Municipal Solid Waste Landfills 

Economic Impact Analysis for the Proposed New 

Subpart to the New Source Performance Standards 

U.S. Environmental Protection Agency 

Office of Air and Radiation 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

June 2014
ii 

CONTACT INFORMATION 

This document has been prepared by staff from the Office of Air and Radiation, U.S. 

Environmental Protection Agency. Questions related to this document should be addressed to 

Alexander Macpherson, U.S. Environmental Protection Agency, Office of Air and Radiation, 

Office of Air Quality Planning and Standards, C439-02, Research Triangle Park, North Carolina 

27711 (email: macpherson.alex@epa.gov). 

ACKNOWLEDGEMENTS

In addition to EPA staff from the Office of Air Quality Planning and Standards and the 

Office of Atmospheric Programs with the U.S. EPA Office of Air and Radiation, Eastern 

Research Group, Inc. (ERG) contributed data and analysis to this document. 

 
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TABLE OF CONTENTS 

TABLE OF CONTENTS .................................................................................................................... III

LIST OF TABLES .............................................................................................................................. V

LIST OF FIGURES ........................................................................................................................... VI

1 EXECUTIVE SUMMARY ........................................................................................................ 1-1

1.1 BACKGROUND .............................................................................................................................................. 1-1

1.2 RESULTS FOR PROPOSED NSPS .................................................................................................................... 1-1

1.3 ORGANIZATION OF THIS REPORT .................................................................................................................. 1-2

2 INDUSTRY PROFILE ............................................................................................................. 2-1

2.1 INTRODUCTION ............................................................................................................................................ 2-1

2.2 WASTE STREAM BACKGROUND ................................................................................................................... 2-3

2.2.1 Municipal Waste ................................................................................................................................ 2-3

2.2.1.1 Generation of Municipal Solid Waste ...................................................................................... 2-3

2.2.1.2 Landfills Covered Under the NSPS/EG ................................................................................... 2-4

2.2.1.3 Trends in Per Capita Waste Sent to Landfills........................................................................... 2-4

2.2.1.4 Composition of MSW Sent to Landfills ................................................................................... 2-5

2.2.2 Consolidation of Waste Streams ........................................................................................................ 2-7

2.3 DISPOSAL FACILITY BACKGROUND ............................................................................................................. 2-8

2.3.1 Technical Background on Landfills as a Source Category ................................................................ 2-8

2.3.1.1 Landfill Siting and Permitting .................................................................................................. 2-8

2.3.1.2 Landfill Operations .................................................................................................................. 2-9

2.3.1.3 Landfill Closure ..................................................................................................................... 2-10

2.3.1.4 Management of Liquids ......................................................................................................... 2-10

2.3.2 Ownership and Characteristics of Landfills ..................................................................................... 2-11

2.4 COSTS AND REVENUE STREAMS FOR LANDFILLS ....................................................................................... 2-15

2.4.1 Major Cost Components for Landfills ............................................................................................. 2-15

2.4.2 Landfill Revenue Sources ................................................................................................................ 2-18

2.5 AIR POLLUTANT EMISSIONS FROM LANDFILLS .......................................................................................... 2-21

2.5.1 NMOC in LFG ................................................................................................................................. 2-21

2.5.2 Methane in LFG ............................................................................................................................... 2-22

2.5.3 Criteria Pollutants from Combustion of LFG .................................................................................. 2-23

2.6 TECHNIQUES FOR CONTROLLING EMISSIONS FROM LANDFILLS ................................................................. 2-24

2.6.1 Introduction...................................................................................................................................... 2-24

2.6.2 Gas Collection Systems ................................................................................................................... 2-24

2.6.3 Destruction ....................................................................................................................................... 2-26

2.6.4 Utilization ........................................................................................................................................ 2-27

2.6.4.1 Technologies .......................................................................................................................... 2-27

2.6.4.2 Revenues and Incentives ........................................................................................................ 2-32

2.7 REFERENCES .............................................................................................................................................. 2-35

3 REGULATORY PROGRAM COSTS AND EMISSIONS REDUCTIONS ............................................. 1

3.1 INTRODUCTION ................................................................................................................................................ 1

3.2 GENERAL ASSUMPTIONS AND PROCEDURES .................................................................................................... 1

3.3 EMISSIONS ANALYSIS ...................................................................................................................................... 3

3.4 ENGINEERING AND ADMINISTRATIVE COST ANALYSIS .................................................................................... 3

3.5 REGULATORY BASELINE AND OPTIONS............................................................................................................ 5

4 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS ............................... 4-1

4.1 ECONOMIC IMPACT ANALYSIS ..................................................................................................................... 4-1
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4.2 SMALL BUSINESS IMPACTS ANALYSIS ......................................................................................................... 4-1

 
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LIST OF TABLES 

Table 2-1 Generation and Discards of MSW, 1960 to 2010 (in pounds per person per day) ................................. 2-5

Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2010 (in thousands of tons) .................................... 2-7

Table 2-3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 2011 ........................ 2-13

Table 2-4 Typical Costs Per Acre for Components of Landfill Construction (Duffy, 2005a) ............................... 2-16

Table 2-5 Average Regional and National Per-Ton Tip Fees (Rounded): 1995-2012 .......................................... 2-19

Table 2-6 Average LFG Power Production Technology Costs ............................................................................. 2-29

Table 2-7 Average LFG Direct-use Project Components Costs ............................................................................ 2-31

Table 3-1 Number of Affected New Landfills under the Baseline and Alternative Options ....................................... 6

Table 3-2 Estimated Annual Average Emissions Reductions for the Baseline and Alternative Options .................... 7

Table 3-3 Estimated Engineering Compliance Costs for the Baseline and Alternative Options ................................. 8

Table 3-4 Estimated Cost-effectiveness for the Baseline and Alternative Options ..................................................... 9

 
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LIST OF FIGURES 

Figure 2-1 Material Composition of the MSW Stream, 2010 .................................................................................. 2-6

Figure 2-2 Landfill Cost Life Cycle ...................................................................................................................... 2-18

Figure 2-3 Typical LFG Generation Curve ........................................................................................................... 2-23

Figure 2-4 Vertical Well LFG Collection .............................................................................................................. 2-25

Figure 2-5 Horizontal Trench LFG Collection ...................................................................................................... 2-25
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1 EXECUTIVE SUMMARY 

1.1 Background 

The EPA is proposing amendments to the Standards of Performance for Municipal Solid 

Waste Landfills. Under the Clean Air Act, the EPA must periodically review and revise the 

standards of performance, as necessary, to reflect improvements in methods for reducing 

emissions. Based on our review of the standards, we are proposing to lower the annual NMOC 

emissions threshold from 50 Mg/year to 40 Mg/year. The EPA is also addressing other 

regulatory issues for sources that have arisen during implementation of Subpart WWW including 

the definition of landfill gas treatment systems, among other topics. This proposed new subpart, 

Subpart XXX, applies to new landfills. 

In this EIA, the EPA presents a profile of the municipal solid waste industry in the United 

States and an analysis of the costs and emissions reductions associated with a range of regulatory 

options, including the option chosen for proposal. The EPA drew upon a comprehensive 

database of existing landfills to develop model landfills to represent new landfills opening in the 

first five years after new subpart XXX is proposed (2014-2018). The model future landfills were 

developed by evaluating the most recently opened existing landfills and assuming that the sizes 

and locations of landfills opening in the future would be similar to the sizes and locations of 

landfills that opened in the last 10 years. The impacts shown in this section are expressed as the 

incremental difference between facilities complying with the current NSPS (40 CFR part 60, 

subpart WWW) and facilities that would be comply with proposed subpart XXX. All impacts 

are shown for the year 2023. The analysis also includes the small entity analysis supporting the 

EPA’s certification that there will not be a significant impact on a substantial number of small 

entities (SISNOSE) arising from this proposal. 

1.2 Results for Proposed NSPS 

For this executive summary, a summary of the findings of the EIA follows: 

Engineering Cost Analysis: To meet the proposed emission limits, a MSW landfill is expected 

to install the least cost control for combusting the landfill gas. The control costs include the costs 

to install and operate gas collection. For landfills where the least cost control option was an 

engine, the costs also include installing and operate one or more reciprocating internal 

combustion engines to convert the landfill gas into electricity. Revenue from electricity sales was 
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incorporated into the net control costs using state-specific data on wholesale purchase prices. The 

annualized costs also include testing and monitoring costs. For this proposal, which tightens the 

emissions threshold, the EPA estimated the nationwide incremental annualized cost in 2023 to be 

$471,000 (2012$). While not quantified, the costs associated with the additionally proposed 

changes to address other regulatory issues and clarifications are expected to be minimal. 

Emissions Analysis: In 2023, this proposal would achieve reductions of 79 Mg NMOC, 12,000 

Mg methane, and 308,000 Mg CO2-equivalents1

 compared to the baseline. These pollutants are 

associated with substantial health, welfare and climate effects. 

Small Entity Analysis: Because the ownership of new landfills in the future is unknown, the 

EPA performed a screening analysis that assumed new landfills would be physically and 

financially similar to and have the same type of ownership as recently established landfills. 

Based upon historical data, the screening analysis predicted that four new landfills would be 

owned by small entities, but that none would be owned by small governments. Only one of the 

four small landfills were predicted to be incrementally affected by this proposal. Based upon this 

analysis, we conclude there will not be a significant economic impact on a substantial number of 

small entities (SISNOSE) arising from this proposal. 

Economic Impacts: Because of the relatively low cost of this proposal and the lack of 

appropriate economic parameters or models, the EPA is unable to estimate the impacts of the 

proposal on the supply and demand for MSW landfill services. However, the EPA does not 

believe the proposal will lead to changes in supply and demand for landfill services or waste 

disposal costs, tipping fees, or the amount of waste disposed in landfills. Hence, the overall 

economic impact of the proposal should be minimal on the affected industries and their 

consumers.

1.3 Organization of this Report 

The remainder of this report details the methodology and the results of the EIA. Section 

2 presents the industry profile of municipal solid waste landfill industry. Section 3 describes 

emissions, emissions control options, and engineering costs. Section 4 presents the small entity 

screening analysis. 

 

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 A global warming potential of 25 is used to convert methane to CO2-equivalents. 
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2 INDUSTRY PROFILE 

2.1 Introduction 

Municipal solid waste (MSW) is the stream of garbage collected by sanitation services 

from homes, businesses, and institutions. MSW typically consists of metals, glass, plastics, 

paper, wood, organics, mixed categories, and composite products. The majority of collected 

MSW that is not recycled is typically sent to landfills—engineered areas of land where waste is 

deposited, compacted, and covered. The New Source Performance Standards (NSPS) and the 

state and federal plans implementing the emission guidelines for MSW landfills regulate air 

emissions from landfills that receive household waste as defined in 40 CFR 60.751. Hereinafter 

these regulations are collectively referred to as the NSPS/EG. These MSW landfills can also 

receive other types of waste, such as construction and demolition debris, industrial wastes, or 

nonhazardous sludge. MSW landfills are designed to protect the environment from contaminants 

which may be present in the solid waste stream and as such are required to comply with federal 

Resource Conservation and Recovery Act (RCRA) regulations or equivalent state regulations, 

which include standards related to location restrictions, composite liners requirements, leachate 

collection and removal systems, operating practices, groundwater monitoring requirements, 

closure and post-closure care requirements, corrective action provisions, and financial assurance 

(EPA, 2012a). 

EPA estimates the total amount of MSW generated in the United States in 2010 was 

approximately 250 million tons, a 20 percent increase from 1990. Despite increased waste 

generation, the amount of MSW deposited in landfills decreased from about 145.3 million tons in 

1990 to 135.5 million tons in 2010. This decline is due to a significant increase in the amount of 

waste recovered for recycling and composting as well as that combusted for energy recovery 

(EPA, 2011). The number of active MSW landfills in the United States has decreased from 

approximately 7,900 in 1988 to 1,900 in 2009 (EPA, 2010a). 

Landfills are different than many other traditionally regulated emissions source 

categories. Typically, entities regulated for air emissions are involved in manufacturing or 

production and their emissions are directly related to processes involved in creating products 

(e.g., vehicles, bricks) or commodities (e.g., natural gas, oil). When manufacturing or production 

facilities cease to operate, their emissions typically cease. Landfills are a service industry—a 

repository for waste that needs to be properly disposed—and their emissions are a by-product of 
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the deposition of that waste. Landfills continue to emit air pollution for many years after the last 

waste is deposited. 

Landfill gas (LFG) is a by-product of the decomposition of organic material in MSW in 

anaerobic conditions in landfills. LFG contains roughly 50 percent methane and 50 percent 

carbon dioxide, with less than 1 percent non-methane organic compounds and trace amounts of 

inorganic compounds. The amount of LFG created primarily depends on the quantity of waste 

and its composition and moisture content as well as the design and management practices at the 

site. LFG can be collected and combusted in flares or energy recovery devices to reduce 

emissions. MSW landfills receive approximately 69 percent of the total waste generated in the 

United States and produce 94 percent of landfill emissions. The remainder of the emissions is 

generated by industrial waste landfills (EPA, 2012b).

Entities potentially regulated under Standards of Performance for Municipal Solid Waste 

Landfills include owners of MSW landfills and owners of combustion devices that burn 

untreated LFG. At its core, firms engaged in the collection and disposal of refuse in a landfill 

operation are classified under the North American Industry Classification System (NAICS) 

codes Solid Waste Landfill (562212) and Administration of Air and Water Resource and Solid 

Waste Management Programs (924110). 

Landfills are owned by private companies, government (local, state, or federal), or 

individuals. In 2004, 64 percent of MSW landfills were owned by public entities while 

36 percent were privately owned (O’Brien, 2006). Affected entities comprise establishments 

primarily engaged in operating landfills for the disposal of non-hazardous solid waste; or the 

combined activity of collecting and/or hauling non-hazardous waste materials within a local area 

and operating landfills for the disposal of non-hazardous solid waste. This industry also includes 

government establishments primarily engaged in the administration and regulation of solid waste 

management programs. 

Private companies that own landfills range in size from very small businesses to large 

businesses with billions in annual revenue. Public landfill owners include cities, 

counties/parishes, regional authorities, state governments, and the federal government (including 

military branches, Bureau of Land Management, Department of Agriculture, Forest Service, and 

Department of the Interior - National Park Service). 
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2.2 Waste Stream Background 

2.2.1 Municipal Waste 

2.2.1.1 Generation of Municipal Solid Waste 

Municipal solid waste (MSW) is generally defined as nonhazardous waste from 

household, commercial, and institutional sources. These three broad categories of primary MSW 

generators are described as: 

 Household – solid waste from single-and multiple-family homes, hotels and motels, 

bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and dayuse recreation areas. 

 Commercial – solid waste from stores, offices, restaurants, warehouses, and other 

nonmanufacturing activities. 

 Institutional – solid waste from public works (such as street sweepings and tree and 

brush trimmings), schools and colleges, hospitals, prisons, and similar public or 

quasi-public buildings. Infectious and hazardous waste from these generators are 

managed separately from MSW. 

Households are the primary source of MSW, accounting for 55 to 65 percent of total 

MSW generated, followed by the commercial sector (EPA, 2011). Waste from commercial and 

institutional locations amounts to 35 to 45 percent of total MSW (EPA, 2011). The industrial 

sector manages most of its own solid residuals by recycling, reuse, or self-disposal in industrial 

waste landfills. For this reason industry directly contributes a very small share of the MSW flow, 

although some industrial waste does end up in MSW landfills. 

Various underlying factors influence the trends in the quantity of MSW generated over 

time. These factors include changes in population, individual purchasing power and disposal 

patterns, trends in product packaging, and technological changes that affect disposal habits and 

the nature of materials disposed. Generators of MSW provide most of the demand for services 

that collect, treat, or dispose of MSW. Fluctuations in the quantity of MSW generated and 

changes in the cost and pricing structure of disposal services result in varying demand for landfill 

services. 

Most MSW generators are charged a flat fee for disposal services, which can be paid 

through taxes for household garbage collection. This structure may provide little economic 
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incentive to lower waste disposal or to divert waste through recycling because generators are 

charged the same price regardless of the quantity of waste disposed. Less common are unit price 

programs, such as “pay-as-you-throw” (PAYT). In PAYT programs, each unit of waste disposed 

has an explicit price, such that the total fee paid for MSW services increases with the quantity of 

waste discarded. Hence, the unit price can act as a disincentive to dispose of excess waste and 

also encourages recycling (Callan, 2006). 

2.2.1.2 Landfills Covered Under the NSPS/EG 

The Landfills NSPS/EG applies only to landfills that accept “household waste” as defined 

in 40 CFR 60.751, which states “household waste means any solid waste (including garbage, 

trash, and sanitary waste in septic tanks) derived from households (including, but not limited to, 

single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, 

campgrounds, picnic grounds, and day-use recreation areas).” Some of the MSW landfills 

subject to the Landfills NSPS/EG may also receive other types of wastes, such as commercial, 

industrial, and institutional solid waste, nonhazardous sludge, and construction and demolition 

debris. 

2.2.1.3 Trends in Per Capita Waste Sent to Landfills 

In 2010, Americans generated about 250 million tons of trash, and recycled nearly 

65 million tons of this material, equivalent to a 26 percent recycling rate (EPA 2011). 

Composting recovered more than 20 million tons of waste (~8 percent of total waste) and about 

29 million tons of waste were combusted for energy recovery (~12 percent) (EPA 2011). After 

recycling, composting, and combustion with energy recovery, the net per capita discard rate to 

landfills was 2.40 pounds per person per day in 2010 (EPA 2011). This is a 4 percent decrease 

from the 2.51 per capita discard rate in 1960, when minimal recycling occurred in the United 

States (see Table 2-1). 

Since 1990, the total amount of MSW going to landfills has dropped by almost 10 million 

tons, from 145.3 million to 135.5 million tons in 2010 (EPA 2011). While the number of U.S. 

landfills has steadily declined over the years, the average landfill size has increased. At the 

national level, landfill capacity appears to be sufficient, although it is limited in some areas (EPA 

2011). 
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Table 2-1 Generation and Discards of MSW, 1960 to 2010 (in pounds per person per day) 2

Activity 1960 1970 1980 1990 2000 2005 2007 2008 2009 2010 

Generation 

 2.68 3.25 3.66 4.57 4.72 4.67 4.64 4.53 4.35 4.43 

Discards to landfill a

2.51 3.02 3.24 3.19 2.71 2.61 2.52 2.45 2.36 2.40 

Discards to landfill 

(% of total generation) 94% 93% 89% 70% 57% 56% 54% 54% 54% 54% 

a Discards after recovery minus combustion with energy recovery. Discards include combustion without energy 

recovery. 

2.2.1.4 Composition of MSW Sent to Landfills 

Organic materials continued to be the largest component of MSW in 2010. Yard 

trimmings and food scraps account for 29.1 percent and paper and paperboard account for 

another 16.2 percent. Plastics comprise 17.3 percent while metals and wood make up 8.8 percent 

and 8.2 percent, respectively. Textiles account for 6.8 percent and glass accounts for 5.1 percent. 

Rubber and leather follow at 4.0 percent. Other miscellaneous wastes make up approximately 

4.4 percent of the MSW generated in 2010 (EPA 2011). Figure 2-1 displays material 

composition percentages of the MSW stream in 2010, and Table 2-2 shows the amounts of 

different materials discarded in the MSW stream from 1960 to 2010. 

 

 

2

 Table adapted from U.S. Environmental Protection Agency. 2011. “Municipal Solid Waste Generation, Recycling, 

and Disposal in the United States Tables and Figures for 2010.” Table 4. EPA-530-F-11-005. Washington, DC: 

U.S. EPA. Available at 

< http://www.epa.gov/osw/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf>. As obtained on 

October 30, 2011. 
2-6

Figure 2-1 Material Composition of the MSW Stream, 20103

 

 

3

 Figure adapted from U.S. Environmental Protection Agency. 2011. “Municipal Solid Waste Generation, 

Recycling, and Disposal in the United States Tables and Figures for 2010.” Table 3. EPA-530-F-11-005. 

Washington, DC: U.S. EPA. Available at 

< http://www.epa.gov/osw/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf>. As obtained on 

October 30, 2011.
2-7

Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2010 (in thousands of 

tons)4

Wastes 1960 1970 1980 1990 2000 2005 2010 

Paper and Paperboard 24,916 37,540 43,420 52,500 50,180 42,880 26,740

Glass 6,620 12,580 14,380 10,470 9,890 9,950 8,400

Metals 10,770 13,350 14,290 12,580 12,340 13,400 14,540

Plastics 390 2,900 6,810 16,760 24,050 27,470 28,490

Rubber and Leather 1,510 2,720 4,070 5,420 5,850 6,200 6,610

Textiles 1,710 1,980 2,370 5,150 8,160 9,670 11,150

Wood 3,030 3,720 7,010 12,080 12,200 12,960 13,580

Other Materialsb 70 470 2,020 2,510 3,020 3,080 3,380

Food Scraps 12,200 12,800 13,000 23,860 29,130 31,300 33,790

Yard Trimmings 20,000 23,200 27,500 30,800 14,760 12,210 14,200

Miscellaneous Inorganic 

Wastes 1,300 1,780 2,250 2,900 3,500 3,690 3,840

Total MSW Discarded 82,516 113,040 137,120 175,030 173,080 172,810 164,720

a Discards after materials and compost recovery. In this table, discards include combustion with energy recovery. 

Does not include construction and demolition debris, industrial process wastes, or certain other wastes. b Includes electrolytes in batteries and fluff pulp, feces, and urine in disposable diapers. 

Details may not add to totals due to rounding. 

2.2.2 Consolidation of Waste Streams 

Collection and transportation are necessary components of all MSW management 

systems regardless of the specific disposal options. Collections of MSW vary by service 

arrangements between local governments and collectors and by level of service provided to 

households. Depending on the arrangement type and other considerations for particular 

jurisdictions, MSW being sent to landfills may be deposited in a local landfill or routed to a 

regional landfill through a transfer process. Local landfills are generally located in the 

 

4

 Table adapted from U.S. Environmental Protection Agency. 2011. “Municipal Solid Waste Generation, Recycling, 

and Disposal in the United States Tables and Figures for 2010.” Table 3. EPA-530-F-11-005. Washington, DC: 

U.S. EPA. Available at 

< http://www.epa.gov/osw/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf>. As obtained on 

October 30, 2011. 
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communities in which they serve whereas regional landfills are often located outside of the 

communities they serve and receive waste from several cities and towns. 

Solid waste transfer is the process in which collection vehicles unload their waste at 

centrally located transfer stations. Transfer stations can minimize hauling costs by decreasing the 

number of drivers and vehicles hauling waste to disposal sites and reducing the turn-around time 

of vehicles because they do not have to haul waste to distant regional landfills. Smaller loads are 

consolidated into larger vehicles, usually tractor-trailer trucks, trains, or barges, which are better 

suited for the long-distance hauls often required to reach the final disposal site, often a regional 

landfill. As public opposition to local MSW disposal facilities increases and the cost of disposal 

at locations near generators rise, long-distance hauls to regional landfills are becoming more 

common. 

2.3 Disposal Facility Background 

2.3.1 Technical Background on Landfills as a Source Category 

An MSW landfill refers to an area of land or an excavation where MSW is placed for 

permanent disposal. MSW landfills do not include land application units, surface impoundments, 

injection wells, or waste piles. Modern MSW landfills are well-engineered disposal facilities that 

are sited, designed, operated, and monitored to protect human health and the environment from 

pollutants that may be present in the solid waste stream (EPA, 2012c). 

2.3.1.1 Landfill Siting and Permitting 

MSW landfills are required to comply with federal regulations contained in Subtitle D of 

the Resource Conservation and Recovery Act (RCRA) [40 CFR Part 258], or equivalent state 

regulations. RCRA requirements include location restrictions that ensure landfills are constructed 

away from environmentally-sensitive areas, including fault zones, wetlands, flood plains, or 

other restricted areas (EPA, 2012c). Site selection for landfills is an integral part of the design 

process. 

Construction and operating permit applications for new landfills must be submitted to and 

approved by state and local regulatory agencies as part of the siting and design process. Often, 

states require a registered professional engineer to design the landfill (Guyer, 2009). Additional 
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permits must be issued for each expansion of the landfill from its originally permitted waste 

design capacity and footprint area. New or modified landfills may also require air permits under 

the New Source Review (NSR) permitting program, which includes Prevention of Significant 

Deterioration (PSD) requirements for landfills sited in attainment areas, or areas where the air 

quality meets the National Ambient Air Quality Standards (NAAQS), and more stringent NSR 

requirements for landfills located in non-attainment areas. 

Developing a new landfill or expanding an existing landfill has become increasingly 

difficult, especially in metropolitan areas, due to the urbanization of suitable sites, permitting 

barriers, elevated land costs, and other factors. If a new landfill is proposed or when expansion 

plans for existing landfills are announced, adjacent communities may mount opposition that can 

hinder issuance of required permits and thus development of the landfill (Alva, 2010). 

2.3.1.2 Landfill Operations 

The two most common methods for active disposal of waste into landfills are the area fill 

method and the trench method. The area fill method involves waste placement in a large open 

section of a lined landfill and then spreading and compacting waste in uniform layers using 

heavy equipment. The trench method of filling waste in a modern landfill involves placing and 

compacting waste into a trench and then using material from the trench excavation as daily 

cover. Local conditions often determine the most appropriate method for a particular landfill, and 

a combination of the two methods can be utilized. The trench method is less commonly used 

than the area fill method, mostly due to the expense of lining side slopes of the landfill (Guyer, 

2009). 

As required by Subtitle D of RCRA, cover material is applied on top of the waste mass at 

the end of each day to prevent odors and fires and reduce litter, insects, and rodents. Materials 

used as daily cover include soil, compost, incinerator ash, foam, and tarps (NSWMA, 2008). 

Similarly, intermediate cover is used when an area of the landfill is not expected to receive waste 

or a cap for an extended period of time. Intermediate covers have traditionally consisted of layers 

of soil, geotextiles, or other materials. The reasons for using intermediate cover are similar to 

those for using daily cover and may also include erosion control. 

It is important to maintain anaerobic conditions within the landfill waste mass to avoid 

excess air infiltration that can cause fires. Landfill fires can be avoided by closely monitoring 
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landfill conditions and maintaining the landfill as a controlled facility. If active LFG collection 

systems are installed, then gas wells are monitored to ensure oxygen is not being pulled into the 

landfill due to excessive vacuum levels. 

2.3.1.3 Landfill Closure 

Once an area of the landfill, or cell, has reached its permitted height, that cell is closed 

and a low permeability cap made of compacted clay or synthetic material is installed to prevent 

infiltration of precipitation. To divert water off of the top of the landfill, a granular drainage layer 

is placed on top of the low-permeability barrier layer. A protective cover is placed on top of the 

filter blanket and topsoil is placed as the final layer to support vegetation. The final cap and 

cover inhibit soil erosion and provide odor and LFG control (NSWMA, 2008). If an LFG 

collection and control system is in place, then expansion of the collection system into filled cells 

or areas of the landfill may require additional gas wells to be installed soon after these cells are 

closed and capped. Gas collection system design is discussed further in Section 6. 

RCRA Subtitle D regulations contain closure and post-closure care requirements, 

including written closure and post-closure care plans and maintaining the final cover, leachate 

collection system, and groundwater and LFG monitoring systems. The required post-closure care 

period is 30 years from site closure, but this can be shortened or extended if approved by state 

regulatory agencies (EPA, 2012d). 

2.3.1.4 Management of Liquids 

Leachate is the liquid that passes through the landfilled waste and strips contaminants 

from the waste as it percolates. Precipitation is the primary source of this liquid. To prevent 

water pollution and protect soil beneath, RCRA Subtitle D requires liners for landfills as well as 

leachate collection and removal and groundwater monitoring systems. Composite liner systems 

are used along the bottom and sides of landfills as impermeable barriers and are typically 

constructed with layers of natural materials with low permeability (e.g., compacted clay) and/or 

synthetic materials (e.g., high-density polyethylene) (NSWMA, 2008). Landfill liner systems 

also help prevent off-site migration of LFG. 

Leachate collection systems remove leachate from the landfill as it collects on the liner 

using a perforated collection pipe placed in a drainage layer (e.g., gravel). Waste is placed 
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directly above the leachate collection system in layers. Collected leachate can be treated on-site 

or transported off-site to treatment facilities. For landfills with LFG collection systems, LFG 

condensate can be combined with leachate prior to treatment. 

Although traditional landfills tend to minimize the infiltration of liquids into a landfill 

using liners, covers, and caps (sometimes referred to as “dry tombs”), some landfills recirculate 

all or a portion of leachate collected to increase the amount of moisture within the waste mass. 

This practice of leachate recirculation results in a faster anaerobic biodegradation process and 

increased rate of LFG generation. Similarly, landfills may introduce liquids other than leachate, 

such as sludge and industrial wastewater. Conventional landfills typically have in-situ moisture 

contents of approximately 20 percent, whereas landfills recirculating leachate or other liquids 

may maintain moisture contents ranging from 35 to 65 percent (EPA, 2012e). Often, landfills 

injecting or recirculating liquids are termed bioreactors, but bioreactor landfills are defined 

differently amongst industry and regulatory agencies. In addition, bioreactor landfills may have 

air injected in a controlled manner to further accelerate biodegradation of the waste, which 

occurs for aerobic and hybrid bioreactor configurations. 

2.3.2 Ownership and Characteristics of Landfills 

Since the 1980’s, the number of active MSW landfills in the United States has decreased 

by approximately 75 percent (from ~7,900 in 1988 to ~1,900 in 2009) and the share of sites that 

are publicly owned has also decreased—from 83 percent in 1984 to 64 percent in 2004 (EPA, 

2010b; O’Brien, 2006). However, the overall volume of disposal capacity has remained fairly 

constant, indicating a trend of growing individual landfill capacity (SWANA, 2007). In 2004, 

privately owned sites represented 83 percent of the permitted MSW landfill capacity and 

77 percent of the MSW landfilled in that year, an indication that private landfills are likely to be 

significantly larger than public ones (O’Brien, 2006). In 2004, the average daily amount of MSW 

disposed at public sites was just under 200 short tons, whereas the average private site landfilled 

nearly 1,200 short tons of MSW per day—further evidence that publicly owned landfills are 

generally much smaller than their private counterparts (O’Brien, 2006). 

EPA recognized as early as 2002 that a nationwide trend in solid waste disposal is toward 

the construction of larger, more remote, regional landfills. Economic considerations, influenced 

by regulatory and social forces, are compelling factors that likely led to the closure of many 
2-12

existing sites and to the idea of regional landfills (EPA, 2002b). The passage of federal 

environmental regulations that affected landfills (e.g., RCRA in 1976, Subtitle D of RCRA in 

1991), established requirements which made it more expensive to properly construct, operate, 

maintain, and close landfills (O’Brien, 2006; EPA 2012f; EPA, 2002b). Large, private 

companies are better able to accommodate the increased costs of owning a landfill, since owning 

multiple sites, many of which have large capacities, provides an economy of scale for cost 

expenditures (O’Brien, 2006). To offset the high cost of constructing and maintaining a modern 

landfill, facility owners construct large facilities that attract high volumes of waste from a large 

geographic area. By maintaining a high volume of incoming waste, landfill owners can keep 

tipping fees relatively low, which subsequently attracts more business (EPA, 2002b). 

As older, public landfills near their capacities, communities must decide whether to 

construct new landfills or seek other options. Many find the cost of upgrading existing facilities 

or constructing new landfills to be prohibitively high, and opt to close existing facilities. Also, 

public opposition often makes siting new landfills near population centers difficult and adequate 

land may not be available near densely populated or urban areas. Many communities are finding 

that the most economically viable solution to their waste disposal needs is shipping their waste to 

regional landfills. In these circumstances, a transfer station serves as the critical link in making 

the shipment of waste to distant facilities cost-effective (EPA, 2002b). 

Waste transfer stations are facilities where MSW is unloaded from collection vehicles 

and reloaded into long-distance transport vehicles for delivery to landfills or other 

treatment/disposal facilities. By combining the loads of several waste collection trucks into a 

single shipment, communities and waste management companies can save money on the labor 

and operating costs of transporting waste to a distant disposal site. They can also reduce the total 

number of vehicular miles traveled to and from the disposal site(s) (EPA, 2012g). Given the 

dramatic decrease in the number of active landfills in the past 20 years, transfer stations play an 

important part in facilitating the movement of solid waste from the areas in which it originates to 

its end location, often a large, centrally located landfill. The role of transfer stations in waste 

management has become even more prominent with the increase in the number of “regional” 

landfills—sites with very large capacities, often located in remote areas, and usually privately 

owned. As more and more publicly owned landfills reach capacity and close, the waste must go 

somewhere, and often that is to a regional landfill by way of a transfer station. 
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There are more than 200 private companies that own and/or operate landfills, ranging 

from large companies with numerous landfills throughout the country to local businesses that 

own a single landfill (EPA, 2012b). The handling of MSW in the United States generated $55 

billion of revenue in 2011 (EBI, 2012). In terms of 2011 revenue, the top two companies that 

own and/or operate MSW landfills in the United States were Waste Management ($13.38 billion) 

and Republic Services ($8.19 billion), which together accounted for 39 percent of the revenue 

share in 2011 (Bloomberg, 2012WM; Bloomberg, 2012RSG). The next tier of companies 

involved in landfill management includes Veolia Environmental Services North America Corp. 

($1.88 billion), Progressive Waste Solutions ($1.84 billion), and Waste Connections ($1.51 

billion) (Gerlat, 2012; Bloomberg, 2012BIN; Bloomberg, 2012WCN). Table 2-3 contains a 

summary of the 2011 revenue for the top five companies, as well as information about their 

MSW landfills and transfer stations. 

Table 2-3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 

2011 

Company 

2011 

Revenue 

(billion $) 

No. of MSW 

Landfills Owned 

and/or Operated 

MSW 

Received at 

Landfills 

(million tons) 

No. of Transfer 

Stations Owned 

and/or Operated 

Waste Management 

(Bloomberg, 

2012WM)

13.38 266 91.2 287 

Republic Services 

(Bloomberg, 

2012RSG)

8.19 

191 active/ 

130 closed 

NA 194 

Veolia 

Environmental 

Services North 

America Corp. 

(Gerlat, 2012)a

1.88 29 NA 43 
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Table 2-3 Top 5 Waste Management Companies That Own or Operate MSW Landfills in 

2011 

Company 

2011 

Revenue 

(billion $) 

No. of MSW 

Landfills Owned 

and/or Operated 

MSW 

Received at 

Landfills 

(million tons) 

No. of Transfer 

Stations Owned 

and/or Operated 

Progressive Waste 

Solutions 

(Bloomberg, 

2012BIN)

1.84 NA NA NA 

Waste Connections 

(Bloomberg, 

2012WCN)

1.51 46 14.9 58 

a In 2012, VESNA agreed to sell its U.S. solid waste operations, Veolia ES Solid Waste, Inc., to Star Atlantic Waste 

Holdings LP, a unit of Highstar Capital; the sale is to be completed by end of 2012. Highstar also owns Advanced 

Disposal Services Inc. and Interstate Waste Services Inc. 

NA = Not available. 

The industry that deposits MSW in landfills encompasses a wide range of job types, 

including garbage collectors, truck drivers, heavy equipment operators, engineers of various 

disciplines, specialized technicians, executives, MSW department directors, administrative staff, 

weigh scale operators, salespersons, and landfill operations managers. In 2007, 1,501 private 

establishments had 21,766 employees in the continental United States under NAICS 562212 

(Solid Waste Landfill) (Census, 2012). In 2011, solid waste management departments of local 

governments reported 98,957 full-time employees and 14,679 part-time employees (Census, 

2011); however, statistics are not readily available solely for landfill-related aspects of these 

departments. As the population continues to grow in the United States the amount of waste 

generated will continue to increase, but the amount of waste landfilled may remain the same or 

decrease (EPA, 2012h). Employment within the waste management industry overall will likely 

remain strong, perhaps with an increased shift of employees from the public sector to the private 

sector. 
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2.4 Costs and Revenue Streams for Landfills 

2.4.1 Major Cost Components for Landfills 

EPA promulgated Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) under 

the RCRA on October 9, 1991 (EPA, 2012i). The law requires that non-hazardous MSW be 

disposed of in specially designed sanitary landfills. The criteria include location restrictions, 

design and operating standards, groundwater monitoring requirements, corrective actions, 

financial assurance requirements, landfill gas (LFG) migration controls, closure requirements, 

and post-closure requirements (EPA, 2012j). It can cost more than $1 million per acre to 

construct, operate, and close a landfill in compliance with these regulations (Fitzwater, 2012). 

Landfill costs are site specific and vary based on factors such as terrain, soil type, 

climate, site restrictions, regulatory issues, type and amount of waste disposed, preprocessing, 

and potential for groundwater contamination. Landfill costs fall into the following categories: 

site development, construction, equipment purchases, operation, closure, and post-closure. 

Site development includes site surveys, engineering and design studies, and permit 

package fees. Surveys are necessary to determine if a potential site is feasible. Permits are 

required from local, state, and federal governments. As an example, engineering design and a 

permit application for an MSW landfill in Kentucky can cost approximately $750,000 to 

$1.2 million (KY SWB, 2012). 

Construction costs encompass building the landfill cells as well as development of 

permanent on-site structures needed to operate the landfill. Cortland County, New York 

estimated that the cost for site development and cell construction (not including on-site building 

construction) for a 224.5-acre site would be approximately $500,000 per acre (EnSol, 2010). In 

2005, a series of articles was written that estimated costs for a hypothetical landfill based on 

known market conditions and cost data. The theoretical landfill had a design capacity of 

4 million cubic yards and a footprint of 33 acres. The study determined that the cost of 

constructing a landfill of this size would be between $300,000 and $800,000 per acre. Table 2-4 

summarizes typical construction costs per acre by individual task for this example site (Duffy, 

2005a). 

 
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Table 2-4 Typical Costs Per Acre for Components 

of Landfill Construction (Duffy, 2005a) 

Task Low End High End 

Clear and Grub $1,000 $3,000

Site Survey $5,000 $8,000

Excavation $100,000 $330,000

Perimeter Berm $10,000 $16,000

Clay Liner $32,000 $162,000

Geomembrane $24,000 $35,000

Geocomposite $33,000 $44,000

Granular Soil $48,000 $64,000

Leachate System $8,000 $12,000

QA/QC $75,000 $100,000

TOTAL $336,000 $774,000

Excavation of the landfill site comprises a notable portion of the construction costs. 

Installation of a landfill liner can vary greatly in cost depending on the site’s geology. Most 

states require only a single liner and leachate collection system for MSW, but requirements vary 

for the minimum thickness of clay liners. Landfill sites may have good quality clay located onsite that would significantly lower the cost of a clay liner. The QA/QC task in Table 2-4 refers to 

management and quality oversight which is usually performed by independent third-party 

consultants. 

For the hypothetical landfill in the study, total building and additional structure costs 

could total between $1.165 million and $1.77 million. Operation of the landfill requires a truck 

scale, scale house, wheel wash facility, and buildings to accommodate an office and provide 

space for maintenance. The cost of each building structure varies depending on its functions and 

could range from $10 to $100 per square foot. Office buildings cost more while maintenance 

buildings and tool sheds cost less. In addition, fencing around the facility and roadways are 

required and add to the costs (Duffy, 2005a). 

Operating costs of the example landfill include staffing, equipment (payments and 

maintenance), leachate treatment, and facilities and general maintenance. Landfill operations and 

maintenance activities are performed using a variety of heavy construction equipment with 
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operating costs dependent on fuel, repairs, and maintenance. Operating costs are relatively small 

when compared to the capital costs; estimated annual operating costs from this study are (Duffy, 

2005a): 

 Operations (equipment, staff, facilities and general maintenance): $500,000. 

 Leachate collection and treatment (assumes sewer connection and discharge cost of 

$0.02/gallon): $10,000. 

 Environmental sampling and monitoring (groundwater, surface water, air gas, 

leachate): $30,000. 

 Engineering services (consulting firms and in-house staff): $60,000. 

Once a landfill no longer accepts waste, the closure process includes the installation of a 

final cover and cap. Capital costs for installation of a cap can run between $80,000 and $500,000 

per acre. For example, at a Maryland sanitary landfill costs were $150,000 per acre (MDE, 

2012). The capping costs for a 249.4-acre site in Cortland County, New York were estimated to 

be approximately $134,000 per acre. Factors influencing these costs include the materials used 

for the cap, site topography, and the availability of clay or soil suitable for use as the cover. 

Similar to the costs of the clay liner during the construction of the landfill, availability of nearby 

clay would significantly reduce this cost (EnSol, 2010). 

The closure process can include the installation of an LFG collection system which is 

necessary to collect and destroy or beneficially use the methane gas that is generated. (However, 

many landfills install gas collection and control systems as the landfill is being filled, or as areas 

within the landfill reach final grade, rather than waiting until closure to begin gas collection 

system installation.) The costs associated with an LFG collection and flare system are minimal as 

compared to the capital costs for landfill construction, annual landfill operating costs, and other 

closure costs. Section 6 discusses average installation costs for gas collection systems and flares. 

Post-closure care requires maintenance to ensure the integrity and effectiveness of the 

final cover system, leachate collection system, groundwater monitoring system, and methane gas 

monitoring system. These activities prevent water and air pollution from escaping into the 

surrounding environment. The required post-closure care period is 30 years from site closure, 

and can be shortened or extended by the director of an approved state program as necessary to 

ensure protection of human health and the environment. Over a 30-year period, post-closure care 

and maintenance can cost from $64,000 to $88,000 per acre (Duffy, 2005b). 
2-18

Figure 2-2 shows that landfill costs peak prior to the landfill opening and again following 

the landfill closing (EPA, 1997). 

Figure 2-2 Landfill Cost Life Cycle 

2.4.2 Landfill Revenue Sources 

The cost to dispose of MSW at a landfill is commonly known as a “tip fee” or “gate fee”. 

Typically, reported tip fees represent the “spot market” price for MSW disposal, i.e., the drive-up 

cost to dispose of a ton of waste (NSWMA, 2011). Other tip fees exist at MSW facilities (e.g., 

waste accepted under a long-term contract, volume discounts, and special wastes); these fees 

may be higher or lower than the spot market price (Repa, 2005). In September 2012, the average 

national spot market price to dispose of one ton of waste in a U.S. landfill was roughly $45, up 

3.5 percent over 2011 (WBJ, 2012). This compares to average national tip fees of approximately 

$32 in 1998 (EPA, 2002) and $8 in 1985 (NSWMA, 2011). 

Average tip fees vary by region of the country, as shown in Table 2-5. Tip fees in 

northeastern states have historically been and continue to be higher than those in other regions. 
2-19

The next most expensive areas, on average, are the Mid-Atlantic and western states. Tip fees 

tend to be higher near large population centers (Wright, 2012); this is likely influenced by the 

fact that metropolitan areas have less land area for waste disposal and therefore, fewer landfills. 

There is variation in tip fees within states as well, depending on landfill ownership (public or 

private) and proximity of other landfills. 

Table 2-5 Average Regional and National Per-Ton Tip Fees (Rounded): 1995-2012 

U.S. Region 1995a 1998a 2000a 2002a 2004a 2008b 2010c 2012d

Northeast $73 $67 $70 $69 $71 $67 NA $73 

Mid-Atlantic $46 $44 $46 $45 $46 $56 NA NA 

South $29 $31 $31 $30 $31 $32 NA NA 

Midwest $31 $31 $33 $34 $35 $39 NA NA 

South Central $20 $21 $22 $23 $24 $34 NA NA 

West Central $23 $23 $22 $23 $24 $39 NA NA 

West $38 $36 $35 $39 $38 $44 NA NA 

National $32 $32 $32 $34 $34 $42 $44 $45 

Northeast: CT, ME, MA, NH, NY, RI, VT 

Mid-Atlantic: DE, MD, NJ, PA, VA, WV 

South: AL, FL, GA, KY, MS, NC, SC, TN 

Midwest: IL, IN, IA, MI, MN, MO, OH, WI

South Central: AZ, AR, LA, NM, OK, TX 

West Central: CO, KS, MT, NE, ND, SD, UT, WY 

West: AK, CA, HI, ID, NV, OR, WA

a Source: Repa, 2005. 

b

 Source: Data from Biocycle, 2010. Data were not available for all states. For nine states, 2006 or 2009 data 

were substituted for missing year 2008 data. 

c

 Source: WBJ, 2010. 

d

 Source: WBJ, 2012.

Publicly owned landfills set tip fees based on the need to cover landfill and other waste 

management-related costs, while privately owned landfills’ tip fees are set based on competition 

or the lack thereof (Wright, 2012). For municipalities that depend on landfill tip fees to fund 

programs and services, more waste disposed in the local community-owned landfill means more 

money generated to fund their solid waste systems, including non-disposal services like 

recycling. Conversely, if more waste starts going to private landfills instead, less revenue is 

generated for community programs. An increasing presence of private facilities that can set 
2-20

competitive tip fees has caused some communities to reduce their own tip fees in an effort to 

attract enough disposal volume to keep revenues at a sufficient level (Burgiel, 2003). 

Historically, the construction and operating costs of public MSW landfills have been 

funded by tip fees, tax revenues (e.g., county/city property tax revenue that goes into a general 

fund), or a combination of these. Factors influencing tip fee values have included population and 

economic growth, recycling rates, operating and transportation costs, land values, and legislation. 

Traditionally, 30 percent of landfills receive all revenue from tip fees, 35 percent receive all 

revenue from taxes, and 35 percent cover the costs of waste disposal through a combination of 

tip fees and taxes. The use of taxes as a revenue source rather than tip fees has implications on 

waste disposal services. When disposal costs are included in taxes, most people are not aware of 

the actual costs involved and there is little incentive to reduce waste generation rates. Also, 

tax-supported facilities are typically underfunded relative to actual disposal costs, resulting in 

poorer operation than fully funded landfills supported by tip fees. Factors that influence the 

choice of revenue sources include landfill size and ownership. Landfills receiving small 

quantities of waste are likely to rely heavily on taxes for their revenue while larger landfills rely 

on both taxes and tip fees (EPA, 2002a). 

Private owners of landfills rely heavily on tip fees relative to other landfill owners. It 

remains unclear whether private landfills rely on tip fees because they are larger, or larger 

landfills rely heavily on tip fees because they are private (EPA, 2002a). 

As shown in Table 2-5, average tip fees by region remained fairly steady between 1995 

and 2004, with minor declines in some years but with a gradual upward trend. The greatest 

increases in average tip fees occurred between 1985 and 1995, with the national average tip fee 

increasing by $24 (293 percent) or an average of $2.40 per year. By contrast, between 1995 and 

2004, the national average tip fee increased by only 7 percent, or an average of 23 cents per year. 

Tip fees are expected to continue to increase gradually, based on recent data and given rising fuel 

costs, insurance costs, and other operating costs (Wright, 2012). 

A landfill can also generate revenue by entering an agreement to sell carbon credits for 

voluntary destruction of methane, entering a gas sales agreement to sell LFG for beneficial use, 

or entering a power purchase agreement to sell electricity generated from LFG and/or renewable 

energy credits from the generation of that electricity. These types of revenue are small relative to 

tip fees and total landfill revenues, but can help offset some landfill expenses, for example, the 
2-21

cost of installing a gas collection system or energy recovery equipment. More information about 

these potential revenue sources is available in Section 6. 

2.5 Air Pollutant Emissions from Landfills 

Municipal solid waste (MSW) landfills are a source of non-methane organic compounds 

(NMOC) which include volatile organic compounds (VOC) , methane, a potent greenhouse gas 

(GHG), and hazardous air pollutants. LFG is formed during the decomposition of landfilled 

waste and, if not controlled, can emit numerous pollutants into the air. Several factors affect the 

amount of LFG generated and its components, including the age and composition of the waste, 

the amount of organic compounds in the waste, and the moisture content and temperature of the 

waste (EPA, 2012k). LFG generated from established waste (waste that has been in place for at 

least a year) is typically composed of roughly 50 percent methane (CH4) and 50 percent carbon 

dioxide (CO2) by volume, with trace amounts of non-NMOC and inorganic compounds (e.g., 

hydrogen sulfide) (EPA, 2010c; EPA, 2012k). 

2.5.1 NMOC in LFG 

The NMOC portion of LFG, while a small amount of LFG by volume, can contain a 

variety of significant air pollutants. NMOC include various organic hazardous air pollutants 

(HAPs) and VOC. If left uncontrolled, VOC can contribute to the formation of ground-level 

ozone, a common pollutant with adverse health impacts. Nearly 30 organic hazardous air 

pollutants have been identified in uncontrolled LFG, including benzene, toluene, ethyl benzene, 

and vinyl chloride (EPA, 2012k). 

NMOC in LFG results mainly from the volatilization of organic compounds contained in 

the landfilled waste, while some NMOC may be formed by biological processes and chemical 

reactions within the waste (EPA, 1998). Waste materials that contribute to the formation of 

NMOC include items such as household cleaning products and materials coated with or 

containing paints and adhesives; during decomposition, NMOC can be stripped from these 

materials by other gases (e.g., CH4 or CO2) and become part of the LFG (EPA, 2012k). 

The concentration of NMOC in uncontrolled LFG depends on several factors, including 

waste types in the landfill and the local climate. EPA’s Compilation of Air Pollutant Emission 

Factors (AP–42) provides a default NMOC concentration of 595 parts per million by volume 
2-22

(ppmv), of which 110 ppmv are considered HAP compounds. The total uncontrolled organic 

HAPs volume in LFG from MSW landfills is typically less than 0.02 percent of the total LFG 

(EPA, 2012k). 

2.5.2 Methane in LFG 

Methane is 25 times more effective at retaining heat in the earth’s atmosphere than CO2

and therefore is considered a potent GHG (IPCC 2007). The CO2 generated from MSW landfills 

is deemed biogenic because the CO2 would have been generated anyway as a result of natural 

decomposition of the organic waste materials if they had not been deposited in the landfill (EPA, 

2010c). 

When waste is first placed in a landfill, it enters an aerobic decomposition stage during 

which little CH4 is produced. However, within a year or less, the waste environment becomes 

anaerobic, CH4 generation increases, and the amount of CO2 produced begins to level out (EPA, 

2010c). Figure 2-3 presents a sample LFG generation curve over time for a typical MSW 

landfill. Significant CH4 generation can continue for 10 to 60 years after initial waste placement 

(EPA, 2012k). 
2-23

Figure 2-3 Typical LFG Generation Curve 

In 2012, landfills were the third-largest anthropogenic source of CH4 emissions in the 

United States, accounting for approximately 18 percent (EPA, 2014). Increasing attention is 

being given to mitigation of CH4, given its global warming potential 25 times greater than CO2

and its relatively short atmospheric lifetime of about 12 years (as compared to 50-200 years for 

CO2) (EPA, 2014). 

2.5.3 Criteria Pollutants from Combustion of LFG 

While collection and combustion of LFG in a flare or energy project equipment (e.g., 

reciprocating engine, boiler, turbine) greatly reduces emissions of methane and NMOC 

(including VOC and organic HAP), the combustion process generates criteria pollutants 

including carbon monoxide (CO), nitrogen oxides (NOX), sulfur dioxide (SO2), and particulate 

matter (PM) (EPA, 1998). NOX formation is strongly tied to the combustion temperature in the 

equipment, while CO and PM emissions are primarily the result of incomplete combustion of the 
2-24

gas. SO2 production depends upon the amount of sulfur in the LFG (EPA, 2000). More 

information about LFG combustion devices is available in Section 6. 

2.6 Techniques for Controlling Emissions from Landfills 

2.6.1 Introduction 

Emissions from landfills can be controlled by installing gas collection systems and either 

flaring the LFG or utilizing it as an energy source. Large landfills with emissions exceeding 50 

megagrams per year (Mg/yr) of nonmethane organic compounds (NMOC) are required by the 

MSW landfills NSPS to control and/or treat LFG to significantly reduce the amount of toxic air 

pollutants released. However, many landfills voluntarily choose to control emissions, in part 

because of the economic benefits of LFG energy projects. 

This section describes the equipment and costs associated with LFG emission controls. 

The control technologies are divided into three categories: gas collection systems, destruction, 

and utilization. Much of the information in this section was obtained from the U.S. EPA’s 

Landfill Methane Outreach Program (LMOP) Landfill Gas Energy Project Development 

Handbook (EPA 2010d). 

2.6.2 Gas Collection Systems 

LFG collection typically begins after a portion of the landfill (known as a “cell”) is 

closed to additional waste placement. Gas vents are installed to collect LFG from the closed cell. 

The gas vents may be configured as vertical wells or horizontal trenches, and some collection 

systems involve a combination of the two. Vertical wells (Figure 2-4) are the most common 

method of LFG collection and involve drilling wells vertically in the waste to collect gas. 

Horizontal trenches (Figure 2-5) use piping laid horizontally in trenches in the waste; these 

systems are useful in deeper landfills and in areas of active filling. Both types of collection 

systems connect the wellheads to lateral piping that transports the gas to a collection header. 
2-25

Source: EPA, 2010d 

Figure 2-4 Vertical Well LFG Collection 

Source: EPA, 2010d 

Figure 2-5 Horizontal Trench LFG Collection 

Collection from the gas vents may be either passive or active. Passive systems rely on the 

natural pressure gradient between the waste mass and the atmosphere to move gas to collection 

systems. Most passive systems intercept LFG migration and the collected gas is vented to the 

atmosphere. Active systems use mechanical blowers or compressors to create a vacuum that 

optimizes LFG collection (ATSDR, 2001). 
2-26

Collection efficiency is a measure of the ability of a gas collection system to capture 

generated LFG. Although rates of LFG capture can be measured, rates of actual generation in a 

landfill cannot be measured; therefore, considerable uncertainty exists regarding actual collection 

efficiencies achieved at landfills. Collection efficiencies at landfills with comprehensive gas 

collection systems typically range from 60 to 85 percent, with an average of 75 percent most 

commonly assumed (EPA, 1998). 

Total collection system costs vary widely, based on a number of site-specific factors. For 

example, if the landfill is deep, collection costs tend to be higher because well depths will need 

to be increased. Collection costs also increase with the number of wells installed. Based on data 

from the LMOP’s Landfill Gas Energy Cost Model (LFGcost), the estimated capital cost (in 

2008 $’s) required for a 40-acre collection system designed for 600 cubic feet per minute (cfm) 

of LFG is $784,000, assuming one well is installed per acre. Typical annual operation and 

maintenance (O&M) costs (in 2008 $’s) for collection systems are $2,250 per well. If an LFG 

energy project generates electricity, a landfill will often use a portion of the electricity generated 

to operate the system and sell the rest to the grid in order to offset these operational costs.

2.6.3 Destruction 

Collected LFG is typically combusted in flares or combustion devices that recover 

energy, such as boilers, internal combustion engines, and gas turbines. Properly designed and 

operated combustion equipment generally reduces NMOC by 98 percent or to a 20 ppmv outlet 

concentration, as specified in the current MSW landfill NSPS (40 CFR 60.752). Combustion also 

destroys over 98 percent of the methane. 

Flares are the most common control device used at landfills. Flares are also a component 

of each energy recovery option because they may be needed to control LFG emissions during 

energy recovery system startup and downtime and to control any gas that exceeds the capacity of 

the energy conversion equipment. In addition, a flare is a cost-effective way to gradually increase 

the size of the energy recovery system at an active landfill. As more waste is placed in the 

landfill and the gas collection system is expanded, the flare is used to control excess gas between 

energy conversion system upgrades (e.g., before addition of another engine). 

Flare designs include open (or candlestick) flares and enclosed flares. Open flares employ 

simple technology where the collected gas is combusted in an elevated open burner. A 
2-27

continuous or intermittent pilot light is generally used to maintain the combustion. Enclosed 

flares typically employ multiple burners within fire-resistant walls, which allow them to maintain 

a relatively constant and limited peak temperature by regulating the supply of combustion air 

(ATSDR, 2001b). Enclosed flares are more expensive but may be preferable (or required by state 

regulations) because they provide greater control of combustion conditions, allow for stack 

testing, and might achieve slightly higher combustion efficiencies than open flares. They can 

also reduce noise and light nuisances. 

Flare costs vary based on the gas flow of the system. LFGcost estimates for flares include 

condensate collection and blowers. Condensate collection (also called knockout devices) is 

necessary because condensate forms when warm gas from the landfill cools as it travels through 

the collection system. If condensate is not removed, it can block the collection system. Blowers 

are needed to ensure a steady flow of gas to the flare. The size, type, and number of blowers 

needed depend on the gas flow rate and distance to downstream processes. 

Based on data from LFGcost (in 2008 $’s), a flare for a system with an average of 

600 cfm of LFG will cost $207,000 (including condensate collection and blowers). Typical 

annual O&M costs are approximately $4,500 per flare. Electricity costs to operate the blower for 

a 600 cfm active gas collection system average $44,500 per year. 

2.6.4 Utilization 

After collection, LFG may be used in an energy recovery system to combust the methane 

and other trace contaminants. LMOP’s Landfill and LFG Energy Project Database, which tracks 

the development of U.S. LFG energy projects and landfills with project development potential, 

indicates that approximately 600 LFG energy projects are currently operating in 48 states. 

Roughly three-fourths of these projects generate electricity, while one-fourth are direct-use 

projects in which LFG is used for its thermal capacity (EPA, 2012m). 

This section summarizes LFG utilization technologies in four general categories: power 

production, cogeneration, direct use, and alternative fuel. This section also provides a discussion 

of the economic benefits of LFG utilization projects. 

2.6.4.1 Technologies 

It is important to note that all of the technologies discussed below typically require 

treatment of LFG prior to entering the control device to remove moisture, particulates, and other 
2-28

impurities. (While “treatment” has a specific meaning within the MSW landfill NSPS, the term is 

used more generally in common usage and as discussed here.) The level of treatment can vary 

depending on the type of control and the types and amounts of contaminants in the gas. LFG is 

typically dehumidified, filtered, and compressed before being sent to energy recovery devices. 

For most boilers and internal combustion engines, no additional treatment is used. Some internal 

combustion engines and many gas turbine and microturbine projects apply siloxane removal 

using adsorption beds after the dehumidification step. 

2.6.4.1.1 Power Production 

Producing electricity from LFG continues to be the most common beneficial-use 

application, accounting for about three-fourths of all U.S. LFG energy projects (EPA, 2012m). 

Electricity can be produced by burning LFG in an internal combustion engine, a gas turbine, or a 

microturbine. 

The majority (more than 70 percent) of LFG energy projects that generate electricity do 

so by combusting LFG in internal combustion engines. Advantages of this technology include: 

low capital cost, high efficiency, and adaptability to variations in the gas output of landfills. 

Internal combustion engines are well-suited for 800 kilowatt (kW) to 3 megawatt (MW) projects, 

but multiple units can be used together for projects larger than 3 MW. Internal combustion 

engines are relatively efficient at converting LFG into electricity, achieving efficiencies in the 

range of 25 to 35 percent. 

Gas turbines are more likely to be used for large projects, where LFG volumes are 

sufficient to generate a minimum of 3 MW and typically more than 5 MW. Unlike most internal 

combustion engine systems, gas turbine systems have significant economies of scale. The cost 

per kW of generating capacity drops as gas turbine size increases, and the electric generation 

efficiency generally improves as well. 

Microturbines, as their name suggests, are much smaller than turbines, with a single unit 

having between 30 and 250 kW in capacity, and thus are generally used for projects smaller than 

1 MW. Small internal combustion engines are also available for projects in this size range and 

are generally less costly. Microturbines may be selected for certain projects (rather than internal 

combustion engines) because they can operate with as little as 35 percent methane and less than 

300 cfm, and also produce low nitrogen oxide emissions. 
2-29

An LFG energy project may use multiple units to accommodate a landfill’s specific gas 

flow over time. For example, a project might have three internal combustion engines, two gas 

turbines, or an array of 10 microturbines, depending on gas flow and energy needs. 

The costs of energy generation using LFG vary greatly; they depend on many factors 

including the type and size of electricity generation equipment, the necessary compression and 

treatment system, and the interconnect equipment. Table 2-6 presents examples of typical costs 

for several technologies, including costs for a basic gas treatment system typically used with 

each technology. 

Table 2-6 Average LFG Power Production Technology Costs

Technology 

Typical Capital Costs 

($/kW)a

Typical Annual O&M Costs 

($/kW)a

Internal combustion engine (>800 kW) $1,700 $180 

Small internal combustion engine (<1 MW) $2,300 $210 

Gas turbine (>3 MW) $1,400 $130 

Microturbine (<1 MW) $5,500 $380 

Source: EPA 2010d 

a

 2010 $’s 

2.6.4.1.2 Cogeneration 

LFG energy cogeneration applications, also known as combined heat and power (CHP) 

projects, provide greater overall energy efficiency and are growing in number. In addition to 

producing electricity, these projects recover and beneficially use the heat from the unit 

combusting LFG. LFG cogeneration projects can use internal combustion engine, gas turbine, or 

microturbine technologies. 

Less common LFG electricity generation technologies include a few boiler/steam turbine 

applications in which LFG is combusted in a large boiler to generate steam which is then used by 

a steam turbine to create electricity. A few combined cycle applications have also been 

implemented. These combine a gas turbine that combusts LFG with a steam turbine that uses 

steam generated from the gas turbine’s exhaust to create electricity. Boiler/steam turbine and 

combined cycle applications tend to be larger in scale than the majority of LFG electricity 

projects that use internal combustion engines. 
2-30

2.6.4.1.3 Direct Use 

The simplest and often most cost-effective use of LFG is direct use as a fuel for boilers 

and other direct thermal applications to produce useful heat or steam. However, this is only an 

option if there is an end user located near the landfill who is willing and able to use the LFG. An 

end user’s energy requirements are an important consideration when evaluating the sale of LFG 

for direct use. Because no economical way to store LFG exists, all gas that is recovered must be 

used as available; gas that cannot be immediately used in energy recovery equipment is flared 

and the associated revenue opportunities are lost. The ideal gas customer, therefore, will have a 

steady annual gas demand compatible with the landfill’s gas flow. When a landfill does not have 

adequate gas flow to support the entire needs of a facility, LFG can still be used to supply a 

portion of the needs. The number and diversity of direct-use LFG applications is continuing to 

grow. 

Boilers are the most common type of direct use, and LFG is used in boilers at a wide 

variety of industrial manufacturing facilities as well as commercial and institutional buildings. 

Boilers can often be easily converted to use LFG alone or in combination with fossil fuels. 

Equipment modifications or adjustments may be necessary to accommodate the lower Btu value 

of LFG, and the costs of modifications will vary. If retuning the boiler burner is the only 

modification required, costs will be minimal. However, retrofitting an existing natural gas boiler 

to include LFG may cost between $100,000 and $400,000, depending on the extent of the 

retrofit. 

Direct thermal applications include kilns (e.g., cement, pottery, and brick), tunnel 

furnaces, process heaters, and blacksmithing forges. In addition, infrared heaters can use LFG to 

fulfill space heating needs. Greenhouses can combust LFG in boilers to provide heat for the 

greenhouse and to heat water used in hydroponic plant culture. LFG can be used to heat the 

boilers in plants that produce biofuels including biodiesel and ethanol. 

Table 2-7 presents typical cost ranges for the components of a direct-use project. The 

costs shown below for the gas compression and treatment system include compression, moisture 

removal, and filtration equipment typically required to prepare the gas for transport through the 

pipeline and for use in a boiler or process heater. If more extensive treatment is required to 

remove other impurities, costs will be higher. The gas pipeline costs also assume typical 

construction conditions and pipeline design. Pipelines can range from less than a mile to more 
2-31

than 30 miles long, although most are shorter than 10 miles because length has a major effect on 

costs. In addition, the costs of direct-use pipelines are often affected by obstacles along the route, 

such as highway, railroad, or water crossings. End users will likely need to modify their 

equipment to make it suitable for combusting LFG, but these costs are usually borne by the end 

user and are site-specific to their combustion device. 

Table 2-7 Average LFG Direct-use Project Components Costs

Component Typical Capital Costsa

 Typical Annual O&M Costsa 

Gas compression and treatment $960/scfm $90/scfm 

Gas pipeline and condensate 

management system 

$330,000/mile Negligible 

Source: EPA 2010d 

a

 2010 $’s, based on a 1,000 scfm system 

scfm: standard cubic feet per minute 

2.6.4.1.4 Alternative Fuel 

Production of alternative fuels from LFG, by upgrading the gas using high-Btu 

conversion technologies, is becoming more prevalent. LFG can be used to produce the 

equivalent of pipeline-quality gas (natural gas), compressed natural gas (CNG), or liquefied 

natural gas (LNG). Pipeline-quality gas can be injected into a natural gas pipeline and used by 

residential, commercial, or industrial end users along the pipeline. CNG and LNG can be used to 

fuel vehicles at the landfill (e.g., water trucks, earthmoving equipment, light trucks, autos), fuel 

refuse-hauling tucks (long-haul refuse transfer trailers and route collection trucks), and supply 

the general commercial market. Although only a handful of these projects are currently 

operational, several more are in the construction or planning stages. 

LFG can be converted into a high-Btu gas by increasing its methane content and, 

conversely, reducing its carbon dioxide, nitrogen, and oxygen content. In the United States, three 

methods have been commercially employed (i.e., beyond pilot testing) to remove carbon dioxide 

from LFG, including membrane separation, molecular sieve (also known as pressure swing 

adsorption or PSA), and amine scrubbing. 

Recent capital costs of high-Btu processing equipment have ranged from $2,600 to 

$4,300 per standard cubic foot per minute (scfm) of LFG. The annual cost to provide electricity 
2-32

to, operate, and maintain these systems ranges from $875,000 to $3.5 million (EPA 2010d).

Costs will depend on the purity of the high-Btu gas required by the receiving pipeline or energy 

end user as well as the size of the project, since some economies of scale can be achieved when 

producing larger quantities of high-Btu gas. 

2.6.4.2 Revenues and Incentives 

Landfill owners can receive revenue from the sale of carbon credits, the sale of electricity 

generated from LFG to the local power grid, or from the sale of LFG to a direct end user or 

pipeline. However, the revenue received represents only a small percentage of the operating 

costs of a landfill. 

2.6.4.2.1 Greenhouse Gas Credits 

Voluntary greenhouse gas trading programs purchase credits from landfills that capture 

LFG to destroy or convert methane contained in the gas and obtain credit for the reduction of 

greenhouse gas in terms of carbon equivalents. In order to qualify for these programs, the 

emission reductions must be in addition to regulated actions and have recent project installation. 

Examples of companies operating on the voluntary carbon market include Climate Action 

Reserve, EcoSecurities, Evolution Markets, AgCert, Blue Source, GE/AES, and Chicago Climate 

Exchange (EPA 2012a). 

Bilateral trading and greenhouse gas credit sales are other voluntary sources of revenue. 

Bilateral trades are project-specific and are negotiated directly between a buyer and seller of 

greenhouse gas credits. In these cases, corporate entities or public institutions, such as 

universities, may wish to reduce their “carbon footprint” or meet internal sustainability goals, but 

do not have direct access to developing their own project. Therefore, a buyer may help finance a 

specific project in exchange for the credit of offsetting greenhouse gas emissions from their 

organization. 

Many state and regional government entities are establishing their own greenhouse gas 

initiatives to cap or minimize greenhouse gas emissions within their jurisdictions. Examples 

include the Regional Greenhouse Gas Initiative (RGGI), the Washington carbon dioxide offset 

program, and the Massachusetts carbon dioxide reduction from new plants. Some of these 

programs establish a cap-and-trade program on carbon dioxide emissions, while others require 
2-33

new fossil-fueled boilers and power plants to either implement or contribute to funding of offset 

projects, including LFG. 

Certain LFG energy projects may qualify for participation in nitrogen oxides cap-andtrade programs, such as the nitrogen oxides State Implementation Plan (SIP). The revenues for 

these incentives vary by state and will depend on factors such as the allowances allocated to each 

project, the price of allowances on the market, and if the project is a CHP project (typically CHP 

projects receive more revenue due to credit for avoided boiler fuel use). 

2.6.4.2.2 Electricity Project Revenue 

The primary revenue component of the typical electricity project is the sale of electricity 

to the local utility. This revenue stream is affected by the electricity buy-back rates (i.e., the rate 

at which the local utility purchases electricity generated by the LFG energy project). Electricity 

buy-back rates for new projects depend on several factors specific to the local electric utility and 

the type of contract available to the project, but typically range between 2.5 and 7 cents per 

kilowatt-hour (kWh) (EPA, 2010d). 

When assessing the economics of an electricity project, it is also important to consider 

the avoided cost of the electricity used on-site. Electricity generated by the project that is used in 

other operations at the landfill is, in effect, electricity that the landfill does not have to purchase 

from a utility. This electricity is not valued at the buy-back rate, but at the rate the landfill is 

charged to purchase electricity (i.e., retail rate). The retail rate is often significantly higher than 

the buy-back rate. 

LFG energy projects can potentially use a variety of additional environmental revenue 

streams, which typically take advantage of the fact that LFG is recognized as a renewable, or 

“green,” energy resource. These additional revenues can come from premium pricing, tax credits, 

greenhouse gas credit trading, or incentive payments. They can be reflected in an economic 

analysis in various ways, but typically, converting to a cents/kWh format is most useful. 

LFGcost accommodates four common types of electric project credits: a direct cash grant, a 

renewable energy tax credit expressed in dollars per kWh, a direct greenhouse gas (carbon) 

credit expressed in dollars per metric ton of carbon dioxide equivalent (discussed in 

Section 6.3.2.1), and a direct electricity tax credit expressed in dollars per kWh. This section 
2-34

includes discussion of the available environmental revenue streams that an LFG electricity 

project could possibly use. 

Premium pricing is often available for renewable electricity (including LFG) that is 

included in a green power program, through a Renewable Portfolio Standard (RPS), a Renewable 

Portfolio Goal (RPG), or a voluntary utility green pricing program. These programs could 

provide additional revenue above the standard buy-back rate because LFG electricity is 

generated from a renewable resource. 

Renewable energy certificates (RECs) are sold through voluntary markets to consumers 

seeking to reduce their environmental footprint. They are typically offered in 1 megawatt-hour 

(MWh) units, and are sold by LFG electricity generators to industries, commercial businesses, 

institutions, and even private citizens who wish to achieve a corporate renewable energy 

portfolio goal or to encourage renewable energy. If the electricity produced by an LFG energy 

project is not being sold as part of a utility green power program or green pricing program, the 

project owner may be able to sell RECs through voluntary markets to generate additional 

revenue. 

Tax credits, tax exemptions, and other tax incentives, as well as federal and state grants, 

low-cost bonds, and loan programs are available to potentially provide funding for an LFG 

energy project. For example, Section 45 of the Internal Revenue Code provides a per-kWh 

federal production tax credit for electricity generated at privately owned LFG electricity projects. 

To qualify for the credit, which was 1.1 cent per kWh for the 2009 taxable year, all electricity 

produced must be sold to an unrelated person during the taxable year. Under legislation passed in 

February 2009, the placed-in-service date deadline for LFG energy projects to be eligible for the 

first 10 years of production is December 31, 2013. Another popular funding option is the Clean 

Renewable Energy Bond (CREB) program, which allows electric cooperatives, government 

entities, and public power producers to issue bonds to finance renewable energy projects 

including LFG electricity projects. The borrower pays back the principal of the CREB, and the 

bondholder receives federal tax credits in lieu of the traditional bond interest. 

2.6.4.2.3 Direct-use Project Revenues 

The primary source of revenue for direct-use projects is the sale of LFG to the end user; 

the price of LFG, therefore, dictates a project’s revenue. Often LFG sales prices are indexed to 
2-35

the price of natural gas, but prices will vary depending on site-specific negotiations, the type of 

contract, and other factors. In recent years, typical LFG prices have ranged from $4.00 to $8.00 

per million British thermal units (MMBtu) or 0.38¢ to 0.75¢ per megajoule. In general, the price 

paid by the end user must provide an energy cost savings that outweighs the cost of required 

modifications to boilers, process heaters, kilns, and furnaces in order to burn LFG. 

Federal and state tax incentives, loans, and grants are available that may provide 

additional revenue for direct-use projects. Greenhouse gas emissions trading programs are also 

potential revenue streams for direct-use projects. 

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<http://www.mde.state.md.us/programs/ResearchCenter/FactSheets/LandFactSheet/Documents/

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562212). 

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2-38

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Quality Planning and Standards. “Compilation of Air Pollutant Emission Factors, Fifth Edition, 

Volume I: Stationary Point and Area Sources, Chapter 3: Stationary Internal Combustion 

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2-39

<http://www.epa.gov/osw/nonhaz/municipal/landfill/financial/mswclose.htm>. Last accessed on 

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2-40

Wright, Shawn. 2012. Waste & Recycling News. “Tipping fees vary across the U.S.” July 20, 

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3-1 

3 REGULATORY PROGRAM COSTS AND EMISSIONS REDUCTIONS 

3.1 Introduction 

Currently, the NSPS requires landfills of at least 2.5 million megagrams (Mg) capacity 

and 2.5 million cubic meters in size with estimated nonmethane organic compounds (NMOC) 

emissions of at least 50 Mg per year to collect and control or treat landfill gas (LFG). Landfills 

which meet the design size requirements but do not emit at least 50 Mg NMOC per year are 

required to test and monitor. As part of this review, the EPA evaluated the emission reductions 

and costs associated with a series of regulatory options. This section of the EIA includes three 

sets of discussions related to the proposed new subpart of the NSPS: 

 Emissions Analysis 

 Engineering and Administrative Cost Analysis 

 Regulatory Option Analysis 

This discussion of the emissions and cost analyses is meant to assist the reader of the EIA to 

better understand the economic impact analysis. However, we provide references to the 

technical memoranda prepared by the Office of Air Quality Planning and Standards (OAQPS) 

for the reader interested in a greater level of detail. 

3.2 General Assumptions and Procedures 

The proposed new subpart will affect new landfills. New landfills are defined as landfills 

that commence construction, reconstruction, or modification after the publication of this 

proposed rule. The EPA is unable to exactly predict the physical attributes, location, and 

ownership of landfills opened in the future. To assess the impacts of the proposal, the EPA drew 

upon a comprehensive database of existing landfills to develop model landfills to represent new 

landfills opening in the first 5 years after new subpart XXX is proposed (2014-2018). The model 

future landfills were developed by evaluating the most recently opened existing landfills and 

assuming that the sizes and locations of landfills opening in the future would be similar to the 

sizes and locations of landfills that opened in the last 10 years. Based on this assessment, The 

EPA created a total of 21 model landfills to represent landfills opening during the five years after 
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proposal. The creation of the landfill dataset is detailed in the docketed memorandum, 

“Summary of Landfill Dataset Used in the Cost and Emission Reduction Analysis of Landfill 

Regulations. 2014.” Data for existing landfills were obtained from a database maintained by 

EPA’s Landfill Methane Outreach Program, voluntary data submitted to the EPA by the landfill 

industry as part of this rulemaking effort, and data from the EPA Greenhouse Gas Reporting 

Program.

To estimate the cost and emission impacts of each regulatory option, EPA determined 

which of these model landfills met the design capacity and emission rate thresholds for each 

regulatory option, then calculated the emission reductions and costs for each model landfill under 

each regulatory option in 2023 using the methods described below. The resulting costs and 

emission reductions incurred by each landfill were used to assess the overall impacts of the 

current NSPS in the baseline and the incremental impacts of the regulatory options considered. 

The emission reduction and cost and revenue equations and assumptions are detailed in the 

docketed memorandum from ERG to EPA, “Methodology for Estimating Cost and Emission 

Impacts of Proposed MSW Landfill Regulations. 2014.” 

Although NSPS impacts are frequently examined over the first five years of rule 

implementation, the EPA reviewed ten years (2014-2023) for this analysis and presents costs and 

emission reductions for the year 2023. Due to the emission characteristics of landfills, five years 

would not provide a representative population of landfills for evaluating alternative standards. 

Landfills do not become subject to the control requirements of the standards on the date that they 

begin operation. Instead, landfills exceeding the design capacity threshold become subject to 

control requirements 30 months after the emissions exceed 50 Mg NMOC per year. It may take 

well over five years for a newly constructed landfill to exceed the NMOC threshold, depending 

on the rate of waste acceptance and other site-specific factors. Therefore, a five-year period for 

evaluation of the rule would not capture the control costs incurred by landfills constructed during 

the five-year period that would ultimately be subject to the landfills NSPS. Because the 

applicability provisions are triggered relatively late in the ten year period considered, the EPA 

presents costs and emission reductions for the year 2023. This is more representative of the 

impacts of the rule than an annual average over this 10-year period, which would understate the 

costs and emission reductions since many of the early years of this period (2014-2019) represent 

no emission reductions or control costs. 
3-3 

The emissions and cost modeling was based upon the following basic assumptions: 

 The baseline represents the emission reductions and costs associated with the 

requirements of Subpart WWW. Each regulatory option was compared to this baseline. 

 Each landfill would install gas collection and control systems (GCCS) when the landfill 

exceeds the emission rate and design capacity threshold. 

 Each landfill would remove GCCS when the actual emissions are below the emissions 

threshold, the landfill is closed, and the controls have been in place for at least 15 years. 

 Costs were annualized using a 7 percent interest rate, which is consistent with EPA 

guidance for cost evaluations. 

Alternative regulatory options varied the emission rate thresholds and design capacity thresholds. 

 

3.3 Emissions Analysis 

 

 To estimate emission reductions, the amount of LFG and NMOC emitted at each landfill 

was estimated using a model programmed in Microsoft® Access. The model assumes that the 

collection equipment is installed and operational at the landfill 30 months after the emissions 

exceed the NMOC emission threshold in each option. As the landfill is filled over time, the 

model assumes the landfill expands the GCCS into new areas of waste placement in accordance 

with the expansion lag time of the standard. Once the landfill has reached the maximum gas 

production and the gas production starts to decrease, the analysis assumes that the GCCS will 

collect all of the collectable gas. The emission reductions are equal to the amount of collected 

NMOC or methane that is combusted, which is estimated by multiplying the amount of collected 

gas by a destruction efficiency of 98 percent. 

3.4 Engineering and Administrative Cost Analysis 

The evaluation will assume that landfills will install and remove LFG controls as required 

by the rule. Landfills are required to install controls when the landfill exceeds the emission rate 

and design capacity thresholds. Landfills are allowed to remove controls when the actual 

emissions are below the emissions threshold, the landfill is closed, and the controls have been in 

place for at least 15 years. 
3-4 

The EPA derived the cost equations used in the evaluation from the EPA’s Landfill Gas 

Energy Cost Model (LFGcost), version 2.2, which was developed by the EPA’s Landfill 

Methane Outreach Program (LMOP). LFGcost estimates gas collection, flare, and energy 

recovery system costs and was developed based on cost data obtained from equipment vendors 

and consulting firms that have installed and operated numerous gas collection and control 

systems. LFGcost encompasses the types of costs included in the EPA OAQPS control cost 

manual including capital costs, annual costs, and recovery credits. Total capital costs include 

purchased equipment costs, installation costs, engineering and design costs, costs for site 

preparation and buildings, costs of permits and fees, and working capital. Total annual costs 

include direct costs, indirect costs, and recovery credits. Direct annual costs are those that are 

proportional to a facility-specific metric such as the facility’s productive output or size. Indirect 

annual costs are independent of facility-specific metrics and may include categories such as 

administrative charges, taxes, or insurance. Recovery credits are for materials or energy 

recovered by the control system. 

For this evaluation, the EPA assessed costs in 2012$. The costs included in LFGcost are 

in 2008$. Therefore, the EPA multiplied all costs that are based on LFGcost data by an 

escalation factor to convert them to 2012$. The EPA used an interest rate of 7% to annualize the 

capital costs in this evaluation to estimate the annual capital cost of flares, wells, wellheads 

(including piping to collect gas), and engines over the lifetime of the equipment. The EPA 

assumes that the equipment will be replaced when its lifetime is over, so the annualized capital 

costs are incurred as long as the landfill still has controls in place. In order to calculate the 

annualization factors, the EPA assumes that flares, wells, well heads, and engines have a 15-year 

lifetime. In addition, there is a mobilization/installation charge to bring well drilling equipment 

on site each time the gas collection system is expanded. Because the landfill will be drilling 

wells to expand the control system during the expansion lag year, EPA assumes that this capital 

installation cost has a lifetime equal to the expansion lag time. 

A number of the capital costs equations are dependent upon the number of wells at each 

landfill. In order to estimate the number of wells at each landfill, EPA estimated the number of 

acres that have been filled with waste for each landfill for each year. We assumed that the 

percentage of design area filled (acres) would track the ratio of waste in place/design capacity 
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(e.g., is a landfill has a waste-in-place amount equivalent to 40% of design capacity, then 40% of 

the planned acreage is filled). EPA assumed that each landfill would install one well per acre 

and that the number of wells would increase periodically based on expansion lag time. 

Engines are assumed to be installed only at landfills that produce enough LFG to power 

the engine and only when the electricity buyback rates allow the operation of the engine to be 

profitable. Standard engines used at landfills have approximately 1 MW capacity, which equates 

to 195 million ft3

 per year of collected LFG (at 50 percent methane). Therefore, engines are 

assumed to be installed at landfills that have at least 195 million ft3

 per year of collected LFG for 

at least 15 years. 

EPA calculated and summed the engine capital and operation and maintenance (O&M) 

equations to determine at what electricity buyback rate an engine is profitable. The profitable 

electricity buyback rates are rates that are greater than $0.0457 per kWh at 7%. Engines were 

only assumed to be installed in states with buyback rates exceeding those values. 

Multiple engines may be present at a landfill when there is sufficient gas flow to support 

additional engines. As noted above, one engine requires 195 million ft3

 per year of collected 

LFG, so in order to have two engines on-site, the landfill must have double that amount of LFG 

(390 million ft3 per year) for at least 15 years. 

The capital costs for engines are based on the capital costs for standard reciprocating 

engine-generator sets in LFGcost. These costs include gas compression and treatment to remove 

particulates and moisture (e.g., a chiller), reciprocating engine and generator, electrical 

interconnect equipment, and site work including housings, utilities, and total facility engineering, 

design, and permitting. 

3.5 Regulatory Baseline and Options 

As mentioned before, the alternative regulatory options differ from the baseline by 

varying in the design capacity thresholds and emission rate thresholds: 

 Baseline: design capacity retained at 2.5 Mg, emission threshold retained at 50 Mg 

NMOC/year

 Alternative Option 3.0/40: raises design capacity to 3.0 Mg and emission threshold to 

40 NMOC Mg/yr
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 Proposed Option 2.5/40: design capacity retained at 2.5 Mg, lowers emission threshold 

to 40 NMOC Mg/yr 

 Alternative Option 2.0/40: lowers design capacity to 2.0 Mg, emission threshold 

retained at 40 Mg NMOC/year 

The baseline reflects the parameters of the current NSPS. In the baseline, the NSPS affects 17 

new landfills, meaning that 17 of the 21 model landfills predicted using the methods described 

earlier meet the design capacity thresholds of each option and would at a minimum have to 

report their emissions during this period. In the baseline, 8 of these landfills would also install 

controls by 2023. Additionally, while not quantified, the costs associated with the additionally 

proposed changes to address other regulatory issues and clarifications are expected to be 

minimal. 

Based on the characteristics of the projected landfills, the additional options presented in 

Table 3-1 would require 11 landfills to install controls by 2023. Thus, 11 landfills would incur 

costs and achieve emission reductions by 2023 under all of the more stringent options, compared 

with 8 landfills under the baseline option. 

Table 3-1 Number of Affected New Landfills under the Baseline and Alternative Options 

 Affected New Landfills (no.) 

Landfills 

Affected* 

Landfills 

Reporting but 

Not Controlling 

Emissions 

Landfills 

Controlling 

Emissions 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 17 9 8 

Incremental values versus the current NSPS 

Alternative option 3.0/40 0 -3 3 

Proposed option 2.5/40 0 -3 3 

Alternative option 2.0/40 1 -2 3 

* Not all new projected new landfills are predicted to be affected by the NSPS in the baseline. 

Although only three additional landfills require control in the alternative options when 

compared to the baseline, each of these options would reduce emissions from other landfills 
3-7 

because lower NMOC emission thresholds would subject landfills to the control requirements at 

an earlier date. 

Under the proposed option 2.5/40 and the two alternative options considered (alternative 

options 3.0/40 and 2.0/40), three additional landfills would be required to install controls by 

2023. The reductions achieved under each option are the same because each option has the same 

NMOC threshold trigger of 40 Mg/yr. The corresponding emission reductions would be an 

additional 79 Mg NMOC, 12,000 Mg methane, and 308,000 Mg CO2-e compared the baseline in 

2023. The wide range in magnitude of emission reductions among pollutants is due to the 

composition of landfill gas: NMOC represents less than 1 percent of landfill gas, while methane 

represents approximately 50 percent. Each of these options represents approximately a 13 

percent reduction beyond the current NSPS. 

Table 3-2 Estimated Annual Average Emissions Reductions for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC Methane 

Methane 

(in CO2-

equivalents)*

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 610 95,000 2,400,000 

Incremental values versus the current NSPS 

Alternative option 3.0/40 79 12,000 308,000 

Proposed option 2.5/40 79 12,000 308,000 

Alternative option 2.0/40 79 12,000 308,000 

*A global warming potential of 25 is used to convert methane to CO2-equivalents.

Under the proposed option 2.5/40 and the alternative option 3.0/40, the additional cost in 

2023 would be $471,000 (Table 3-3). The cost is identical for these two options because all of 

the projected new landfills that exceed the NMOC thresholds have a design capacity greater than 

3.0 million Mg. Based on the characteristics of recently constructed landfills, it is likely that 

most new landfills will be larger sites and therefore reducing the design capacity threshold is not 

likely to have any impact. The 2023 cost of alternative option 2.0/40 is only $1,700 higher, at 

$473,000 due to additional reporting costs for one landfill that is projected to exceed the lowered 
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design capacity thresholds but not the NMOC threshold. All of these options represent 

approximately 17 percent in additional costs beyond the baseline. 

Table 3-3 Estimated Engineering Compliance Costs for the Baseline and Alternative 

Options 

 Estimated Annualized Net Cost (2012 dollars) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial 

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 66,000 24,000,000 21,300,000 2,700,000 

Incremental values versus the current NSPS 

Alternative option 3.0/40 6,000 3,200,000 2,700,000 471,000 

Proposed option 2.5/40 6,000 3,200,000 2,700,000 471,000 

Alternative option 2.0/40 7,600 3,200,000 2,700,000 473,000 

Note: all total are independently rounded and might not sum. 

In terms of cost effectiveness, the overall average cost effectiveness for NMOC reductions is 

$4,400 per Mg NMOC under the baseline and $6,000 per Mg NMOC under the proposed option 

2.5/40 and alternative option 3.0/40 (Table 3-4). For alternative option 2.0/40, however, there are 

additional reporting requirements for one landfill affected by this option that would result in 

marginally higher actual cost effectiveness than the proposed option 2.5/40. The docketed memo 

“Methodology for Estimating Testing and Monitoring Costs for MSW Landfill Regulations. 

2014.” contains the details for determining the costs that a landfill would incur to conduct testing 

and monitoring. 

 
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Table 3-4 Estimated Cost-effectiveness for the Baseline and Alternative Options 

 Cost-effectiveness (2012 dollars per Mg)* 

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 4,400 29 1.1

Incremental values versus the current NSPS 

Alternative option 3.0/40 6,000 38 1.5

Proposed option 2.5/40 6,000 38 1.5

Alternative option 2.0/40 6,000 38 1.5

Note: The cost-effectiveness of NMOC and methane are estimated as if all of the control cost were attributed to each 

pollutant separately. 

The average cost-effectiveness of controlling methane is significantly lower than for NMOC 

because methane constitutes approximately 50 percent of landfill gas, while NMOC represents 

less than 1 percent of landfill gas. 

The EPA considered even more stringent alternatives in its analysis of control options 

that may achieve additional reductions of NMOC and methane. For example, reducing the 

NMOC threshold further from the 40 Mg/yr in option 2.0/40 to 34 Mg/yr in an alternative option 

2.0/34 would achieve additional NMOC and methane reductions over the next 10 years. 

Additional emission reductions would be achieved because the lower NMOC threshold would 

require earlier installation of controls. The average annualized cost to implement alternative 

option 2.0/34 would be higher than proposed option 2.5/40 over a 10-year period. 
4-1 

4 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS 

4.1 Economic Impact Analysis 

The impacts shown of the proposal reflect the incremental difference between facilities in 

the baseline and for an option that reduces the NMOC emission rate threshold to 40 Mg/yr from 

the current NSPS level of 50 Mg/yr (proposed option 2.5/40). The proposal retains the design 

capacity threshold of 2.5 million Mg or 2.5 million cubic feet. 

Because the proposed option 2.5/40 tightens the criteria for installing and expanding the 

gas collection and control system, there are incremental costs associated with capturing and/or 

utilizing the additional LFG under this more stringent option. These costs were shown in Section 

3 of this EIA to be about $471,000 in 2023. 

Because of the relatively low cost of proposed option 2.5/40 and the lack of appropriate 

economic parameters or model, the EPA is unable to estimate the impacts of the options on the 

supply and demand for MSW landfill services. Additionally, while not quantified, the costs 

associated with the additionally proposed technical amendments to address other regulatory 

issues and clarifications are expected to be minimal.

Because the relatively low incremental costs of the proposed option 2.5/40, the EPA does 

not believe the proposal would lead to changes in supply and demand for landfill services or 

waste disposal costs, tipping fees, or the amount of waste disposed in landfills. Hence, the 

overall economic impact of the proposal should be minimal on the affected industries and their 

consumers. 

4.2 Small Business Impacts Analysis 

The Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement 

Fairness Act (SBREFA) generally requires an agency to prepare a regulatory flexibility analysis 

of any rule subject to notice and comment rulemaking requirements under the Administrative 

Procedure Act or any other statute, unless the agency certifies that the rule will not have a 

significant economic impact on a substantial number of small entities. Small entities include 

small businesses, small governmental jurisdictions, and small not-for-profit enterprises. 
4-2 

After considering the economic impact of the final rules on small entities for the 

proposal, the analysis indicates that this rule will not have a significant economic impact on a 

substantial number of small entities (or “SISNOSE”). The supporting analyses for these 

determinations are presented in this section of the EIA. 

For purposes of assessing the impact of the proposed amendments on small entities, a 

small entity is defined as: (1) A small business that is primarily engaged in the collection and 

disposal of refuse in a landfill operation as defined by NAICS codes 562212 with annual receipts 

less than $35.5 million; (2) a small governmental jurisdiction that is a government of a city, 

county, town, school district or special district with a population of less than 50,000, and (3) a 

small organization that is any not-for-profit enterprise that is independently owned and operated 

and is not dominant in its field. 

The analysis provides the EPA with an estimate of the magnitude of impacts the proposal 

may have on the entities that own facilities the EPA expects might be impacted by the rule. The 

analysis focuses on small entities because they may have more difficulty complying with a new 

regulation or affording the costs associated with meeting the new standard. This section presents 

the data sources used in the analysis, the methodology we applied to develop estimates of 

impacts, the results of the analysis, and conclusions drawn from the results. 

This small entity impacts analysis relies upon a series of firm-level sales tests for entities 

that are likely to be associated with NAICS code 562212. Because the exact specifications of 

future landfills are unknown, EPA developed 21 model landfills and assumed that these landfills 

would be financially and operationally similar to those that have opened in the preceding 10 

years. For this analysis, the EPA obtained firm-level employment and revenues for all 21 model 

landfills from Hoovers, a database of business information. Based on these historical data, the 

EPA identified four model landfills that would be classified as small entities and none that would 

be classified as small governments. The EPA then estimated firm-level compliance cost impacts 

and calculated cost-to-revenue ratios to identify small firms that might be significantly impacted 

by the rules. 

For the sales test, we divided the estimates of annualized establishment compliance costs 

by estimates of firm revenue. This is known as the cost-to-revenue ratio, or the “sales test.” The 

“sales test” is the impact methodology the EPA employs in analyzing small entity impacts as 

opposed to a “profits test,” in which annualized compliance costs are calculated as a share of 
4-3 

profits. The use of a “sales test” for estimating small business impacts for a rulemaking such as 

this one is consistent with guidance offered by the EPA on compliance with SBREFA5 and is 

consistent with guidance published by the U.S. SBA’s Office of Advocacy that suggests that cost 

as a percentage of total revenues is a metric for evaluating cost increases on small entities in 

relation to increases on large entities.6

The small entities subject to the requirements of this proposed rule may include private 

small businesses and small governmental jurisdictions that own or operate landfills. Although it 

is unknown how many new landfills will be owned or operated by small entities, recent trends in 

the waste industry have been towards consolidated ownership among larger companies. The EPA 

has determined that approximately 10 percent of the existing landfills subject to similar 

regulations (40 CFR Part 60 subparts WWW and Cc or the corresponding State or Federal plan) 

are small entities. 

Only one of the four small landfills was predicted to be incrementally affected by the 

proposal in 2023. The screening analysis compared estimated compliance costs in 2023 for the 

proposal to company sales based on historical data. The ratio of compliance cost to company 

revenue was 12 percent in 2023 for the incrementally affected small entity. 

To determine whether the impacts estimated for 2023 are representative of longer-term 

impacts to small landfills, the EPA further investigated 30 years of cost information (2014-2043) 

for the four small model landfills. Over the 30-year time frame, two small landfills are never 

incrementally affected by the proposal. Descriptive statistics for the two impacted landfills are 

shown in Table 4-1. One landfill has impacts of up to 12 percent (as described above), but 

impacts of this magnitude only occur in two years of the 30 years. In general, average impacts 

over the 30-year timeframe are approximately 1 percent or less and maximum impacts are less 

than 3 percent. In some years, incremental impacts are negative, indicating that the proposed 

provisions are less costly than the baseline NSPS. 

 

5

 The SBREFA compliance guidance to EPA rulewriters regarding the types of small business analysis that should 

be considered can be found at <http://www.epa.gov/sbrefa/documents/rfaguidance11-00-06.pdf> 6

U.S. SBA, Office of Advocacy. A Guide for Government Agencies, How to Comply with the Regulatory 

Flexibility Act, Implementing the President’s Small Business Agenda and Executive Order 13272, June 2010. 
4-4 

Table 4-1. Descriptive Statistics for Impacts to Small Entities, 2014-2043 

 2014-2023 2024-2033 2034-2043 

Future Landfill 

9 

Average - 0.9% -0.01% 

Minimum - - -0.01% 

Maximum - 2.3% -0.01% 

Future Landfill 

19 

Average 1.2% 0.8% 0.0% 

Minimum - -3.2% -2.7% 

Maximum 11.9% 11.9% 2.8% 

The impacts presented in Table 4-1 do not include testing and monitoring costs because 

this information is only available for 2023. Because these are low relative to the other costs of 

the rule, we do not expect this would impact the overall conclusions of the analysis. 

Additionally, impacts are calculated for all years using a single year of revenue for the model 

landfill. The actual impacts will be affected by future changes in revenue. 

Based upon this analysis, we conclude there will not be SISNOSE arising from this 

proposal. First, these proposed revisions do not impact a substantial number of small entities. 

Only two small entities are potentially impacted, which does not constitute a substantial number. 

Additionally, the impacts to these small entities are not significant. Only one of the two landfills 

has impacts greater than 3 percent of sales in two of the 30 years examined. The costs incurred 

by small entities are the result of having to install controls earlier than would have been the case 

under the existing NSPS. (These costs would have been incurred in later years under the existing 

NSPS.) There will continue be a lag between the opening of the landfill and the implementation 

of controls during which the site will be generating revenue through tipping fees. This analysis 

only considers control costs and revenues associated with the collection of landfill gas and does 

not estimate the future collection of tipping fees which will be set at a level adequate to plan for 

known, future requirements. 

Given the trend toward larger landfills owned by large entities, it is likely that there will 

be fewer small landfills in the future than in data from the past five years. Additionally, while we 

assume that the new landfills will be financially and operationally similar to recently opened 

landfills, numerous factors could influence the actual size, location, and revenue of landfills that 

open in the future. The model landfills are based on landfills currently in operation that will not 

be subject to the proposed revisions. All small landfills that will be subject to these proposed 
4-5 

revisions will make decisions about their development and operations with full knowledge of the 

requirements proposed. 

Although not required by the RFA to convene a Small Business Advocacy Review 

(SBAR) Panel because the EPA has now determined that this proposal would not have a 

significant economic impact on a substantial number of small entities, EPA had originally 

convened a panel to obtain advice and recommendations from small entity representatives 

potentially subject to this rule’s requirements. The panel was not formally concluded; however a 

summary of the outreach conducted and the written comments submitted by the small entity 

representatives that the SBAR Panel consulted can be found in the docket for this rulemaking.7

Although this proposed rule will not have a significant economic impact on a substantial number 

of small entities, the EPA nonetheless has tried to reduce the impact of this rule on small entities. 

 

7

 See Docketed memorandum: Small Entity Outreach. 2014.