Barron County Waste-to-Energy 

and Recycling Facility 

(Almena, Wisconsin) 

Bristol Resource Recovery Facility 

Operating Committee 

(Bristol, Connecticut) 

Ecomaine (portland, Maine) 

City of Harrisburg, Pennsylvania 

City and County of Honolulu, 

Hawaii 

City of Huntsville Solid Waste 

Disposal Authority 

(Huntsville, Alabama) 

County Sanitation Districts of 

Los Angeles County 

(Whittier, California) 

Kent County, Michigan 

Lancaster County Solid 

Waste Management Authority 

(Lancaster, Pennsylvania) 

Marion County, Oregon 

Mid-Maine Waste Action Corp. 

(Auburn, Maine) 

Northeast Maryland Waste 

Disposal Authority 

(Baltimore, Maryland) 

Pollution Control Financing 

Authority of Camden County 

(Camden, New Jersey) 

Spokane Regional Solid Waste 

System (Spokane, Washington) 

Wasatch Integrated Waste 

Management District 

(Layton, Utah) 

York County Solid Waste Authority 

(York, Pennsylvania) 

* In coordination with the 

u.s. Conference of Mayors! 

Municipal Waste 

Management Association 

LOCAL GOVERNMENT COALITION FOR 

RENEWABLE ENERGY 

Robert Vollaro 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

October 8, 2010 

Re: Proposed Amendments to Regulations for Mandatory 

Reporting of Greenhouse Gas Emissions 

Dear Bob: 

This is a follow-up to our telephone conversation earlier this week 

regarding EPA's recent proposal to amend the agency's GHG emissions 

reporting rule, Mandatory Reporting of Greenhouse Gases, Proposed Rule, 

75 Fed. Reg. 48744 (August 11, 2010). As you know, on September 27 

the Coalition (i.e., the Local Government Coalition for Renewable 

Energy) submitted comments regarding the proposed amendments, 

focusing on the new definition of "municipal solid waste" (MSW) EPA 

had proposed. In response to those comments, you called to ask if the 

Coalition could provide alternative language to address our concerns with 

the definition of MSW, and our suggested alternative is attached. As you 

will see, for the most part we rely on the new definition as prcposed by the 

agency, and our revisions are shown using Track Changes. I believe you 

will find our suggested alternative self-explanatory, but please do not 

hesitate to call me (at 256-880-6054) with any questions. 

cc: Coalition Members 

Coalition Counsel 

DC_DOCS:698137.1 

John R. ("Doc") Holladay 

I 
Municipal solid waste or MSW means solid phase household, commerciallretail, and/or 

institutional waste. Household waste includes material discarded by single and multiple 

residential dwellings, hotels, motels, and other similar permanent or temporary housing 

establishments or facilities. CommerciaVretail waste includes material discarded by stores, 

offices, restaurants, warehouses, non-manufacturing activities at industrial facilities, and other 

similar establishments or facilities. Institutional waste includes material discarded by schools, 

nonmedical waste discarded by hospitals, material discarded by non-manufacturing activities at 

prisons and government facilities, and material discarded by other similar establishments or 

facilities. Household, commercial/retail, and institutional wastes include yard waste, refusederived fuel, and motor vehicle maintenance materials. Insofar as there is separate collection, 

processing and disposal of industrial source waste streams consisting ot used oil, wood pallets, 

construction, renovation, and demolition wastes (which includes, but is not limited to, railroad 

ties and telephone poles), clean wood, industrial process or manufacturing wastes, medical 

waste, .,motor yehicle parts or vehicle fluff, or used tires that do not contain hazardous waste 

identified or listed under 42 U.S.C. § 6921, such wastes are not municipal solid waste, except 

that such wastes qualify as municipal solid waste where they are collected with other municipal 

solid waste or are otherwise combined with other municipal solid waste for processing and/or 

disposal,., 

DC_DOCS:698135.1 

Deleted: Household, commerciaVretail, 

and institutional waste does not include 

Deleted: or 

Deleted: vehicles (including motor 

Deleted: ) 

Deleted: Household, 

commerciaVretail, and institutional 

wastes include yard waste, refuse-derived 

fuel, and motor vehicle maintenance 

materials, limited to vehicle batteries and 

tires, except where a single waste stream 

consisting of tires is combusted in a unit