1

1 ENVIRONMENTAL PROTECTION AGENCY

2

3

4

5

6

7 40 CFR PART 60

8 PUBLIC HEARING: STANDARDS FOR PERFORMANCE FOR 

9 MUNICIPAL SOLID WASTE LANDFILLS

10

11

12 9:05 a.m. to 5:57 p.m.

13 Tuesday, August 12, 2014

14

15 William Jefferson Clinton East Building

16 1201 Constitution Avenue NW

17 Room 1153

18 Washington, DC 20004

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20

21

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1 EPA Panel Members:

2 David Cozzie, Senior Program Advisor

3 Hillary Ward,

4 Environmental Protection Specialist

5 Shaun Ragnauth (morning session), Economist

6 Swarupa Ganguli (afternoon session),

7 Environmental Protection Specialist

8

9 WITNESSES: PAGE

10 John Skinner 7

11 Karimah Schoenhut 14

12 Anne Germain 22

13

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15

16

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20

21

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1 P R O C E E D I N G S

2 MR. COZZIE: Good morning, my name is 

3 David Cozzie, and I am the chair of today's 

4 public hearing. Thank you for coming today. 

5 Joining me on the panel are Ms. Hillary Ward from 

6 EPA's Office of Air and Radiation, and Mr. Shaun 

7 Ragnauth also from EPA's Office of Air and 

8 Radiation. We are here today to listen to your 

9 comments on EPA's proposed updates to its new 

10 source performance standards for municipal solid 

11 waste landfills. 

12 EPA announced the proposed updates, which 

13 would reduce emissions of methane-rich landfill 

14 gas from landfills constructed, modified, or 

15 reconstructed in the future, on June 30, 2014. 

16 The proposed updates would require new MSW 

17 landfills subject to the rule to begin 

18 controlling landfill gas emissions at a lower 

19 threshold than currently is required for new 

20 landfills. Under the proposal, landfills would 

21 capture two-thirds of their methane and air

22 toxics emissions by 2023. Thirteen percent more 

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1 than they must capture under current regulations. 

2 Methane and air toxics are linked to a number of 

3 harmful pollutant effects on public health and 

4 climate. 

5 The updates would apply to MSW landfills 

6 that begin construction modification or 

7 reconstruction on or after July 17th, 2014, the 

8 day which this proposal was published in the 

9 Federal Register. They would not apply to 

10 landfills subject to the current NSPS, which was 

11 issued in 1996. If you would like more details 

12 on the proposed updates, there is a fact sheet 

13 available near the registration desk. 

14 Before we get started, I would like to go 

15 through a few housekeeping items and ground rules 

16 that will help make today’s hearing runs 

17 smoothly. First, please be sure that you’ve 

18 checked in at the registration desk. Even if you 

19 are not planning speak today. And if you signed 

20 to speak online or by phone but haven’t told us 

21 that you are here, please step out to the 

22 registration desk and let the EPA staff know that 

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1 you have arrived. 

2 I will call speakers up individually. 

3 When your name is called, please come to the 

4 podium at the front of the room. When I call on 

5 you to speak, please state your name and spell it 

6 for the court reporter. Your comments will be 

7 transcribed and included in the record of 

8 comments on the proposed rule. Each speaker will 

9 have five minutes to give comments. We have a 

10 light to let you know how much time you have left 

11 to speak. When the light turns from green to 

12 yellow, that means you have one minute remaining. 

13 When it turns red, that’s a signal that you are 

14 at five minutes and it’s time to stop. When you 

15 are finished speaking, pleas return to your seat.

16 We are here to listen to you today, 

17 however, a panel member may ask you questions to 

18 clarify your comments. I will then call up the 

19 next speaker and so on. If you have brought a 

20 copy -- a written copy of your testimony, please 

21 give that to staff at the registration desk 

22 before you leave today. If you have additional 

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1 comments that you would like to make, you can 

2 submit them in writing. Let me assure you that 

3 EPA gives just as much consideration to comments 

4 we receive in writing as we do comments we 

5 receive at public hearings like this one. So, if 

6 you have more that you would like to say, please 

7 submit it. Your comments will be reviewed. And 

8 there is still time to get written comments in. 

9 Comments must be received by September 15th, 

10 2014.

11 We will put any written comments 

12 submitted today in the official docket for the 

13 proposed rule. Instructions for submitting your 

14 comments in other ways are in the fact sheet, 

15 which is available at the material near the 

16 registration desk. 

17 If you have any questions during the day, 

18 please see the staff at the registration desk, 

19 and someone will try to help you. Thank you 

20 again for taking the time today to share your 

21 comments on EPA’s proposal, and at this time we 

22 can get started. 

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1 And the first speaker I will call is Mr. John 

2 Skinner. 

3 MR. SKINNER: Good morning. I have a 

4 written statement, would you like copies? I’m 

5 not going to read it, but I will paraphrase it.

6 MR. COZZIE: Yeah, if you have a written 

7 comment, if you would please leave it at the 

8 registration desk, that would be fantastic.

9 MR. SKINNER: Do you want one now?

10 MR. COZZIE: No. We will collect it at 

11 the registration desk.

12 MR. SKINNER: Okay, fine, thank you. 

13 Shall I start?

14 MR. COZZIE: You can go right ahead.

15 MR. SKINNER: Thank you, good morning, my 

16 name is John Skinner. I am the executive 

17 director and CEO of SWANA, the Solid Waste 

18 Association of North America. We are not a trade 

19 association, we are a professional and an 

20 education association with 8,300 members in North 

21 America, the United States and Canada, and our 

22 members work both for the private sector and for 

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1 the public sector. About 60 percent work for the 

2 public sector and the remainder work for the 

3 private sector and they are active in landfilling 

4 across North America. We provide education and 

5 training for our members. 

6 The standards that you have put out and 

7 proposed is of very significant interest to all 

8 of our members, many of them who have been 

9 operating under the prior subpart WWW for many, 

10 many years. We noticed in the preamble that 

11 there are many, many questions that you ask, if 

12 you count them all, there are probably over 80, 

13 maybe even more if you look at the subparts of 

14 the questions, and there’s also many documents 

15 that you reference in the preamble. We believe 

16 that 60 days public comment is not sufficient to 

17 review all that material and to comment during 

18 the comment period. Adding the fact that you 

19 also put out an advanced notice for emission 

20 guidelines that has a similar number of questions 

21 and documents putting them both together in a 60 

22 day public comment period is just not feasible. 

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1 So we have requested formally, an extension of 

2 the comment period of both for an additional 60 

3 days. 

4 The landfills that have been operating 

5 under the existing subpart WWW have shown 

6 remarkable progress in reducing greenhouse gases. 

7 As EPA indicates, the amount of methane reduced 

8 from 1990 to 2012 has been over 30 percent by 

9 those standards, and that’s at a time when waste 

10 generation and waste disposed of in landfills 

11 increased by 26 percent so that’s also very, very 

12 significant -- a very effective regulation which 

13 the solid waste industry has complied with and 

14 achieved very, very considerably.

15 A couple of specific comments on key 

16 provisions, and we will submit in detail, by the 

17 end of the comment period, a lot more comments 

18 and more details on this. The reduction of the 

19 emissions threshold from 50 milligrams to 40 

20 milligrams of NMOC is not unreasonable of a 

21 standard for new facilities. Our concern is when 

22 existing facilities modify their permit and 

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1 increase their capacity, they would be subject to

2 these new standards as well, and we are -- our 

3 question is, all of these facilities are 

4 currently operating under the WWW, would they 

5 then have to operate under the new provisions of 

6 subpart XXX, and that -- if so, if that is the 

7 answer, the scope of this regulation is far 

8 greater than the proposal indicates. The 

9 proposal discusses the impact of new facilities, 

10 the impact on existing facilities could be very, 

11 very significant in terms of number of facilities 

12 and also very significant with respect to what

13 those facilities have to achieve. So we would 

14 like clarification on that. 

15 A second issue that’s important to us is 

16 the proposed rule on startup, shutdown, and 

17 malfunction, where the standard would apply 

18 during that period. We feel that is an 

19 infeasible standard to comply with. Any thermal 

20 device has to come up to temperature before it is 

21 effective. Any mechanical or thermal device will 

22 have a malfunction, and to require that the 

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1 standard be met during that period of time, is 

2 just very unreasonable. Every facility will be 

3 out of compliance when they start up their 

4 thermal combustion device. And we think the 

5 existing rule under WWW, which allowed for some 

6 period of time to come into compliance, both 

7 during the startup and shutdown, and also during 

8 the malfunction, is much more reasonable and we 

9 suggest that you please revisit that. 

10 We support the language that clarifies 

11 that the use of treated landfill gas is not 

12 limited to fuel for stationary combustion devices 

13 but also includes vehicle fuels and high BTU 

14 pipeline injection. We don’t believe it is 

15 necessary to set treatment standards for those 

16 gasses that are going to be treated. We think 

17 you should just simply refer to the 

18 manufacturer’s standards for those devices. This 

19 would have no impact on emission rates, it would 

20 simply –- those standards are there to protect 

21 the equipment, and rather than being prescriptive 

22 about that in the standard, we feel that it is 

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1 inappropriate.

2 Finally, we also are concerned about a 

3 clear path from exiting the regulatory 

4 requirements, once a site no longer exceeds the 

5 NMOC threshold. 

6 We will submit comments on all these 

7 points during the public comment period. Thank 

8 you.

9 MR. COZZIE: Thank you Mr. Skinner. 

10 Panel, do you have any questions?

11 MS. WARD: Not at this time. Thank you.

12 MR. COZZIE: And I just have one 

13 question. 

14 When you’ve referred to the modification 

15 of the permit, were you talking about permits 

16 that were modified prior to this date, or several 

17 of the -- modified subsequent --

18 MR. SKINNER: After the date. Landfills 

19 go through permit modification all of the time, 

20 and many times those modifications increase the 

21 design capacity of the facility. In some cases, 

22 this -- it is built into the permit review 

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1 process. Our reading is, that would 

2 automatically subject those facilities to the new 

3 standards in subpart triple X, where many of 

4 those facilities are operating at triple W at 

5 this point in time. But I am talking about 

6 subsequent increases in permitting.

7 MR. COZZIE: Okay. In relation to the 

8 startup shutdown malfunction, you mentioned -- in 

9 your comments, will you submit some information 

10 or data talking about the startup time it takes 

11 to come up to temperature. Will that be included 

12 as well?

13 MR. SKINNER: Yes, and we think the 

14 current standard in WWW is appropriate. One day 

15 five -- one hour five days is the type of de 

16 minimis period for both startup shutdown and 

17 modification, which would be something that we’ve 

18 complied with all of this time and would be able 

19 to comply with in the future. But a zero 

20 tolerance during that period of time is just not 

21 practical.

22 MR. COZZIE: Thank you very much.

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1 MR. SKINNER: Okay.

2 MR. COZZIE: At this point in time, I 

3 would like to call forward Karimah Schoenhut.

4 MS. SCHOENHUT: Good morning, my name is 

5 Karimah Schoenhut. I’m a legal fellow with the 

6 climate and air regulatory and policy program at 

7 the Environmental Defense Fund. 

8 EDF is a nonprofit, nonpartisan 

9 organization that combines law, policy, science, 

10 and economics to find solutions to today’s most 

11 pressing threats to public health and the 

12 environment. On behalf of EDF and its over 

13 750,000 members nationwide, I urge EPA to 

14 strengthen the proposed new source performance 

15 standards for municipal solid waste landfills, 

16 and to adopt stronger protections for emissions 

17 from existing landfills. 

18 EPA’s current proposal fails to secure 

19 vital and highly cost-effective emission 

20 reductions for methane, a potent accelerant of 

21 climate destabilization, and does not adequately 

22 account for the most recent science thoroughly 

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1 documenting the dangerous force of this climate 

2 change accelerant. 

3 Landfills are the nation’s third largest 

4 anthropogenic source of methane, which is 

5 generated along with air toxics and ozone forming 

6 pollutants as the waste deposited in landfills 

7 decomposes. 

8 Methane is a powerful climate pollutant 

9 that is 84 to 86 times more potent than carbon 

10 dioxide within the first two decades after it is 

11 emitted, and 28 to 34 times more potent even a 

12 century after its emission. Studies show that 

13 reducing methane now from major source sectors, 

14 such as oil and gas development and municipal 

15 landfills, while simultaneously making deep cuts 

16 in carbon pollution from other major sources like 

17 power plants, is crucial for slowing the rate of 

18 near-term climate change and securing long-term 

19 climate stability.

20 This proposed rule is an important part 

21 of the White House strategy to reduce methane 

22 emissions, and is also required by the Clean Air 

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1 Act, which directs EPA to review, and if 

2 appropriate, revise the NSPS for each category at 

3 least once every eight years. EPA’s current NSPS 

4 for landfills has not been updated since 1996 and 

5 no longer reflects the full range of technologies 

6 to reduce emissions from landfills. 

7 Just in the last two years, for example, 

8 the state of California extensively analyzed the 

9 latest technologies and practices for reducing 

10 landfill emissions. California adopted well11 designed modern standards that protect human 

12 health and the environment beyond the NSPS by 

13 covering a large number of landfills, ensuring 

14 rapid installation and expansion of emission 

15 controls, and requiring rigorous monitoring to 

16 ensure landfills prevent leaks of methane and 

17 other harmful pollutants to the atmosphere.

18 EPA action to modernize standards for both new 

19 and existing landfills is urgently needed and 

20 long overdue. The proposed rule does represent 

21 some limited progress. The proposed NSPS would 

22 modestly reduce the emission threshold that 

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1 ensure landfills install basic emission controls, 

2 and it would require monitoring of certain 

3 landfill features where leaks frequently occur. 

4 EPA estimates these measures would reduce 

5 emissions from new landfills by approximately 13 

6 percent in 2023, the equivalent to just over 

7 300,000 metric tons of carbon dioxide using EPA’s 

8 current global warming potential for methane, and 

9 at a very low cost, just a dollar fifty for every 

10 ton of CO2 equivalent emissions reduced.

11 Nevertheless, the proposed rule misses 

12 opportunities to set standards that truly reflect 

13 state-of-the-art technologies and best practices 

14 in this industry, as section 111 of the Clean Air 

15 Act requires. For example, EPA proposes to 

16 continue allowing landfills up to five years to 

17 install a gas collection system, even though 

18 leading researchers have concluded that almost 30 

19 percent of total emissions from a landfill are 

20 emitted within this timeframe. EPA’s own 

21 analysis shows that earlier gas collection would 

22 yield significant additional reductions of almost 

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1 1,000,000 metric tons of CO2 equivalent in 2023.

2 In addition, the proposed rule does not 

3 require rigorous monitoring to ensure that 

4 landfills are properly maintained and operated. 

5 The current NSPS requires only a small portion of 

6 the landfill surface to be monitored each 

7 quarter, potentially allowing many leaks to go 

8 undetected and unrepaired. California requires 

9 approximately four times as much monitoring as 

10 the current NSPS and provides for a rigorous 

11 average limit on methane emissions in addition to 

12 a limit on individual detection readings. We 

13 urge EPA to strengthen NSPS in these and other 

14 respects. 

15 In parallel, EPA must also take prompt 

16 action to reduce emissions from existing 

17 landfills. Existing landfills will emit far more 

18 methane and other harmful pollutants than new 

19 landfills for the foreseeable future, and present 

20 opportunities for significant and cost-effective 

21 reductions in emissions. EPA’s analysis 

22 indicates that reduced applicability threshold 

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1 and early gas collection at existing landfills 

2 could avoid approximately 770,000 metric tons of 

3 methane emissions a year at a cost of only four 

4 twenty -- four dollars 20 per ton of CO2

5 emissions. Using the IPCC’s more accurate 20-

6 year value for methane global warming potential, 

7 these reductions are equivalent to approximately 

8 65,000,000 metric tons of CO2 each year.

9 Strong standards for existing landfills would 

10 leverage the innovative technologies and 

11 practices that many communities and landfill 

12 operators around the country have implemented 

13 already to reduce emissions including, recycling 

14 and composting, responsible use of landfill gas 

15 for energy and advance cover systems.

16 Thank you for this opportunity to share 

17 our thinking on these issues. We look forward to 

18 providing more detailed submissions before the 

19 end of the public comment period.

20 MR. COZZIE: Thank you, Ms. Schoenhut. 

21 Panel members, any questions?

22 MS. WARD: I had a couple questions. 

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1 You mentioned that in the proposal, rigorous 

2 monitoring was not required and you referenced 

3 the California approach. Have you explored 

4 anything beyond that, or were you specifically 

5 advocating for the adoption of the California 

6 approach?

7 MS. SHOENHUT: I think that EDF would 

8 like to consider – would like EPA to consider the 

9 California approach as an example, as perhaps the 

10 best example of rigorous monitoring, but we will 

11 provide more detailed comments on that in our 

12 written comments.

13 MS. WARD: And the same as a follow-up 

14 question toward expansion, you mentioned the five 

15 year timeline that’s allotted for expansion of 

16 the well system and how that does not, in your 

17 opinion, necessarily accurately account for gas 

18 that comes off the landfill. 

19 Were you advocating for a tightening of 

20 that time, or a removal of that time, or were you 

21 thinking to explore that more in your comments? 

22 I just wanted to get a little clarification 

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1 there.

2 MS. SCHOENHUT: For a tightening of that 

3 time period. And that will be addressed -- the 

4 extent of the tightening will be addressed in the 

5 written comments.

6 MR. RAGNAUTH: No comments.

7 MS. SCHOENHUT: Thank you.

8 MR. COZZIE: Thank you very much. 

9 Well I believe that’s the extent of our speakers 

10 that have signed up, to this point. So, given 

11 that, I will put the hearing into recess until 

12 any other speakers show up. 

13 Thank you.

14 [WHEREUPON, A RECESS WAS TAKEN AT 9:24 

15 AM. THE HEARING RECOMMENCED AT 10:30 AM]

16 MR. COZZIE: Good morning, the time now 

17 is 10:30 am and I am reconvening the panel on the 

18 public hearing on proposed updates on new source 

19 performance standards for solid waste landfills. 

20 At this time I will call forward Anne Germain. 

21 MS. GERMAIN: So, just go ahead?

22 MR. COZZIE: Go right ahead.

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1 MS. GERMAIN: Okay. Good morning, I am 

2 Anne Germain, director of waste and recycling 

3 technology, for the National Waste and Recycling 

4 Association. Thank you for the opportunity to 

5 testify on the agency’s proposed rule for 

6 standards of performance from municipal solid 

7 waste landfills. The National Waste and 

8 Recycling Association, formerly the National 

9 Solid Waste Association, is a not-for-profit 

10 trade association representing private solid 

11 waste and recycling collection processing and 

12 management companies. Our members own and 

13 operate the majority of the landfills in the 

14 Unites States. 

15 When these rules were first promulgated 

16 in 1996, our members responded by investing 

17 significant capital and human resources in 

18 installing, expanding and improving their 

19 landfill gas collection and control systems, as 

20 well as their landfill cover systems. These 

21 efforts have resulted in significantly reduced 

22 emissions. 

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1 As highlighted in EPA’s Inventory of U.S. 

2 Greenhouse Gas Emissions and Sinks, between 1990 

3 and 2012, landfills have reduced methane 

4 emissions by more than 30 percent. The 1996 NSPS 

5 emission guidelines have been very successful in 

6 prompting development by the landfill sector of 

7 highly effective methane controls. As the EPA 

8 moves into new amendments to these regulations, 

9 it is important that proposals build on successes 

10 that the industry has worked so hard to achieve 

11 over the past 18 years.

12 We believe that the EPA should streamline 

13 the standards to eliminate the historical 

14 bureaucracy that has hampered effective 

15 implementation of methane controls, and avoid 

16 establishing new provisions that are neither 

17 cost-effective, nor achieve new methane 

18 reductions. EPA should recognize that many 

19 landfills are partially or fully closed and these 

20 sites need flexibility to adjust their control 

21 systems to compensate from diminished methane 

22 generation and appropriately exit the regulatory 

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1 regime. The current regulations do not 

2 effectively provide that needed flexibility.

3 In our initial review of the prosed rule and 

4 accompanying technical analyses, we noted that 

5 the agency was hard-pressed to identify 

6 additional means to obtain further cost-effective 

7 methane reductions. While the intent of this 

8 rulemaking is to further reduce emissions, our 

9 members are concerned that many of the proposed 

10 measures will do little to achieve that goal. 

11 The proposed revisions make it more difficult for 

12 landfills to optimize the performance of their 

13 landfill gas collection and control systems by 

14 perpetuating prescriptive standards that require 

15 them to make system adjustments that often hamper 

16 emissions controls. Rather than reducing 

17 needless bureaucracy, these provisions actually 

18 increase paperwork and administrative burdens for 

19 both the landfill sector and our state 

20 regulators, with no attendant environmental 

21 benefits.

22 The U.S. landfill sector has successfully 

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1 pioneered the use of landfill gas to produce 

2 renewable electricity and facility and 

3 transportation fuels. There are over 600 

4 renewable energy projects in the United States in 

5 part, through the cooperative efforts of landfill 

6 owners and operators as well as EPA’s Landfill 

7 Methane Outreach Program. However, EPA is 

8 proposing new landfill gas treatment requirements 

9 that are superfluous to the operation of these 

10 beneficial projects, resulting in zero emissions 

11 reductions and significantly increasing project 

12 costs. We are very concerned that the proposed 

13 provisions will discourage the development of new 

14 renewable energy projects and may force existing 

15 projects to shut down.

16 The industry is beginning a detailed 

17 review of the rule and supporting documents. In 

18 addition to publication of the proposed NSPS, the 

19 solid waste industry must also respond to the 

20 advanced notice of proposed rulemaking for 

21 Emission Guidelines and Compliance Times for 

22 Municipal Solid Waste Landfills that was issued 

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1 that same day. Both proposals entail review of 

2 hundreds of pages of technical documents and 

3 preparation of information and comments to 

4 numerous Agency questions that will require 

5 extensive time and resources, particularly within 

6 that same 60-day period. As such, we have 

7 requested a 60-day extension be provided to 

8 commenters on the proposed NSPS so that the EPA 

9 will benefit from a thoroughly researched 

10 response.

11 In closing, the National Waste and 

12 Recycling Association appreciates your 

13 consideration of our testimony today and 

14 forthcoming recommendations on these standards of 

15 performance. Should you have any questions about 

16 these comments, please feel free to reach me at 

17 (202) 364-3724, or at amgermain -- sorry, at 

18 agermain@wasterecyling.org. 

19 On behalf of the solid waste recycling 

20 industry, thank you for your thoughtful 

21 consideration of these comments.

22 MR. COZZIE: Thank you, Ms. Germain. 

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1 Panel, any questions?

2 MR. RAGNAUTH: I have no questions.

3 MS. WARD: Hi, Anne. 

4 MS. GERMAIN: Hello.

5 MS. WARD: Do you know if you guys will 

6 be planning to, in your detailed comments, to 

7 provide more information about your thoughts 

8 concerning streamlining? 

9 I know mentioned that in you testimony.

10 MS. GERMAIN: Yeah, I expect that we are 

11 going to be providing a lot of ideas and 

12 suggestions on what things we are hoping to see 

13 reductions in. In particular, they are probably 

14 going to be related to wellhead controls, because 

15 that’s where a lot of the really prescriptive 

16 standards come in, and that’s a lot of the areas 

17 where we think there’s opportunities, but there’s 

18 probably going to be significantly more than just 

19 that. 

20 MS. WARD: And I’m assuming the same 

21 thing for closed areas, or those of declining gas 

22 flows, you will have more detailed comments?

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1 MS. GERMAIN: To try and reduce -- yes, 

2 and that’s probably the reason we have to still 

3 develop some of those responses, and that’s 

4 probably the reason why we kind of need an 

5 extension to the 60 days, because to try and 

6 assemble all of that information and provide 

7 alternative suggestions to the EPA, we need a 

8 little more time.

9 MS. WARD: Thank you.

10 MR. RAGNAUTH: Nothing.

11 MR. COZZIE: Thank you. Hillary hit on a 

12 couple of my questions as well about the 

13 streamline and the flexibility. You mentioned 

14 providing more flexibility and I guess my 

15 question is the same, will you provide more 

16 detail in a -- in your subsequent comments? 

17 MS. GERMAIN: Yes. We have an industry 

18 group that we have assembled to try and provide 

19 as much detail as possible, that we think will be 

20 representative of the entire industry, that we 

21 think are rules that will -- adjustments that 

22 could be made that are going to either not reduce 

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1 any -- or not increase any emissions or, perhaps, 

2 even have a positive effect on emissions, but at 

3 the same time, give the industry the ability to 

4 have a lot more flexibility in the way they 

5 operate their systems.

6 Part of the problem is, sometimes there’s 

7 no real ability to document any reductions in 

8 emissions. It’s kind of more anecdotal, and so 

9 there’s no documentable information, but we can 

10 certainly demonstrate that it doesn’t increase. 

11 MR. COZZIE: All right, thank you. Thank 

12 you for your testimony, and will you be leaving a 

13 copy of that with registration? 

14 MS. GERMAIN: It’s kind of waterlogged 

15 but I would be happy to leave it.

16 MR. COZZIE: Fine. It reads the same. 

17 Thank you very much. 

18 [CONVERSATION HELD OFF THE RECORD]

19 MR. COZZIE: It is now 10:38 and with no 

20 other speakers signed up, I am putting the panel 

21 in recess.

22 [WHEREUPON, A RECESS WAS TAKEN AT 10:38 

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1 AM. THE HEARING RECOMMENCED AT 11:45 AM]

2 MR. COZZIE: The time now is 11:45, I 

3 will reconvene the panel. There are no speakers 

4 at this point. We will recess the panel until one 

5 o’clock this afternoon. 

6 [WHEREUPON, THE LUNCH BREAK WAS TAKEN AT 

7 11:45 AM. THE HEARING RECONVENED AT 1:09 PM]

8 MR. COZZIE: Good afternoon and welcome 

9 to the public hearing on proposed updates to the 

10 new source performance standards for new solid 

11 waste landfills. We are reopening the panel at 

12 this point. I would like to recognize --

13 acknowledge that Ms. Swarupa Ganguli has replaced 

14 Mr. Shaun Ragnauth on the panel. 

15 At this time we have no speakers. We 

16 will stay open and see if any speakers arrive. 

17 [WHEREUPON A RECESS WAS HELD AT 1:10 PM. 

18 THE HEARING RECOMMENCED AT 1:31 PM]

19 MR. COZZIE: As we have no speakers at 

20 the moment, we will recess until any speakers 

21 sign up at the registration desk. 

22 Thank you.

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1 [WHEREUPON, A RECESS WAS TAKEN AT 1:31 

2 PM. THE HEARING RECOMMENCED AT 5:57 PM]

3 MR. COZZIE: Good evening. Welcome to 

4 the public hearing on municipal solid waste 

5 landfills. The time now is 5:57. At this time I 

6 am reopening the meeting. There are no speakers 

7 signed up and we will officially close the 

8 meeting now.

9 Thank you and have a great evening.

10 [WHEREUPON, THE HEARING CONCLUDED AT 5:57 

11 PM]

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