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**June 22, 2005**

U.S. Department of Energy - Submitted via Internet

***RIN Number 1901--AB11***

**RE:** **Interim Final General Guidelines for the Reporting of
Greenhouse Gas Emissions and Emission Reductions Under Section 1605(b)
of the National Energy Policy Act**

> *(Note: This is second of [two]{.underline} SWANA comment letters
> submitted)*

Dear Sir or Madam:

The Solid Waste Association of North America (SWANA) is pleased to offer
the following *supplementary* comments in response to the
above-referenced U.S. Department of Energy (DOE) General Guidelines for
Reporting of Greenhouse Gas (GHG) Emissions under Section 1605(b) of the
National Energy Policy Act, RIN Number 1901--AB11. These comments are
intended to support the position of the Integrated Waste Services
Association (IWSA) with respect to the Interim Final General Guidelines.

SWANA is a not-for-profit association comprised of over 7,000 solid
waste professionals representative of local governments and companies
across the U.S. and Canada involved in all aspects of responsible
municipal solid waste management practices. SWANA supports a
comprehensive integrated solid waste management approach that
incorporates a broad range of source reduction, materials recycling and
energy recovery activities to reduce and recover value from municipal
solid wastes. SWANA has an interest in this matter as the Association
represents a broad cross-section of public and private waste-to-energy
plant owner/operators that provide waste disposal services and renewable
energy generation to numerous cities and communities across the country.
More than 39 million people rely upon the 89 waste-to-energy facilities
operating nationwide to cleanly and safely dispose of nearly 93,000 tons
of trash each day.

Together with our partnering organization IWSA, SWANA supports the
position that the Interim Final Guidelines issued by the U.S. Department
of Energy fail to acknowledge the complete universe of real and
quantifiable benefits attributable to waste-to-energy facilities in
lowering the amount of greenhouse gases into our atmosphere on a
constant basis. Waste-to-energy reduces greenhouse gas emissions in
several important ways. First, combustion diverts municipal solid waste
from landfills where the trash would otherwise produce methane as it
decomposes. Second, electric energy resulting from waste combustion
displaces electricity generated by fossil fuel-fired power generators
(and associated greenhouse gas emissions). Third, waste-to-energy
facilities recover ferrous and non-ferrous materials in the waste stream
that would have been lost if placed into a landfill, but when recovered
increase recycling rates and reduce greenhouse gas emissions.

As DOE has allowed waste-to-energy and others to calculate the avoided
emissions associated with utilities, we urge you to similarly allow
waste-to-energy to calculate and register avoided methane emissions that
would have otherwise occurred at landfills if waste had not been
combusted. EPA has provided the DOE with a method of accounting for
greenhouse gas benefits of waste-to-energy, *i.e.,* the Decision Support
Tool model. This accounting tool should be allowed as part of the DOE
rule, and the credits generated therein should be reported and
registered by the generator of the avoidance credits, the
waste-to-energy facility.

Again, thank you in advance for consideration of our views. We look
forward to working with DOE on this very important issue.

Respectfully submitted,

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John H. Skinner, Ph.D.

SWANA Executive Director and CEO