25,000 tons of [carbon dioxide] annually and would require them to obtain permits that would demonstrate they are using Best Available Control Technologies (BACT) to minimize their [greenhouse gas] emissions,” according to a SWANA press release. “SWANA's comments expressed many concerns with the rule, but mainly focused on the lack of industry involvement with BACT development and the fact that the proposed threshold is too low … ”

“If EPA were to finalize this rulemaking as proposed, they would subject a large number of very small solid waste disposal facilities to regulation under the Clean Air Act, ” said John Skinner, executive director and CEO of SWANA, in a press release. “This would represent a very expensive undertaking for the regulated facilities for a very small reduction in emissions.”

Among the specific concerns that SWANA includes in its letter to EPA are the effects on waste-to-energy facilities. “The direct emissions from waste-to-energy facilities are more than offset by the overall [greenhouse gas] reductions that waste-to-energy provides,” the letter says.

View SWANA's letter.

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