1

From: Grossman, Andrea <Andrea_L_Grossman@omb.eop.gov>

Sent: Monday, July 13, 2015 10:44 AM

To: Ward, Hillary

Subject: Re: Summary of Interagency Comments under EO 12866 and 13563 for EPA's MSW Landfill 

Rules (RINs 2060-AM08 and 2060-AS23)

Hillary, 

I think it's safe to assume at this point that nothing more will be coming, so the package I sent over is complete. 

Thanks for checking, 

Andrea

 

From: Ward, Hillary [mailto:Ward.Hillary@epa.gov] 

Sent: Monday, July 13, 2015 10:23 AM 

To: Grossman, Andrea 

Subject: RE: Summary of Interagency Comments under EO 12866 and 13563 for EPA's MSW Landfill Rules (RINs 2060-

AM08 and 2060-AS23) 

 

Morning Andrea, 

Karen T. is out today. Just wanted to check in to see if we should expect any additional interagency comments on both 

packages. 

Regards, 

Hillary Ward 

US EPA, Sector Policies and Programs Division 

Fuels and Incineration Group 

(919)541-3154 

 

From: Grossman, Andrea 

Sent: Thursday, July 09, 2015 05:33 PM 

To: Thundiyil, Karen <Thundiyil.Karen@epa.gov> 

Cc: Szabo, Aaron; Laity, Jim 

Subject: Summary of Interagency Comments under EO 12866 and 13563 for EPA's MSW Landfill Rules (RINs 2060-AM08 

and 2060-AS23) 
2

Attached please find a summary of interagency comments under EOs 12866 and 13563 on the EPA supplemental 

proposal and proposed rule, titles “Standards of Performance for Municipal Solid Waste Landfills” and “Emissions 

Guidelines and Compliance Times for Municipal Solid Waste Landfills”, as well as the accompanying RIA covering both. 

These compiled comments are being sent at this point in light of ongoing discussions about this rule’s schedule. 

Additional interagency comments will be sent as they become available. 

Please let me know if you have any questions. 

Andrea Grossman 

Office of Information and Regulatory Affairs 

202-395-4756 
1

From: Thundiyil, Karen <Thundiyil.Karen@epa.gov>

Sent: Friday, July 17, 2015 11:44 AM

To: Grossman, Andrea

Cc: Ward, Hillary; Marsh, Karen; Cozzie, David

Subject: Landfills - response to interagency comments

Attachments: EO 12866 Landfills EG 2060 AS23 NPRM 20150717.docx; DRAFT Screening Analysis EG 

NSPS Proposals 042915.xlsx; DRAFT Landfills EG Cost and Emission Impacts 

071815.docx; Summary of Interagency Comments Under EO12866 13563 20150718.docx

Hi Andrea, 

Attached you’ll find EPA’s responses to the general comments, technical comments and typographical comments 

provided last week. This email also provides the draft small business screening analysis, the draft EG Impacts memo, and 

the revised EG preamble that reflects interagency comments. 

At the beginning of next week, we’ll provide the RIA comments and a revised RIA. 

Please let us know if you have any questions. 

Karen. 
1

From: Thundiyil, Karen <Thundiyil.Karen@epa.gov>

Sent: Monday, July 20, 2015 2:13 PM

To: Grossman, Andrea

Cc: Ward, Hillary; Cozzie, David; Marsh, Karen

Subject: Landfills - response to remaining interagency comments

Attachments: Summary of Interagency Comments Under EO12866 13563 20150720.docx; Copy of EG 

Cost and Emission Impacts Appendix B 20150720.xlsx; EO12866_LandfillsEG 2060 AS23 

RIA 20150720.docx

Hi Andrea, 

Attached you’ll find full response to the interagency comments, including the RIA comments. You’ll also find the revised RIA with 

tracked changes and the EG Costs and Emissions Impacts Appendix B. 

Please let us know if you have questions, otherwise, I’ll check in with you later this week. 

Thanks, 

Karen. 
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

ENVIRONMENTAL PROTECTION AGENCY (EPA): Proposed Rule and Supplemental 

Proposal 

Standards of Performance for Municipal Solid Waste Landfills and Emission Guidelines 

and Compliance Times for Municipal Solid Waste Landfills and Accompanying RIA 

RINs 2060-AM08 and 2060-AS23 

General Comments 

1) Reviewer recommends that EPA provide estimates of costs and benefits for additional 

years. Given the nature of this rule, presenting only 2025 is likely to miss a significant 

portion of GCCS costs shifted forward, and doesn’t give a complete picture of the 

increase in costs due to extending GCCS maintenance. Reviewer recommends presenting 

2020, 2030, and 2040 as well to show how costs and benefits of the rule will evolve as 

existing landfills move to end of useful life. 

2) Reviewer recommends clarifying in the rules why both standards are written in terms of 

non-methane organic compounds (NMOCs), however it aims to regulate both NMOCs 

and methane. Most of the language focuses on controlling for NMOCs but most of the 

benefits come from controlling methane. Reviewer recommends explaining in both rules 

why an NMOC standard regulating NMOCs is also an appropriate proxy for methane and 

how controlling for NMOCs also controls for methane. 

3) Reviewer recommends clarifying in the rules whether the cited 98% effectiveness of 

GCCS at destroying NMOCs (referenced throughout the rules) is also 98% effective at 

destroying methane. 

4) Reviewer requests additional information about the source of the projected emissions 

reductions. It would be useful to have access to model data used, including the inventory 

of existing sources and their projected emissions curves. Access to the modelling 

showing the emissions and cost lifecycles over time and the effect of changing the 

emissions threshold from 50 to 34, as well as the effect of the tier 4 alternative would be 

helpful. 

5) Reviewer recommends clarification about why the small business screening analysis for 

the NSPS has been revised. If the screening analysis has been revised, reviewer requests 

the modelling or data that supports this new screening analysis. 

6) Reviewer recommends providing for more time for existing facilities to close to be 

included in the closed facility subcategory. The reasoning behind this subcategory would 

apply equally well to facilities close to the end of their useful life. Because of the time it 

will take to implement changes to the emissions guidelines, reviewer recommends that 

EPA propose included facilities that within 13 months after the publication of the final 

emission guidelines (a period of time likely before the first SIPs would be approved) for 

facilities to close and be included in the closed subcategory. 

7) Reviewer recommends including broader language (beyond combustion and chemical 

manufacturing) in the below sentence on page 17 of the emission guidelines to clarify 

that treated landfill gas can be used in a variety of ways including vehicle fuel, 

production of high-Btu gas for pipeline injection, and other beneficial uses. 
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

a. “The proposed definition allows the level of treatment to be tailored to the type 

and design of the specific combustion equipment or chemical manufacturing 

process in which the landfill gas is used.” 

8) Reviewer recommends clarifying whether, in practice, treated landfill gas was limited to 

use as a fuel for stationary construction devices in advance of this rule’s proposed 

changes. 

9) Reviewer recommends providing additional information on whether EPA anticipates that 

these rulemakings will change long-term landfill behavior. Does EPA project that any 

landfills will install GCCS that would not have done so in the absence of the emissions 

guidelines or engage in beneficial use of LFG or change their anticipated beneficial use? 

10) Reviewer recommends clarifying whether an owner or operator who must maintain a sitespecific treatment system monitoring plan must revise the plan if the intended end use of 

the treated LFG changes. See page 17 of the emissions guidelines. 

a. Reviewer also recommends clarifying what happens if the actual end use of the 

LFG differs from the “intended” end use detailed in the plan. 

11) Reviewer recommends editing the sentence on page 29 EG about NMOC containing air 

pollutants that pose more concern due to adverse effects on health and welfare. Since this 

rule focuses on greenhouse gas and aligns with the Climate Action Plan, it seems odd to 

call methane less concerning. 

12) Reviewer recommends clarifying how, if EPA did not receive new data on the NMOC 

destruction of energy recovery devices, do the cost/benefit estimates assume earnings 

from energy recovery from these devices? 

13) Reviewer recommends clarifying on page 92 EG why emissions will be higher in 2025 

just because the “majority of landfills in the dataset are expected to remain open”. An 

estimate of the number of new landfills expected from 2014-2025 would be helpful here. 

Or are the emissions cumulative rather than annual? 

14) Reviewer recommends clarifying throughout the rules which cost/benefit discussions are 

for the status quo and which are for the proposed rule. Recommend deleting any 

estimates for other scenarios or options or at least clarifying that they are not currently in 

place or proposed. 

15) Reviewer recommends clarifying why EPA is proposing to choose option 2.5/34, which 

based on the cost comparison tables seems to have the highest cost per Mg NMOC and 

methane of the options considered. 

16) Reviewer recommends clarifying on page 20 of the EG how EPA would maintain a 

recordkeeping and reporting requirement for landfills owners or operators to estimate 

emissions during periods of SSM.

Technical Comments

1) Reviewer recommends clarifying on page 15 of the NSPS EPA’s response to public 

comments received about whether landfills subject to the lower NMOC threshold may 

lose potential carbon credit revenue from voluntary projects and about difficulty with 

maintaining a flare in arid areas. As written, these are identified as concerns but are not 

addressed. 
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

2) Reviewer recommends clarifying why, if operational standards for temperature and 

nitrogen/oxygen no longer apply at the wellheads in order to trigger corrective action, are 

owners/operators still required to monitor for these. See page 19 of the emissions 

guidelines and elsewhere in the rule. 

a. Reviewer recommends eliminating the monitoring/recordkeeping requirements 

for these standards, and instead framing their use instead as a way to ensure 

effective use of the GCCS, and a preferable component of a site-specific 

operating plan. 

3) Reviewer recommends clarifying how the third requirement for removing GCCS (page 

19 EG) would work. That is, does an owner/operator have to show that there would be no 

surface methane emissions of 500 ppm or greater without the GCCS or only that there are 

no such SEMs with the GCSS operating? 

4) Reviewer recommends clarifying the section on page 41 EG, where the sentence about 

“wet areas getting wetter and dry regions getting drier” is immediately preceded by a 

sentence anticipating “substantial shifts in where precipitation falls”. These seem to be in 

conflict. 

5) Reviewer recommends clarifying table 2 on page 94 EG. Does the “baseline” refer to the 

existing emissions guidelines threshold or the one proposed in this rule? It is unclear what 

threshold/controls the anticipated reductions are tied to. 

6) Reviewer recommends clarifying the cost language on pages 117 and 118 EG. As 

written, it sounds like a fraction of the costs will be borne by “open landfills” and a larger 

cost for all landfills. Does this mean that “closed” landfills will bear a greater proportion 

of the costs? Why? 

7) Reviewer recommends clarifying that the additional 22 and additional 36 landfills 

referred to on page 156 EG are all closed landfills. 

8) Reviewer recommends clarifying on page 180 EG any potential hazards of closing vents 

during an uncontrolled gas event. 

9) Reviewer recommends clarifying why one of the potential requirements on page 198 EG 

is to restrict team members to those who have not previously performed work for the 

respondents, including how this might affect affected landfills in more remote or rural 

areas. 

10) Reviewer recommends adding “of control devices” after “periods of startup, shutdown, 

and malfunction” on page 20 and 65 of the EG.

Typographical Comments

1) Reviewer recommends adding a citation for the sentence including the phrase “evidence 

indicates that the increases in heat mortality...” (see page 33 EG) 

2) Reviewer recommends increased reliance on citations in the climate change section 

(pages from approximately 20-50 EG). 

3) Reviewer recommends clarifying on page 108 EG that the proposed rule would “reduce” 

methane. As written, it says “achieve” methane. Could also say “achieve methane 

reductions of...” 
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

4) Reviewer notes that the email address for OIRA on page 232 EG is incorrect. 

5) Reviewer recommends citing the assertion on page 34 of the emissions guidelines (and 

NSPS where appropriate) that climate change is “very likely to fundamentally rearrange 

U.S. ecosystems over the 21st century.”

6) Reviewer recommends replacing the word “of” with “on” on page 54 EG in the sentence 

including “...several items to minimize the burden...”

RIA Comments 

1) Reviewer recommends deleting the discussion in the RIA (starting on page 4-25) because 

acrolein and acetaldehyde are HAPS but not key landfills gases. Further, the discussion 

of acrolein being “more toxic” is uncertain because there is no information about doseresponse. Without dose response, all that can be said is that adverse health effects can 

start to manifest at lower concentrations for acrolein than acetaldehyde.

2) Reviewer recommends clarifying in the RIA that EPA cannot estimate how much HAPs 

would be reduced because of this rule, and therefore cannot estimate benefits. 

3) Reviewer recommends clarifying the first paragraph of the RIA on toluene. It currently 

says “toluene was not carcinogenic in adequate inhalation cancer bioassays of rata and 

mice exposed for life, and increased evidence of mammary cancer and leukemia were 

reported in a lifetime rat oral bioassay.” Were the increased incidences of mammary 

cancer and leukemia observed in inadequate oral cancel bioassays? 

a. The cancer classification is just hazard identification, so there should be 

discussion on why the evidence is inadequate despite a positive oral cancer 

bioassay.

4) Reviewer recommends presenting the revenue for electricity generated in the benefit 

section.

5) Reviewer recommends clarifying the gross cost in the cost discussion. 

6) Reviewer recommends presenting the baseline emissions of methane and NMOC in 

tabular format.

7) Reviewer recommends providing additional details on EPA’s methods for estimating 

costs and emissions reductions, and recommends drawing additional language citing to 

the two summary TSDs referenced.

8) Reviewer recommends incorporating relevant memos such as “methodology for 

estimating cost and emission impacts of proposed MSW landfill regulations” as 

appendices of the RIA.

9) Reviewer recommends clearly articulating the analytic timeline since EPA only presents 

results in the RIA for a snapshot of 2025.

10) Reviewer recommends that the ES.1 background should more clearly articulate that the 

document represents the analysis for both emissions guidelines for existing landfills and 

NSPS for new landfills.

11) Reviewer recommends clarifying throughout the document the distinction between 

existing landfills and new landfills. Reviewer suggests using phrases such as “emissions 

guidelines for existing landfills” and “NSPS for new landfills”.

12) Reviewer requests providing a citation for 50% of landfill gas being composed of 

methane.

13) Reviewer recommends additional information on the basis for the assumed efficacy of the 

collection systems, including citations.
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

14) Reviewer requests that EPA provide the peer review report for the Marten et al social 

cost paper.

15) Reviewer notes that the basis for no SISNOSE finding isn’t stated and requests the 

analysis to support this conclusion.

16) Reviewer recommends stating in 1.2.1 the requirements relevant to methane. Otherwise, 

it’s not clear why methane isn’t included in the co-benefit category.

17) Reviewer recommends deleting the discussion in 1.2.2 of market power and 

inadequate/asymmetric information since they are not relevant to this rulemaking.

18) Reviewer recommends that EPA use PPI data from BLS instead of the 2% inflation rate 

for capital and 2.5% inflation rate for O&M on 3-5.

19) Reviewer recommends clarifying on 3-8 what “baseline” means in Table 3-2

20) Reviewer recommends presenting revenue projections in the benefit section on 3-10. Is 

“beneficial projects” a term of art?

21) Reviewer recommends presenting cost-effectiveness both with and without the added 

revenue on 3-12.

22) Reviewer recommends clearly articulating which reductions are primary benefits and 

which are co-benefits on 4.1.

23) Reviewer recommends on 4-9 footnoting that the bias is unknown for other GHG.

24) Reviewer recommends providing a citation for Marten and Newbold 2012, which is not 

in the reference list. See 4-10.

25) Reviewer recommends more specificity in the HAP benefits discussion on 4.5. If there 

are known HAP emissions please focus the discussion to those emissions. The current 

discussion doesn’t seem very relevant to these rulemakings.

26) Reviewer recommends that given the current unemployment rate of 5.3%, the compelling 

need for an extensive discussion on employment on 5.3 isn’t clear. For the final rule, 

reviewer recommends abbreviating this discussion. 

27) Reviewer recommends adding discussion in the RIA of the impacts (or lack thereof) of 

the proposed Tier 4 option on the emissions reductions assumed by the 34 threshold. 

28) Reviewer notes that the RIA currently does not discuss the climate impacts of the 

oxidization of CH4 into CO2 into the atmosphere. While it is likely that these impacts are 

small when offset by other considerations, a discussion that these impacts were 

considered would be appropriate. For example, such a discussion occurs in section 4.7 of 

the Oil and Gas rule RIA.

 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

EO12866_LandfillsEG 2060 AS23 RIA 20150720

Regulatory Impact Analysis for the Proposed 

Revisions to the Emission Guidelines for Existing 

Sources and Supplemental Proposed New Source 

Performance Standards in the Municipal Solid Waste 

Landfills Sector 

U.S. Environmental Protection Agency 

Office of Air and Radiation 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

June July 2015
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

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 

Charles Fulcher, 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: fulcher.charles@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. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

iii 

TABLE OF CONTENTS 

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

LIST OF TABLES .................................................................................................................................. VI

LIST OF FIGURES ......................................................................................................................... VIIIVII

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

ES.1 BACKGROUND ........................................................................................................................................... 1

ES.2 RESULTS FOR PROPOSED REVISIONS TO EMISSION GUIDELINES ................................................................... 1

ES.3 RESULTS FOR SUPPLEMENTAL PROPOSED NEW SOURCE PERFORMANCE STANDARDS ................................... 3

ES.3 ORGANIZATION OF THIS REPORT ................................................................................................................ 5

1 INTRODUCTION ........................................................................................................................ 1-1

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

1.2 STATEMENT OF NEED FOR POLICY ACTION .............................................................................................. 1-2

1.2.1 Protection of Human Health and the Environment ......................................................................... 1-2

1.2.2 Need for Regulatory Intervention Because of Market Failure ......................................................... 1-3

1.2.2.1 Air Pollution as an Externality ............................................................................................. 1-4

1.3 ORGANIZATION OF THIS REPORT ........................................................................................................ 1-51-4

1.4 REFERENCES .......................................................................................................................................... 1-5

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 MSW............................................................................................................. 2-3

2.2.1.2 Landfills Covered Under the 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 ........................................................................ 2-242-23

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 .......................................................................................................................... 2-272-26

2.6.4 Utilization .................................................................................................................................. 2-28

2.6.4.1 Technologies ..................................................................................................................... 2-28

2.6.4.2 Revenues and Incentives .................................................................................................... 2-33

2.7 INTEGRATED WASTE MANAGEMENT STRATEGIES .................................................................................. 2-36

2.7.1 Introduction ................................................................................................................................ 2-36
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

iv 

2.7.2 Organics Management ................................................................................................................ 2-37

2.7.2.1 Trends ............................................................................................................................... 2-38

2.7.2.2 Benefits ...................................................................................................................... 2-412-40

2.7.2.3 Barriers ...................................................................................................................... 2-412-40

2.8 REFERENCES ................................................................................................................................. 2-432-42

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

3.1 INTRODUCTION ...................................................................................................................................... 3-1

3.2 GENERAL ASSUMPTIONS AND PROCEDURES ............................................................................................ 3-1

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

3.4 ENGINEERING AND ADMINISTRATIVE COST ANALYSIS ............................................................................. 3-4

3.5 REGULATORY BASELINE AND OPTIONS ................................................................................................... 3-7

3.6 ALTERNATIVE YEARS OF ANALYSIS ............................................................................................... 3-143-12

4 BENEFITS OF EMISSIONS REDUCTIONS .................................................................................. 4-1

4.1 INTRODUCTION ...................................................................................................................................... 4-1

4.2 METHANE (CH4) .................................................................................................................................... 4-4

4.2.1 Methane climate effects and valuation ........................................................................................... 4-4

4.2.2 Methane as an ozone precursor ................................................................................................... 4-16

4.2.3 Combined climate and ozone effects of methane ......................................................................... 4-17

4.3 VOC AS A PM2.5PRECURSOR .......................................................................................................... 4-194-18

4.3.1 PM2.5 health effects and valuation ................................................................................................ 4-19

4.3.2 Visibility Effects......................................................................................................................... 4-23

4.4 VOC AS AN OZONE PRECURSOR ........................................................................................................... 4-23

4.4.1 Ozone health effects and valuation .............................................................................................. 4-24

4.4.2 Ozone vegetation effects ............................................................................................................. 4-25

4.4.3 Ozone climate effects.................................................................................................................. 4-25

4.5 HAZARDOUS AIR POLLUTANT (HAP)BENEFITS ..................................................................................... 4-26

4.5.1 Benzene...................................................................................................................................... 4-31

4.5.2 Ethylbenzene .............................................................................................................................. 4-32

4.5.3 Toluene ...................................................................................................................................... 4-33

4.5.4 Vinyl Chloride ............................................................................................................................ 4-34

4.5.5 Other Air Toxics ......................................................................................................................... 4-35

4.6 ALTERNATIVE YEARS OF ANALYSIS ...................................................................................................... 4-35

4.7 REFERENCES ........................................................................................................................................ 4-36

5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS ................................ 5-1

5.1 INTRODUCTION ...................................................................................................................................... 5-1

5.2 ECONOMIC IMPACT ANALYSIS ................................................................................................................ 5-1

5.3 EMPLOYMENT IMPACTS .......................................................................................................................... 5-2

5.3.1 Background on the Regulated Industry .......................................................................................... 5-3

5.3.2 Employment Impacts of Environmental Regulation ....................................................................... 5-6

5.3.3 Conclusion ................................................................................................................................. 5-11

5.4 SMALL BUSINESS IMPACTS ANALYSIS ................................................................................................... 5-12

5.5 REFERENCES ........................................................................................................................................ 5-13

6 COMPARISON OF BENEFITS AND COST .................................................................................. 6-1

6.1 INTRODUCTION ...................................................................................................................................... 6-1

6.2 NET BENEFITS OF THE PROPOSED STANDARDS ........................................................................................ 6-1

6.3 NET BENEFITS OF THE ALTERNATE STANDARDS ...................................................................................... 6-2

7 SUPPLEMENTAL NSPS PROPOSAL ......................................................................................... 7-1

7.1 INTRODUCTION ...................................................................................................................................... 7-1

7.2 REGULATORY BASELINE AND OPTIONS ................................................................................................... 7-2

7.3 BENEFITS ........................................................................................................................................ 7-107-8
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

v 

7.4 ECONOMIC IMPACTS ...................................................................................................................... 7-147-11

7.4.1 Economic Impact Analysis................................................................................................... 7-147-11

7.4.2 Employment Impacts ........................................................................................................... 7-147-11

7.4.3 Small Business Impacts Analysis ......................................................................................... 7-147-11

7.5 COMPARISON OF BENEFITS AND COSTS .......................................................................................... 7-167-13

7.6 NET BENEFITS OF THE PROPOSED STANDARDS ............................................................................... 7-177-14

7.7 NET BENEFITS OF THE ALTERNATE STANDARDS ............................................................................. 7-187-15

7.8 ALTERNATIVE YEARS OF ANALYSIS ............................................................................................... 7-217-17

8 STATUTORY AND EXECUTIVE ORDER REVIEWS ................................................................... 8-1

8.1 EXECUTIVE ORDER 12866, REGULATORY PLANNING AND REVIEW AND EXECUTIVE ORDER 13563,

IMPROVING REGULATION AND REGULATORY REVIEW ...................................................................................... 8-1

8.2 PAPERWORK REDUCTION ACT ................................................................................................................ 8-2

8.3 REGULATORY FLEXIBILITY ACT.............................................................................................................. 8-4

8.4 UNFUNDED MANDATES REFORM ACT ..................................................................................................... 8-5

8.5 EXECUTIVE ORDER 13132: FEDERALISM ................................................................................................ 8-7

8.6 EXECUTIVE ORDER 13175: CONSULTATION AND COORDINATION WITH INDIAN TRIBAL GOVERNMENTS ... 8-8

8.7 EXECUTIVE ORDER 13045: PROTECTION OF CHILDREN FROM ENVIRONMENTAL HEALTH RISKS AND SAFETY 

RISKS .............................................................................................................................................................. 8-9

8.8 EXECUTIVE ORDER 13211: ACTIONS CONCERNING REGULATIONS THAT SIGNIFICANTLY AFFECT ENERGY 

SUPPLY, DISTRIBUTION, OR USE ..................................................................................................................... 8-10

8.9 NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT ............................................................. 8-10

8.10 EXECUTIVE ORDER 12898: ENVIRONMENTAL JUSTICE .......................................................................... 8-11
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

vi 

LIST OF TABLES 

Table ES-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed Emission Guidelines for 

Existing MSW Landfills in 2025 (2012$) ................................................................................................................ 3

Table ES-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Supplemental Proposed New 

Source Performance Standards for MSW Landfills in 2025 (2012$) ........................................................................ 5

Table 2-1 Generation and Discards of MSW, 1960 to 2012 (in pounds per person per day) ................................ 2-5

Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2012 (in thousands of tons) ................................... 2-7

Table 2-3 Top 5 Waste Management Companies That Owned or Operated MSW Landfills in the United States in 

2013a ................................................................................................................................................................ 2-14

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): 1995-2011 ......................................... 2-19

Table 2-6 Average LFG Power Production Technology Costs ................................................................... 2-302-29

Table 2-7 Average LFG Direct-use Project Components Costs .................................................................. 2-322-31

Table 2-8 Waste Management of Organics in the United States ................................................................. 2-402-39

Table 3-1 Number of Affected Landfills in 2025 under the Baseline and Alternative Options .............................. 3-8

Table 3-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and Alternative Options .... 3-9

Table 3-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-113-10

Table 3-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (3% Discount 

Rate) .......................................................................................................................................................... 3-133-11

Table 3-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate) ...... 3-

143-12

Table 3-6 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and Alternative Options ...... 3-

163-13

Table 3-7 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-163-13

Table 3-8 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and Alternative Options ...... 3-

173-14

Table 3-9 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-173-14

Table 3-10 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and Alternative Options .... 3-

183-15

Table 3-11 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-183-15

Table 4-1 Climate and Human Health Effects of Emission Reductions in this Rule ............................................. 4-2

Table 4-2 Social Cost of CH4, 2012 – 2050a [in 2012$ per metric ton] (Source: Marten et al., 2014b) ................ 4-12

Table 4-3 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) ..................................... 4-14

Table 4-4 Estimated Global Benefits of Net CO2 Reductions in 2025* (in millions, 2012$) .............................. 4-15

Table 4-5 Monetized Benefits-per-Ton Estimates for VOC based on Previous Modeling in 2015 (2012$) ......... 4-22

Table 4-6 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) ..................................... 4-35

Table 4-7 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) ..................................... 4-36

Table 4-8 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) ..................................... 4-36

Table 6-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed Emission Guidelines 

Option 2.5/34 in 2025 (2012$) ............................................................................................................................. 6-2

Table 6-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative Emission Guidelines 

Option 2.5/40 in 2025 (2012$) ............................................................................................................................. 6-3

Table 6-3 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative Emission Guidelines 

Option 2.0/34 in 2025 (2012$) ............................................................................................................................. 6-4

Table 7-1 Number of Affected Landfills in 2025 under the Baseline and Alternative Options .............................. 7-4

Table 7-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and Alternative Options .... 7-5

Table 7-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (7% Discount 

Rate) .............................................................................................................................................................. 7-77-6

Table 7-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (3% Discount 

Rate) .............................................................................................................................................................. 7-97-7
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

vii 

Table 7-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate) ...... 7-

107-8

Table 7-6 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) .............................. 7-137-10

Table 7-7 Estimated Global Disbenefits of Net CO2 Increases in 2025* (in millions, 2012$) ...................... 7-137-10

Table 7-8 Small Business Impact Screening Assessment Results (Reporters and Controllers) .................... 7-167-13

Table 7-9 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed NSPS Option 2.5/34 in 

2025 (2012$) .............................................................................................................................................. 7-177-14

Table 7-10 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Option 2.5/40 in 

2025 (2012$) .............................................................................................................................................. 7-207-16

Table 7-11 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Option 2.0/34 in 

2025 (2012$) .............................................................................................................................................. 7-217-17

Table 7-12 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and Alternative Options .... 7-

227-18

Table 7-13 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-227-18

Table 7-14 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and Alternative Options .... 7-

237-19

Table 7-15 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-237-19

Table 7-16 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and Alternative Options .... 7-

247-20

Table 7-17 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-247-20

Table 7-18 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) ............................ 7-257-21

Table 7-19 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) ............................ 7-257-21

Table 7-20 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) ............................ 7-257-21

 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

viii 

LIST OF FIGURES 

Figure 2-1 Material Composition of the MSW Discard Stream, 2012 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 Well LFG Collection 2-262-25

Figure 4-1 Path from GHG Emissions to Monetized Damages (Source: Marten et al., 2014) 4-9

Figure 4-2 2005 NATA Model Estimated Census Tract Carcinogenic Risk from HAP Exposure from Emissions of 

All Outdoor Sources (inclusive of Residental Wood Heaters) based on the 2005 National Toxic Inventory. 4-28

Figure 4-3 2005 NATA Model Estimated Census Tract Noncancer Risk from HAP Exposure from Emissions of 

All Outdoor Sources (inclusive of Residental Wood Heaters) based on the 2005 National Toxic Inventory 4-29
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-1 

 EXECUTIVE SUMMARY 

ES.1 Background 

The U.S. Environmental Protection Agency (EPA) is proposing revisions to the Emission 

Guidelines for existing Municipal Solid Waste Landfills. The EPA is not statutorily obligated to 

conduct a review of the Emission Guidelines, but has the discretionary authority to do so when 

circumstances indicate that this is appropriate. Based on changes in the landfills industry and 

changes in size, ownership, and age of landfills since the Emission Guidelines were promulgated 

in 1996, the EPA has concluded that it is appropriate to review the landfills Emission Guidelines 

at this time. Based on our review, we are proposing to lower the annual NMOC emissions 

threshold from 50 Mg/year to 34 Mg/year.

In addition, the EPA is proposing Supplemental New Source Performance Standards for 

new or modified Municipal Solid Waste Landfills. On July 17, 2014, the EPA proposed a new 

NSPS subpart that retained the same design capacity size threshold of 2.5 million m3 or 2.5 

million Mg, but presented several options for revising the NMOC emission rate at which a MSW 

landfill must install controls. Since presenting these options, the EPA has updated its model that 

estimates the emission reduction and cost impacts based on public comments and new data. As a 

result of these data and model improvements, we are now proposing to lower the annual NMOC 

emissions threshold from 50 Mg/year to 34 Mg/year.

ES.2 Results for Proposed Revisions to Emission Guidelines 

For the proposed revisions to the Emission Guidelines for existing MSW landfills, the 

key results of the RIA follow and are summarized in Table ES-1: 

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 

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 compliance cost 

in 2025 to be $46.8 million (2012$) using a 7% discount rate. Using a 3% discount rate, the 

Commented [A1]: OMB RIA Comment 10: Reviewer 

recommends that the ES.1 background should more clearly articulate 

that the document represents the analysis for both emissions 

guidelines for existing landfills and NSPS for new landfills. 

EPA Response: This section now discusses the supplemental NSPS 

proposal. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-2 

nationwide incremental annualized compliance cost in 2025 is estimated to be $35 million 

(2012$). 

Emissions Analysis: In 2025, this proposal would achieve reductions of 2,770 Mg NMOC and 

436,100 Mg methane (10.9 million Mg CO2-equivalents1) compared to the baseline. In addition, 

the proposal is expected to result in the net reduction of 238,000 Mg CO2, due to reduced 

demand for electricity from the grid as landfills generate electricity from landfill gas.2 These 

pollutants are associated with substantial health, welfare and climate effects. 

Benefits: The monetized benefits in this RIA include those from reducing 436,100 Mg methane, 

which are valued using the social cost of methane (SC-CH4), and the reductions in CO2, which 

are valued using the social cost of carbon (SC-CO2). The EPA estimates that, in 2025, the 

proposal will yield monetized climate benefits of $310 million (2012$) to approximately $1.7 

billion (2012$)3; the mean SC-CH4 at the 3% discount rate results in an estimate of about $660 

million (2012$) in 2025. The climate benefits associated with the reduction of 238,000 Mg CO2

are estimated to be $12 million (2012$) in 2025. The benefits from reducing some air pollutants 

have not been monetized in this analysis due to data, resource, and methodological limitations, 

including reducing 2,770 Mg NMOC (including undetermined amounts of HAPs). We assessed 

the benefits of these emission reductions qualitatively in this RIA. 

Small Entity Analysis: The EPA certifies that the proposed Emission Guidelines will not have a 

Significant Impact on a Substantial Number of Small Entities (SISNOSE) because the proposed 

rule will not impose any requirements on small entities. Specifically, Emission Guidelines 

established under CAA section 111(d) do not impose any requirements on regulated entities and, 

thus, will not have a significant economic impact upon a substantial number of small entities. 

Economic Impacts: Because of the relatively low net compliance cost of this proposal 

compared to the overall size of the MSW landfill industry, as well as 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

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

2

 The reduced demand for electricity from the grid more than offsets the additional energy demand required to 

operate the control system and the by-product emissions from the combustion of LFG. 

3

 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-3 

Table ES-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

Emission Guidelines for Existing MSW Landfills in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Total Monetized Benefits1 $670 million 

Total Costs2 $35 million $47 million 

Net Benefits $640 million $620 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 2,770 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 2,770 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 436,100 

Mg/yr methane ($660 million, valued using the social cost of methane) and the net reduction of 238,000 

Mg/yr of CO2 ($12 million, valued using the social cost of carbon). The social cost of methane and 

social cost of carbon estimates are calculated with four different values of a one ton reduction (model 

average at 2.5 percent discount rate, 3 percent, and 5 percent; 95th percentile at 3 percent). For the 

purposes of this table, we show the benefits associated with the model average at 3% discount rate; 

however we emphasize the importance and value of considering the full range of values, which is $310 

million - $1.8 billion for the proposed option. We provide climate benefit estimates based on additional 

discount rates in Section 4.2.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

ES.3 Results for Supplemental Proposed New Source Performance Standards 

For the Supplemental Proposed New Source Performance Standards for new or modified 

MSW landfills, the key results of the RIA follow and are summarized in Table ES-2: 

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 

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 compliance cost 

in 2025 to be $8.5 million (2012$) using a 7% discount rate. Using a 3% discount rate, the 

nationwide incremental annualized compliance cost in 2025 is estimated to be $7.1 million 

(2012$). 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-4 

Emissions Analysis: In 2025, this proposal would achieve reductions of 300 Mg NMOC and 

51,400 Mg methane (1.3 million Mg CO2-equivalents4) compared to the baseline. The proposal is 

also expected to result in minor secondary air impacts, specifically an increase of 670 Mg CO2, 

because more energy is required to operate the GCCS at some landfills than is produced by these 

landfills through the burning of LFG in engines. These pollutants are associated with substantial 

health, welfare and climate effects. 

Benefits: The monetized benefits in this RIA include those from reducing 51,400 Mg methane, 

which are valued using the social cost of methane (SC-CH4), offset by the small increases in 

CO2, which are valued using the social cost of carbon (SC-CO2). The EPA estimates that, in 

2025, the proposal will yield monetized climate benefits of $36 million (2012$) to approximately 

$210 million (2012$)5; the mean SC-CH4 at the 3% discount rate results in an estimate of about 

$78 million (2012$) in 2025. The climate disbenefits associated with the increase of 670 Mg CO2

are estimated to be $0.03 million (2012$) in 2025. The benefits from reducing some air 

pollutants have not been monetized in this analysis due to data, resource, and methodological 

limitations, including reducing 300 Mg NMOC (including undetermined amounts of HAPs). We 

assessed the benefits of these emission reductions qualitatively in this RIA. 

Small Entity Analysis: The EPA performed a small business impacts analysis on the 

Supplemental Proposed New Source Performance Standards for new or modified MSW landfills, 

and as with the July 2014 proposed NSPS subpart certifies that the proposed rule will not have a 

Significant Impact on a Substantial Number of Small Entities (SISNOSE). The proposed revision 

does not impact a substantial number of small entities, and the impact to these entities are not 

significant. This is discussed in greater detail in Section 7.4.

Economic Impacts: Because of the relatively low net compliance cost of this proposal 

compared to the overall size of the MSW landfill industry, as well as 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.

 

4

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

5

 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-5 

Table ES-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Supplemental Proposed New Source Performance Standards for MSW Landfills in 2025 

(2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $78 million 

Monetized CO2 disbenefits1 $0.03 million 

Total Costs2 $7.1 million $8.5 million 

Net Benefits $71 million $70 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 51,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 670 Mg/yr of CO2, valued 

using the social cost of carbon. The social cost of methane and social cost of carbon estimates are 

calculated with four different values of a one ton reduction (model average at 2.5 percent discount rate, 

3 percent, and 5 percent; 95th percentile at 3 percent). For the purposes of this table, we show the 

benefits associated with the model average at 3% discount rate; however we emphasize the importance 

and value of considering the full range of values, which is $36 million - $210 million for the proposed 

option. We provide climate benefit estimates based on additional discount rates in Section 4.2.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

ES.3 Organization of this Report 

The remainder of this report details the methodology and the results of the EIARIA. 

Chapter 1 provides an introduction. Chapter 2 presents the industry profile for the municipal 

solid waste landfill industry. Chapter 3 describes emissions, emissions control options, and 

engineering costs of the Emission Guidelines for existing landfills. Chapter 4 presents estimates 

of the benefits of emissions reductions from the Emission Guidelines for existing landfills. 

Chapter 5 present the economic impacts, employment impacts, and small entity screening 

analysis for the Emission Guidelines for existing landfills. Chapter 6 presents the comparison of 

the benefits and costs of the Emission Guidelines for existing landfills, Chapter 7 presents an 

analysis of the supplemental New Source Performance Standards (NSPS) for new or modified 

MSW landfills proposal, and Chapter 8 concludes with the statutory and executive order reviews. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

1-1 

1 INTRODUCTION 

1.1 Background 

The EPA is proposing revisions to the Emission Guidelines for existing Municipal Solid 

Waste Landfills. The EPA is not statutorily obligated to conduct a review of the Emission 

Guidelines, but has the discretionary authority to do so when circumstances indicate that this is 

appropriate. Based on changes in the landfills industry and changes in size, ownership, and age 

of landfills since the Emission Guidelines were promulgated in 1996, the EPA has concluded 

that it is appropriate to review the landfills Emission Guidelines at this time. Based on our 

review, we are proposing to lower the annual NMOC emissions threshold from 50 Mg/year to 34 

Mg/year. 

In addition, the EPA is proposing Supplemental New Source Performance Standards for 

new or modified Municipal Solid Waste Landfills. On July 17, 2014, the EPA proposed a new 

NSPS subpart that retained the same design capacity size threshold of 2.5 million m3 or 2.5 

million Mg, but presented several options for revising the NMOC emission rate at which a MSW 

landfill must install controls. Since presenting these options, the EPA has updated its model that 

estimates the emission reduction and cost impacts based on public comments and new data. As a 

result of these data and model improvements, we are now proposing to lower the annual NMOC 

emissions threshold from 50 Mg/year to 34 Mg/year.

In this RIA, 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 for this analysis. However, this dataset was missing 

some landfill data for recent years (2010-2014) and included incomplete data for many landfills. 

Thus, model landfills were created to represent the recent landfill data that were not included in 

the dataset. The model landfills were developed by evaluating the most recently opened existing 

landfills and assuming that the sizes and locations of landfills opening during 2010-2014 would 

be similar to the sizes and locations of landfills that opened in the most recent complete 5 years 

of data (2005-2010). The impacts of the proposed Emission Guidelines for existing MSW

landfills shown in this RIA are expressed as the incremental difference between facilities 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

1-2 

complying with the current Emission Guidelines for existing MSW landfills (40 CFR part 60, 

subpart Cc) and facilities that would be required to comply with proposed subpart Cf. Likewise, 

the impacts of the proposed NSPS for new or modified MSW landfills shown in this RIA are 

expressed as the incremental difference between facilities complying with the current NSPS for 

new or modified MSW landfills (40 CFR part 60, subpart WWW) and facilities that would be 

required to comply with proposed subpart XXX. All impacts are shown for the year 2025. The 

EPA is assessing impacts in year 2025 as a representative year for the both the landfills Emission 

Guidelines and NSPS. While the year 2025 differs somewhat from the expected first year of 

implementation for the Emission Guidelines (year 2020), the number of existing landfills 

required to install controls under the proposed 2.5/34 option in year 2025 is comparable (within 2 

percent of those required to control in the estimated first year of implementation. Further, year 

2025 represents a year in which several of the landfills subject to control requirements have had 

to expand their GCCS according the expansion lag times set forth in proposed subpart Cf. While 

the analysis focuses on impacts in 2025, results for alternative years are also presented. 

The EPA certifies that the proposed Emission Guidelines for existing landfills will not 

have a Significant Impact on a Substantial Number of Small Entities (SISNOSE) because the 

proposed rule will not impose any requirements on small entities. Specifically, Emission 

Guidelines established under CAA section 111(d) do not impose any requirements on regulated 

entities and, thus, will not have a significant economic impact upon a substantial number of 

small entities. The EPA also certifies that the supplemental proposed NSPS for new or modified 

MSW landfills also will not have a significant impact on a substantial number of small entities 

(SISNOSE). The proposed revision does not impact a substantial number of small entities, and 

the impact to these entities are not significant. This is discussed in greater detail in Section 7.4.

1.2 Statement of Need for Policy Action 

1.2.1 Protection of Human Health and the Environment 

The EPA has concluded, after reviewing data on MSW landfills, that a review of the 

Emission Guidelines for existing MSW landfills is appropriate at this time. In addition, the EPA 

is proposing Supplemental New Source Performance Standards for new or modified Municipal 

Commented [A2]: OMB RIA Comment 9: Reviewer 

recommends clearly articulating the analytic timeline since EPA 

only presents results in the RIA for a snapshot of 2025. 

EPA Response: The discussion has been edited to explain the 

choice of 2025 as a representative year. This discussion also added 

to Sections 3.2 and 7.2. In addition, some results from alternative 

snapshot years are now being included in Chapters 3, 4, and 7.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

1-3 

Solid Waste Landfills. To ensure that public health, safety, and the environment are protected, 

the EPA must ensure that emissions of methane, VOC, and HAP from MSW landfills are 

limited. The pollutant regulated under rules affecting landfills is “MSW landfill emissions”. 

Municipal solid waste landfill emissions, also commonly referred to as landfill gas (LFG), are a 

collection of air pollutants, including methane and NMOC, some of which are toxic.

6 The 1996 

NSPS/EG regulated nonmethane organic compounds (NMOC) as a surrogate for MSW landfill 

emissions but also considered significant methane reductions that could be achieved. In this EG 

and supplemental NSPS proposal, weWe are proposing to lower the annual NMOC emissions 

threshold from 50 Mg/year to 34 Mg/year. The proposed Emission Guidelines are expected to 

result in significant emissions reductions from existing MSW landfills. For the proposed 

Emission Guidelines, there will be climate benefits and HAP, ozone and PM2.5 health “cobenefits”. These co-benefits occur because the control techniques to meet the standards 

simultaneously reduce methane, VOC, and HAP emissions. The NMOC portion of LFG can 

contain a variety of air pollutants, including VOC and various organic HAP. VOC emissions are 

precursors to both fine particulate matter (PM2.5) and ozone formation, while methane is a 

greenhouse gas and a precursor to global ozone formation. As described in Chapter 4, these 

pollutants are associated with substantial health effects, climate effects, and other welfare effects. 

Thus, the proposed rule is expected to reduce human morbidity and premature mortality due to 

exposure to PM2.5, in addition to providing human health and ecosystem benefits due to reduced 

emissions of methane and HAP, and improved visibility due to reduced PM levels.

1.2.2 Need for Regulatory Intervention Because of Market Failure 

The U.S. Office of Management and Budget (OMB) directs regulatory agencies to 

demonstrate the need for a major rule. If the rule is intended to correct a market failure, the 

regulatory impact analysis must show that a market failure exists and that it cannot be resolved 

 

6 LFG is composed of approximately 50 percent methane, 50 percent CO2, and less than 1 percent NMOC. (Source: 

EPA. Compilation of Air Pollution Emission Factors, Publication AP-42, Draft Section 2.4 Municipal Solid 

Waste Landfills. October 2008. Available at http://www.epa.gov/ttn/chief/ap42/ch02/draft/d02s04.pdf.) While 

this composition is typical of LFG generated from established waste (waste that has typically been in place for at 

least a year), the quantity and composition of LFG does vary over the lifetime of the landfill. See Section 2.5 for 

more discussion. 

Commented [A3]: OMB RIA Comment 12: Reviewer requests 

providing a citation for 50% of landfill gas being composed of 

methane. 

EPA Response: Reference added in footnote. 

Commented [A4]: OMB RIA Comment 16: Reviewer 

recommends stating in 1.2.1 the requirements relevant to methane. 

Otherwise, it’s not clear why methane isn’t included in the cobenefit category. 

EPA Response: This discussion has been edited to indicate that 

NMOC is a surrogate for MSW landfill emissions, which is the 

regulated pollutant. MSW landfill emissions are composed of 

methane, CO2, and NMOC. In the 1996 NSPS/EG, it was noted that 

“The emissions of concern are non-methane organic compounds 

(NMOC) and methane.” Therefore, while NMOC has always been 

the emission measured to determine if a control system must be in 

place, methane has always been a targeted emission as well. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

1-4 

by measures other than Federal regulation. Market failures are categorized by OMB as 

externalities, market power, or inadequate or asymmetric information. The following paragraphs 

address each of the three categories of market failure as they apply to MSW landfills. The only 

of these three categories that applies to MSW landfills is air pollution as an externality, which is 

discussed in the following section.

1.2.2.1 Air Pollution as an Externality 

Air pollution is an example of a negative externality. This means that, in the absence of 

government regulation, the decisions of generators of air pollution do not fully reflect the costs 

associated with that pollution. For an MSW landfill operator, pollution from landfill gas is a byproduct that can be ignored or disposed of cheaply by venting it to the atmosphere. Left to their 

own devices, many MSW landfill operators may choose to treat air as a free good and not 

internalize the damage cause by emissions. NMOC and Greenhouse Gas (GHG) emissions 

impose costs on society, such as negative health and welfare impacts that are not reflected in the 

market price of the MSW landfill services being provided. This damage is borne by society, and 

the people who are adversely affected by the pollution are not able to collect compensation to 

offset their costs. They cannot collect compensation because the adverse effects, like odor and 

increased risks of morbidity and mortality, are by and large non-market goods. That is, they are 

goods that are not explicitly and routinely traded in organized free markets. 

1.2.2.2 Market Power 

In some respects, local disposal markets are natural monopolies. There are large 

economies of scale in disposal operations, there are barriers to entry through the large up-front 

capital costs necessary to construct a landfill, and in some situations transportation costs are too 

high to ship MSW between regions for disposal (though this is less the case in recent years). 

Unfortunately, the monopolistic (or oligopolistic) local markets that result from these natural 

conditions do not have the competitive market checks and balances that are needed to ensure the 

best utilization of societal resources. While the proposed Emission Guidelines are not designed 

to address the problem of market power, they are intended to ensure that MSW landfills operate 

in a more socially optimal manner. 

Commented [A5]: OMB RIA Comment 17: Reviewer 

recommends deleting the discussion in 1.2.2 of market power and 

inadequate/asymmetric information since they are not relevant to 

this rulemaking. 

EPA Response: Sections have been deleted. 
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1.2.2.3 Inadequate or Asymmetric Information 

The third category of potential market failure that is sometimes used to justify 

government regulation is inadequate or asymmetric information. Some MSW landfills can 

reduce costs by installing gas collection systems, recovering energy from the gas, and selling 

purified gas or electricity. Due to the costs associated with obtaining information about the 

potential costs and benefits of control, some landfills do not install such systems. The Emission 

Guidelines would specify the collection of information that may reduce the cost of obtaining data 

to make an informed decision on whether energy recovery is a good option.

1.3 Organization of this Report 

The remainder of this report details the methodology and the results of the RIA. Chapter 

2 presents the industry profile for the municipal solid waste landfill industry. Chapter 3 describes 

emissions, emissions control options, and engineering costs of the Emission Guidelines for 

existing landfills. Chapter 4 presents estimates of the benefits of emissions reductions from the 

Emission Guidelines for existing landfills. Chapter 5 present the economic impacts, employment

impacts, and small entity screening analysis for the Emission Guidelines for existing landfills. 

Chapter 6 presents the comparison of the benefits and costs of the Emission Guidelines for 

existing landfills, Chapter 7 presents an analysis of the supplemental New Source Performance 

Standards (NSPS) for new and modified MSW landfills proposal, and Chapter 8 concludes with 

the statutory and executive order reviews. 

1.4 References 

U.S. Environmental Protection Agency (EPA). 2008. Compilation of Air Pollution Emission 

Factors, Publication AP-42, Draft Section 2.4 Municipal Solid Waste Landfills. October 

2008. Available at http://www.epa.gov/ttn/chief/ap42/ch02/draft/d02s04.pdf.
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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 (EG) for MSW landfills regulate air 

emissions from landfills that receive household waste as defined in 40 CFR 60.751. 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, 2012b). 

EPA estimates the total amount of MSW generated in the United States in 2012 was 

approximately 251 million tons, a 20 percent increase from 1990. Despite increased waste 

generation, the amount of MSW deposited in landfills decreased from about 145 million tons in 

1990 to 135 million tons in 2012. 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, 2014a). The number of active MSW landfills in the United States has decreased from 

approximately 7,900 in 1988 to approximately 1,800 in 2014 (EPA, 2010; WBJ, 2014). 

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 (NMOC) 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 95 percent of landfill emissions. The remainder of the emissions 

is generated by industrial waste landfills (EPA, 2015h).

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. 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 2014, 58 percent of active MSW landfills were owned by public entities while 

42 percent were privately owned (EPA, 2014c). 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 of dollars 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 MSW 

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; Shin, 2014). 

2.2.1.2 Landfills Covered Under the EG 

The Landfills 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 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 2012, Americans generated about 251 million tons of trash. More than 65 million tons 

of this material was recycled and more than 21 million tons was composted, equivalent to a 34.5 

percent recycling rate (EPA, 2014a). In addition, about 29 million tons of waste was combusted 

for energy recovery (~12 percent) (EPA, 2014a). After recycling, composting, and combustion 

with energy recovery, the net per capita discard rate to landfills was 2.36 pounds per person per 

day in 2012 (EPA, 2014a). This is a 6 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 about 10 million 

tons, from 145 million to 135 million tons in 2012 (EPA, 2014a). While the number of U.S. 

MSW 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, 2014a). 
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Table 2-1 Generation and Discards of MSW, 1960 to 2012 (in pounds per person per day) 7

Activity 1960 1970 1980 1990 2000 2005 2008 2010 2011 2012

Generation 

 2.68 3.25 3.66 4.57 4.74 4.69 4.55 4.44 4.40 4.38 

Discards to landfill a

2.51 3.02 3.24 3.19 2.73 2.63 2.46 2.41 2.36 2.36 

Discards to landfill 

(% of total generation) 94% 93% 89% 70% 58% 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 

In 2012, organic materials continued to be the largest component of discarded MSW. 

Yard trimmings and food scraps account for 29.8 percent and paper and paperboard account for 

another 14.8 percent. Plastics comprise 17.6 percent while metals and wood make up 9.0 percent 

and 8.2 percent, respectively. Rubber, leather, and textiles combined account for 11.2 percent 

and glass accounts for 5.1 percent. Other miscellaneous materials account for the remaining 

4.3 percent of the MSW discarded in 2012 (EPA, 2014a). Figure 2-1 displays material 

composition percentages of the MSW discard stream in 2012, and Table 2-2 shows the amounts 

of different materials discarded in the MSW stream from 1960 to 2012. 

 

7

 Table adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, Recycling, 

and Disposal in the United States: Facts and Figures for 2012.” Table 4. EPA-530-F-14-001. Washington, DC: 

U.S. EPA. <http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_fs.pdf>. Accessed January 6, 2015. 
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Figure 2-1 Material Composition of the MSW Discard Stream, 20128

 

 

8

 Figure adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, 

Recycling, and Disposal in the United States: Facts and Figures for 2012.” Figure 7. EPA-530-F-14-001. 

Washington, DC: U.S. EPA. <http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_fs.pdf>. Accessed 

January 6, 2015.

21.1%

8.2%

17.6%

5.1%

9.0%

8.7%

14.8%

4.3%

11.2%

Food waste

Wood

Plastics

Glass

Metals

Yard trimmings

Paper & paperboard

Other

Rubber, leather & textiles
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Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2012 (in thousands of tons)9

Wastes 1960 1970 1980 1990 2000 2005 2010 2012 

Paper and Paperboard 24,910 37,540 43,420 52,500 50,180 42,880 26,740 24,260 

Glass 6,620 12,580 14,380 10,470 9,890 9,950 8,400 8,370 

Metals 10,770 13,350 14,290 12,580 12,340 13,410 14,500 14,760 

Plastics 390 2,900 6,810 16,760 24,070 27,600 28,790 28,950 

Rubber and Leather 1,510 2,720 4,070 5,420 5,850 6,240 6,120 6,180 

Textiles 1,710 1,980 2,370 5,150 8,160 9,680 11,100 12,080 

Wood 3,030 3,720 7,010 12,080 12,200 12,960 13,430 13,410 

Other Materialsb

70 470 2,020 2,510 3,020 3,080 3,370 3,300 

Food Waste 12,200 12,800 13,000 23,860 30,020 32,240 34,770 34,690 

Yard Trimmings 20,000 23,200 27,500 30,800 14,760 12,210 14,200 14,370 

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

Total MSW Discarded 82,510 113,040 137,120 175,030 173,990 173,940 165,260 164,270

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 

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 

 

9

 Table adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, Recycling, 

and Disposal in the United States Tables and Figures for 2012.” Table 3. Washington, DC: U.S. EPA. 

<http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_dat_tbls.pdf>. Accessed January 15, 2015. 
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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, 2012b). 

2.3.1.1 Landfill Siting and Permitting 

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

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, 2012b). 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 

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 
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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 soil and other materials 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 

generally less desirable than the area fill method, mostly due to the expense of lining side slopes 

to protect groundwater from leachate leakage and restrict gas migration (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 (NW&RA, 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 

landfill conditions and maintaining the landfill as a controlled facility. If an active LFG 

collection system is installed, then gas wells are monitored to ensure oxygen is not being pulled 

into the landfill due to excessive vacuum levels. 
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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 (NW&RA, 2008). If an LFG 

collection 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 2.6. 

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, 2012c). 

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) (NW&RA, 2008). Landfill liner systems 

also help prevent offsite 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 

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. 
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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, 2012d). 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 1980s, the number of active MSW landfills in the United States has decreased 

by approximately 75 percent (from ~7,900 in 1988 to ~1,800 in 2014) and the share of sites that 

are publicly owned has also decreased—from 83 percent in 1984 to 58 percent in 2014 (EPA, 

2010; WBJ, 2014; O’Brien, 2006; EPA, 2014c). However, the overall volume of disposal 

capacity has remained fairly constant, indicating a trend of growing individual landfill capacity 

(SWANA, 2007). Based on landfills reporting to the EPA Greenhouse Gas Reporting Program 

(GHGRP) that they were actively accepting waste in 2013, privately owned sites represented 73 

percent of the overall permitted MSW landfill capacity and 73 percent of the MSW landfilled in 

that year, an indication that private landfills are likely to be significantly larger than public ones 

(GHGRP, 2013). Among these reporting sites, the average annual amount of MSW disposed at 

public sites was just under 175,000 short tons, whereas the average private site landfilled about 

427,000 short tons of MSW per year—further evidence that publicly owned landfills are 

generally much smaller than their private counterparts (GHGRP, 2013). 

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 

existing sites and to the idea of regional landfills (EPA, 2002b). The passage of federal 
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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 2012e; 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, often using shipments from rail or truck (BioCycle, 2014a). 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, 2012f). Given the 

dramatic decrease in the number of active landfills in the past 25 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 100 private companies that own and/or operate currently active 

MSW landfills, ranging from large companies with numerous landfills throughout the country to 

local businesses that own a single landfill (EPA, 2014c). The handling of MSW in the United 

States generated $55 billion of revenue in 2011, of which landfilling contributed $13 billion 

(WBJ, 2012a). In terms of their overall 2013 revenue, the top two companies that own and/or 

operate MSW landfills in the United States were Waste Management ($13.98 billion) and 

Republic Services ($8.42 billion), which together accounted for approximately 40 percent of the 

solid waste management revenue share in 2013 (Bloomberg, 2014WM; Bloomberg, 2014RSG). 

The next tier of companies involved in landfill management includes Clean Harbors ($3.51 

billion), Progressive Waste Solutions ($2.03 billion), and Waste Connections ($1.93 billion) 

(Bloomberg, 2014CLH; Bloomberg, 2014BIN; Bloomberg, 2014WCN). Table 2-3 contains a 

summary of the 2013 revenue for the top five companies, as well as information about their 

MSW landfills and transfer stations. 
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Table 2-3 Top 5 Waste Management Companies That Owned or Operated MSW 

Landfills in the United States in 2013a

Company 

2013 

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, 

2014WM)

13.98 267 93.8 300 

Republic Services 

(Bloomberg, 

2014RSG)

8.42 

190 active/ 

124 closed 

N/A 199 

Clean Harbors 

(Bloomberg, 

2014CLH)

3.51 2 N/A N/A 

Progressive Waste 

Solutions 

(Bloomberg, 

2014BIN)

2.03 N/A N/A N/A 

Waste Connections 

(Bloomberg, 

2014WCN)

1.93 42 active 19.5 61 

a Ranking of top five companies adapted from “The 2013 Waste Age 100”. <http://waste360.com/%5Bprimaryterm%5D/2013-waste-age-100-premium>. Accessed January 16, 2015. 

N/A = 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 2012, 1,290 private 

establishments had 15,426 employees in the continental United States under NAICS 562212 

(Solid Waste Landfill) (Census, 2012). In 2013, solid waste management departments of local 

governments reported 95,674 full-time employees and 14,638 part-time employees (Census, 

2013); 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, 2015h). 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, 2012g). 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, LFG migration controls, closure requirements, and postclosure requirements (EPA, 2012g). 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 onsite structures needed to operate the landfill. Cortland County, New York estimated 

that the cost for site development and cell construction (not including onsite 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 on 

site 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 

operating costs dependent on fuel, repairs, and maintenance. Operating costs are relatively small 
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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 2.6 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). 
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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 (NW&RA, 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 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, 2012b), while the national average for only the largest public and 

private landfills was about $49 per ton (KleanIndustries, 2012). This compares to average 

national tip fees of approximately $32 in 1998 (Repa, 2005) and $8 in 1985 (NW&RA, 2011). 
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Average tip fees also 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. 

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): 1995-2011 

U.S. Region 1995a 1998a 2000a 2002a 2004a 2008b 2010c 2011d

Northeast $73 $67 $70 $69 $71 $67 NA $78 

Mid-Atlantic $46 $44 $46 $45 $46 $56 NA $65 

South $29 $31 $31 $30 $31 $32 NA $39 

Midwest $31 $31 $33 $34 $35 $39 NA $43 

South Central $20 $21 $22 $23 $24 $34 NA $33 

West Central $23 $23 $22 $23 $24 $39 NA $35 

West $38 $36 $35 $39 $38 $44 NA $55 

National $32 $32 $32 $34 $34 $42 $44 $50 

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: Shin, 2014 (data reported from Waste & Recycling News).

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 
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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 (300 percent) or an average of $2.40 per year. From 1985 to 2008, tipping fees 

for private landfills increased an average of $1.25 per year but these private fees increased by 

about $1.95 per year between 2004 and 2008 (KleanIndustries, 2012). 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 
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tip fees and total landfill revenues, but can help offset some landfill expenses, for example, the 

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

these potential revenue sources is available in Section 2.6. 

2.5 Air Pollutant Emissions from Landfills 

MSW landfills are a source of 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, 2012h). LFG generated from established waste 

(waste that has been in place for at least a year) is typically composed of roughly 50 percent 

methane and 50 percent carbon dioxide by volume, with trace amounts of NMOC and inorganic 

compounds (e.g., hydrogen sulfide) (EPA, 2015a; EPA, 2012h). 

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, 2012h). 

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., methane or carbon dioxide) and become part of the LFG (EPA, 

2012h). 
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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 

(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, 2012h). 

2.5.2 Methane in LFG 

Methane is 28-3625 times more effective at retaining heat in the earth’s atmosphere than 

carbon dioxide, over a 100 year time horizon, and therefore is considered a potent GHG (IPCC, 

20072013).10 In 2012, landfills were the third-largest anthropogenic source of methane emissions 

in the United States, with MSW landfills accounting for approximately 15 percent of the total 

methane emissions from all sources (EPA, 2015h).The carbon dioxide generated from MSW 

landfills is deemed biogenic because the carbon dioxide 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, 2015a). 

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

availability of oxygen at this stage means that carbon released from the decomposition of organic 

waste materials is in the form of carbon dioxide, and little methane is produced. during which 

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

anaerobic, methane generation increases, and the amount of carbon dioxide produced begins to 

level out (EPA, 2015a). Figure 2-3 presents a sample LFG generation curve over time for a 

typical MSW landfill. Significant methane generation can continue for 10 to 60 years after initial 

waste placement (EPA, 2012h). 

 

10 Note that this proposal uses a GWP value for methane of 25 for CO2 equivalency calculations, consistent with the 

GHG emissions inventories and the IPCC Fourth Assessment Report.

Commented [A6]: OMB RIA comment 28: Reviewer notes 

that the RIA currently does not discuss the climate impacts of the 

oxidization of CH4 into CO2 into the atmosphere. While it is likely 

that these impacts are small when offset by other considerations, a 

discussion that these impacts were considered would be appropriate. 

For example, such a discussion occurs in section 4.7 of the Oil and 

Gas rule RIA. 

EPA response: We don’t account for the CO2 because it is deemed 

biogenic and 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. In other words, the increase in 

atmospheric carbon dioxide concentration associated with the 

decomposition of organic waste materials would have occurred in 

the baseline and is not affected by the proposed rule. The new text in 

the RIA, pgs 2-22 and 2-23, clarifies this point. 
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Figure 2-3 Typical LFG Generation Curve 

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

United States, with MSW landfills accounting for approximately 15 percent of the total methane 

emissions from all sources (EPA, 2015h). Increasing attention is being given to mitigation of

methane, given its global warming potential 25 times greater than carbon dioxide and its 

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

dioxide) (EPA, 2015h). 

As methane oxides in the atmosphere, the carbon in methane is converted to carbon 

dioxide. Both the carbon dioxide generated directly from aerobic decomposition in MSW 

landfills and created as a result of methane oxidation in the atmosphere is deemed biogenic 

because the carbon dioxide 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, 

2015a). In other words, the increase in atmospheric carbon dioxide concentration associated with 

the decomposition of organic waste materials would have occurred in the baseline and is not 

affected by the proposed rule.
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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 

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

information about LFG combustion devices is available in Section 2.6. 

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 NMOC are required by the MSW landfills EG 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) LFG Energy Project Development Handbook 

(EPA, 2015a). 

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 or horizontal wells, and some collection systems 

involve a combination of the two. Vertical wells (Figure 2-4) are the most common method of 
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LFG collection and involve drilling wells vertically in the waste to collect gas. Horizontal wells 

(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. 

Source: EPA, 2015a 

Figure 2-4 Vertical Well LFG Collection 
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Source: EPA, 2015a 

Figure 2-5 Horizontal Well 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 (EPA, 1998). 

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 50 to 95 percent, with an average of 75 percent most 

commonly assumed (EPA, 1998; Sullivan, 2010; EPA, 2015a). In the current GHGRP 

requirements for MSW landfills (40 CFR part 98, subpart HH), LFG collection efficiencies vary 

for active gas collection systems depending upon cover material type, with daily soil cover 

assigned 60 percent, intermediate/final soil cover assigned 75 percent (also the default value), 

and final soil cover of three feet or thicker of clay and/or geomembrane cover system assigned 

95 percent. 

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

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

2012 $’s) required for a 40-acre collection system is $897,000, assuming one well is installed per 

acre. Typical annual operation and maintenance (O&M) costs (in 2012 $’s) for collection 

systems are approximately $2,500 per well, or $100,000 for a 40-acre system (EPA, 2014b). 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 landfills EG (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 

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

used at landfills meeting the criteria in 40 CFR 60.18(b) have been demonstrated to have 

destruction efficiencies similar to enclosed flares. 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, 2001). Enclosed flares are 

more expensive but may be preferable (or required by state regulations) because they provide 
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greater control of combustion conditions and allow for stack testing. They can also reduce noise 

and light nuisances. 

Flare costs vary based on the gas flow of the system. LFGcost-Web 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-Web (in 2012$), a flare for a system designed for 600 cubic 

feet per minute (cfm) of LFG will cost $223,000 (including condensate collection and blowers). 

Typical annual O&M costs (in 2012$) are approximately $5,000 per flare. Electricity costs to 

operate the blower for a 600-cfm active gas collection system would be $53,000 per year, 

assuming an electricity price of $0.085 per kilowatt-hour (kWh) (EPA, 2014b). 

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 640 LFG energy projects are currently operating in 48 states and 

Puerto Rico. 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, 2015b). 

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 

impurities. (While “treatment” has a specific meaning within the MSW landfills EG, 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 
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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, 2015b). 

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. 
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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 as well as interconnection costs. 

Table 2-6 Average LFG Power Production Technology Costs 

Technology 

Typical Size Used 

to Estimate Costs 

Typical Capital 

Costs ($/kW)a

Typical Annual O&M 

Costs ($/kW)a

Internal combustion engine 3,000 kW $1,700 $200 

Small internal combustion engine 500 kW $2,500 $220 

Gas turbine 10,000 kW $1,400 $130 

Microturbine 200 kW $2,900 $220 

Source: EPA, 2014b 

a

 2012$ 

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. 
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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 

(EPA, 2014b). 

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 
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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,b 

Gas compression and treatment $1,200/cfm $130/cfm 

Gas pipeline and condensate 

management system 

$449,000/mile Negligible 

Source: EPA, 2014b 

a

 2012$, based on a 1,000-cfm system with a 5-mile pipeline 

cfm: cubic feet per minute 

b

 Assuming an electricity price of $0.085 per kWh

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. 

Capital costs of high-Btu processing equipment (in 2012$) range from $2,500 per cfm 

LFG for a 10,000-cfm processing system to $5,900 per cfm LFG for a 1,000-cfm processing 
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system. The annual cost to provide electricity to, operate, and maintain these systems (in 2012$) 

is approximately $500 per cfm LFG (EPA, 2014b). Costs will depend on the purity of the highBtu 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. 

For alternative fuel projects, the capital costs of converting LFG into CNG also vary, 

depending primarily on the quantity of fuel being converted and the type of fueling station 

equipment. Similar to high-Btu processing equipment, some economies of scale are realized for 

larger volumes of gas. The capital costs for onsite CNG production with a fueling station (in 

2012$) ranges from $7,200 per cfm LFG for a 600-cfm project to $14,800 per cfm LFG for a 

100-cfm project. The annual cost to operate and maintain a CNG project (in 2012$), including 

media and equipment replacement, is approximately $1 per gallon of gasoline equivalent 

produced by the system, or $0.003 per cfm LFG assuming a conversion efficiency of 65 percent 

and a fuel use rate of 111,200 Btu per gallon of gasoline equivalent (EPA, 2014b). 

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 GHG Credits 

Voluntary GHG 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 GHG 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, Blue Source, and Chicago Climate Exchange (EPA 2012a). 

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

trades are project-specific and are negotiated directly between a buyer and seller of GHG credits. 

In these cases, corporate entities or public institutions, such as universities, may wish to reduce 
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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 GHG emissions from their organization. 

Many state and regional government entities are establishing their own GHG initiatives to 

cap or minimize GHG emissions within their jurisdictions. Examples include the Regional 

Greenhouse Gas Initiative (RGGI), the Washington carbon dioxide offset program, and 

Massachusetts’ carbon dioxide reduction from new plants. Some of these programs establish a 

cap-and-trade program on carbon dioxide emissions, while others require 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 11 cents per 

kWh (EPA, 2014b). 

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 
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“green,” energy resource. These additional revenues can come from premium pricing, tax credits, 

GHG 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-Web 

accommodates four common types of electricity project credits: a direct cash grant, an electricity 

generation tax credit expressed in dollars per kWh, a direct GHG (carbon) reduction credit 

expressed in dollars per metric ton of carbon dioxide equivalent (discussed in Section 2.6.4.2.1), 

and a direct renewable electricity credit expressed in dollars per kWh. This section 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 tax credit, commonly referred to as the renewable electricity Production Tax Credit 

(PTC), for power generated at privately owned LFG electricity projects. To qualify for the credit, 

which was 1.1 cent per kWh for the 2014 calendar year, all electricity produced must be sold to 

an unrelated person during the taxable year. Under legislation passed in December 2014, the 

placed-in-service date deadline for LFG energy projects to be eligible was extended to December 

31, 2014 (DSIRE, 2015). 
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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 

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 $1.50 to $4.00 

per million British thermal units (MMBtu) or 0.14¢ to 0.38¢ per megajoule (EPA, 2013). 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. Specific to vehicle fuel, EPA’s Renewable Fuel 

Standard (RFS) program allows registered renewable fuel producers, including biofuels 

produced from LFG, to generate Renewable Identification Number (RIN) credits for the 

renewable fuel produced which are purchased by parties required to meet specified volumes of 

renewable fuel (EPA, 2014d). In 2014, RIN credits for advanced biofuels (such as LFG-based 

biogas) were between $0.74 and $1.00 per RIN, equivalent to a range of $9 to $13 per million 

Btu (ABC, 2014). GHG emissions trading programs are also potential revenue streams for directuse projects. 

2.7 Integrated Waste Management Strategies 

2.7.1 Introduction 

Landfills are one method of waste disposal, but alternative strategies are available for the 

treatment of MSW, and multiple strategies are often used in combination. EPA has developed a 

non-hazardous waste management hierarchy that ranks the most environmentally sound 

strategies for MSW. Source reduction and reuse (waste prevention) is the most preferred method, 

followed by recycling and composting, energy recovery, and, lastly, treatment and disposal 

(EPA, 2015c). 

Waste prevention is the practice of designing products to reduce the amount of waste that 

will later need to be thrown away, which may result in less toxic waste (EPA, 2015d). Recycling 
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involves the recovery of useful materials, such as paper, glass, plastic, and metals from trash and 

using these materials to make new products. Recycling saves resources, including energy, raw 

materials, and landfill space. 

The diversion of organic materials, such as food scraps and yard waste (e.g., lawn 

trimmings, fallen leaves and branches), from landfills allows these materials to be used to create 

compost or generate energy. The management of organic materials is discussed in Section 2.7.2. 

Alternatively, MSW can be directly combusted in waste-to-energy facilities to generate 

electricity. At the power plant, MSW is unloaded from collection trucks and shredded or 

processed to ease handling. Recyclable materials are separated out, and the remaining waste is 

fed into a combustion chamber to be burned. The heat released from burning the MSW is used to 

produce steam, which turns a steam turbine to generate electricity (EPA, 2015e). 

Landfilling is often used as part of an integrated waste management strategy (e.g., where 

the same community has recycling programs, yard waste composting, and landfilling) and LFG 

can often be used for energy recovery as described in Section 2.6.4. LFG energy projects aim to 

recover and beneficially utilize methane generated from waste that has not been successfully 

diverted from landfills. The promotion of LFG energy is not in conflict with the promotion of 

organic waste diversion, nor does it compete with waste prevention or recycling, but allows LFG 

energy projects to utilize methane generated from millions of tons of organic waste already 

disposed in landfills while supporting future diversion of organic waste from landfills to reduce 

the amount of uncontrolled methane generated. In addition, some studies have shown that 

diverting waste from landfills may not always result in a comparative reduction in GHG 

emissions when efficient LFG collection systems and lifecycle emissions (from transportation 

and processing of organic waste) are taken into account (EPA, 2015f). 

2.7.2 Organics Management 

As detailed in Section 2.2.1.4, food waste, yard debris, and other organic materials 

continue to be the largest component of MSW discarded, with food waste comprising the largest 

portion (EPA, 2014a). Decreasing the amount of organics disposed in landfills would reduce the 

amount of LFG generated. If diverted from disposal in landfills, organic wastes can be 

composted or anaerobically digested. 
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Composting is the controlled biological decomposition of organic material in the 

presence of air to form a humus-like material. Controlled methods of composting include 

mechanical mixing and aerating, ventilating the materials by dropping them through a vertical 

series of aerated chambers, or placing the compost in piles out in the open air and mixing the 

piles periodically (EPA, 2015g). Diverted organic materials can also be used in an anaerobic 

digester, although digesters generally handle relatively small quantities of easily digestible 

waste. BioCycle identified nearly 5,000 composting facilities in the United States, with about 70 

percent composting only yard trimmings and 7 percent composting food scraps (BioCycle, 

2014a). 

Anaerobic digestion involves the conversion of organic matter to energy by 

microbiological organisms in the absence of oxygen. The biogas produced in the digestion 

process is a mixture of methane and carbon dioxide and can be used as a fuel source for heating 

or electricity production. Organic waste can either be digested at facilities specifically designed 

for the organic portion of MSW, or co-digested at wastewater treatment plants and manure 

digesters. The number of anaerobic digesters in the United States that process MSW-based 

wastes is on the rise from the first commercial scale plant coming online by 2010 up to more 

than seven plants operating by 2013, some of them digesting food waste alone and others codigesting food waste with wastewater and other organics (Arsova, 2010; RWI, 2013a; RWI, 

2013b). 

2.7.2.1 Trends 

States and municipalities in the United States are increasingly moving toward the 

diversion of organic wastes from landfills. State initiatives to recycle organic wastes have 

contributed to the growth of curbside organics collection as well as commercial and institutional 

collection and treatment. Table 2-8 lists the 21 states that have mandated organics diversion 

and/or banned disposal of organics from landfills. In particular, five states (California, 

Connecticut, Massachusetts, Rhode Island, and Vermont) have enacted legislation for organics 

disposal specific to food waste (BioCycle, 2014b; MSW Management, 2015). At a local level, 

BioCycle’s Fall 2014 survey identified 198 communities in 19 states with curbside collection of 

food scraps, as shown in Table 2-8. Between 2009 and 2014, the number of municipalities with 

source separated food waste collection more than doubled (from 90 to 198) and the number of 
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households grew by nearly 50 percent (BioCycle, 2015). The assortment of organics 

management initiatives and programs at state and local levels varies across the country by: 

• Type of organic wastes targeted (e.g., food waste, yard waste); 

• Source of organic waste generation (e.g., commercial, residential, institutional); 

• Phase of implementation (from pilot projects to mandatory requirements with fines 

for violations); and 

• Pricing formats (e.g., “pay-as-you-throw,” property tax, fixed fee) (BioCycle, 2015). 
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Table 2-8 Waste Management of Organics in the United States 

State State-wide Organics 

Diversion Mandate and/or 

Disposal Ban1,2,3

Local Residential Food 

Waste Collection 

Program4

Arkansas 

California (FW) 

Colorado 

Connecticut (FW) 

Delaware 

Illinois 

Indiana 

Iowa  

Kentucky 

Maryland  

Massachusetts (FW) 

Michigan 

Minnesota  

Nebraska 

New Hampshire 

New Jersey  

New York 

North Carolina 

Ohio  

Oregon 

Rhode Island2 (FW)

Pennsylvania  

South Carolina 

South Dakota 

Tennessee 

Texas 

Vermont (FW) 

Washington 

Wisconsin  

Number of States 21 19 

FW = Food waste diversion mandate and/or disposal ban

1

 Source: BioCycle, 2014a. Survey results from 39 states that responded. 

2

 Source: BioCycle, 2014b. Rhode Island legislation goes into effect January 2016. 

3

 Source: MSW Management, 2015. 

4

 Source: BioCycle, 2015. Denotes states that have one or more communities with a residential source separated 

food waste collection program. Programs are not state-wide initiatives.
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2.7.2.2 Benefits 

The benefits of diverting organic wastes from landfills include: 

• Reduction of methane, NMOC, and other air pollutants generated by the organic 

fraction of waste disposed in landfills; 

• Production of soil-improving compost material from composting (ILSR, 2014); 

• Generation of biogas from anaerobic digestion used to generate electricity and/or 

heat; and 

• Recovery and recycling of food waste to support food banks for humans or animals 

(MSW Management, 2015). 

2.7.2.3 Barriers 

Some barriers exist that can deter mandating the diversion of organics from landfills, 

especially in the format of a federal mandate, such as: 

• Lack of or variation in regulatory policies, incentives, and drivers to encourage 

organics diversion and make it more affordable (ILSR, 2014). For example, 

Kentucky’s composting permit fees for private entities led to a decline in applicants 

when the fee went from $0 to $3,000 in 2011, with an annual renewal fee of $500 

(BioCycle, 2014b). While New York does not have legislation in place, the state does 

review local materials management plans to provide suggestions on improving 

organics management and offers waste reduction and recycling grants to 

municipalities for education or capital expenditures (BioCycle, 2014b). Lessening 

permit restrictions and fees for organic waste facilities and offering state-level 

assistance to municipalities may spur movement to establish and expand organics 

management programs. 

• Limited capacity for organic material receiving, processing, and treatment facilities 

(e.g., composters, anaerobic digesters) and associated infrastructure (e.g., hauling 

services, transfer stations) (ILSR, 2014). While the United States has no shortage of 

landfill capacity overall, the average amount of organics diverted to composting in 27 

states is 5,155 tons per facility per year, which is far too low to adequately achieve 

higher composting rates (BioCycle, 2014a). Composting of organics can occur at 

several tiers, from home-based and small-scale farm and community sites to onsite 
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institutional systems (primarily schools) to large-scale centralized facilities, thus 

encouraging backyard and locally-based composting and developing adequate 

infrastructure for commercial composting (beyond yard waste) would lead to an 

increased capacity for organic wastes in urban, suburban, and rural areas (BioCycle, 

2014a). 

• Low cost to dispose waste in landfills relative to other waste treatment technologies 

(ILSR, 2014). Traditionally, waste disposal in the United States has been based on 

landfill tipping fees, or the fee a waste collector or hauler pays to discard waste in a 

landfill. Tipping fees at landfills vary across the United States, ranging from $5 to 

$142 per ton in 2011, with a national average just below $50 per ton (Shin, 2014). 

When recycling and organics diversion are introduced, the pricing structure shifts 

from a disposal cost to transportation and processing or treatment costs. Anaerobic 

digesters require significant capital investment and rely on tipping fees to recover 

costs to construct and operate the facility. In addition, due to opposition for siting 

these facilities, it is difficult to obtain permits to build digesters in densely populated 

areas, which results in increased costs to transport feedstock to the digester 

(Waste360, 2014). More recently, local solid waste agencies have offered reduced 

fees for source separated loads of organics at composting facilities. For example, 

Charleston County, South Carolina has a $25 per ton fee to drop off food and organic 

waste for composting, compared to $66 per ton for traditional waste sent to the 

landfill (ILSR, 2014). In addition, variable rate fees, or “pay-as-you-throw” pricing, 

incentivize separate collection of organics and recyclables as trash collection is 

typically priced at a higher fee than source separated organics and recyclables (ILSR, 

2014). 

• Multifaceted and regional nature of the solid waste management industry. Waste 

generators include households, institutions, and commercial entities, and these parties 

vary regionally in both density and demographics. Historically, state and local 

government has controlled all aspects of collection, transportation, disposal, and 

treatment of solid waste including the permitting of facilities and infrastructure and 

assessment of fees through taxes and operation of landfills. Private companies also 

play a significant role that ranges from collecting and hauling waste to owning and 
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operating landfills. While the industry is moving towards more integrated solid waste 

management approaches at a local or regional level, there is not a shift towards a 

national solid waste management system. As a result, the policies, programs, and 

infrastructure to accommodate organics diversion must be tailored to the unique 

situations of each region, state, or municipality to best implement change among 

interlinked entities of generators, collectors, and treatment and disposal facilities. 

• Lack of information and understanding of the environmental and energy benefits of 

separating, recovering, and utilizing organics. Ultimately, effective organics 

diversion from landfills begins at the point of generation. Changing waste disposal 

habits can be challenging for individuals, businesses, and industries in the United 

States, but education and awareness about the benefits of composting and anaerobic 

digestion in a manner that relates directly to individuals and organizations may 

encourage and increase diversion of organics. 

2.8 References 

Alva, 2010. “Successfully Permitting a Solid Waste Landfill in a Metropolitan Area: Sunshine 

Landfill Expansion Project.” Paul Alva. Solid Waste Association of North America 

(SWANA) WASTECON 2010. 

American Biogas Council (ABC). 2014. “A Snapshot of RNG and the Market.” May 12, 2014. 

<https://www.americanbiogascouncil.org/biogasProcessing/rngMarket_snapshot.pdf>. 

Arsova, Ljupka. 2010. “Anaerobic Digestion of Food Waste: Current Status, Problems and an 

Alternative Product.” Columbia University. Earth Engineering Center. May 2010. 

<http://www.seas.columbia.edu/earth/wtert/sofos/arsova_thesis.pdf>. 

ATSDR. 2001. Landfill Gas Primer – An Overview for Environmental Health Professionals, 

Chapter 5: Landfill Gas Control Measures. Agency for Toxic Substances and Disease 

Registry (ATSDR). November 2001. 

<http://www.atsdr.cdc.gov/hac/landfill/html/ch5.html>.

BioCycle. 2010. “17th

 Nationwide Survey of MSW Management in the U.S.: The State of 

Garbage in America.” October 2010. <http://www.biocycle.net/2010/10/the-state-ofgarbage-in-america-4/>. 

BioCycle. 2014a. “State of Composting in the U.S.” July 2014. 

<http://www.biocycle.net/2014/07/16/state-of-composting-in-the-u-s/>. 

BioCycle. 2014b. “Taking States’ Pulse On Residential Food Waste Collection.” October 2014. 
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BioCycle. 2015. “BioCycle Nationwide Survey: Residential Food Waste Collection in the U.S.” 

January 2015. <http://www.biocycle.net/2015/01/15/residential-food-waste-collection-inthe-u-s-2/>. [Table found in print edition only] 

Bloomberg Businessweek. 2014BIN. Financial Statements for Progressive Waste Solutions 

(BIN). Annual Income Statement as of December 31, 2013. 

<http://investing.businessweek.com/research/stocks/financials/financials.asp?ticker=BIN:

CN>. 

Bloomberg Businessweek. 2014CLH. 2013 SEC Filings - Clean Harbors Inc (CLH). 10-K, 

Annual Financials, March 3, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=CLH

>. 

Bloomberg Businessweek. 2014RSG. 2013 SEC Filings - Republic Services Inc (RSG). 10-K, 

Annual Financials, February 13, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=RSG

>. 

Bloomberg Businessweek. 2014WCN. 2013 SEC Filings - Waste Connections Inc (WCN). 10-

K, Annual Financials, February 10, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=WC

N>. 

Bloomberg Businessweek. 2014WM. 2013 SEC Filings - Waste Management Inc (WM). 10-K, 

Annual Financials, February 18, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=WM

>. 

Burgiel, Jonathan J. 2003. R.W. Beck, Inc. “Making Ends Meet When Revenues Start to 

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3-1 

3 REGULATORY PROGRAM COSTS AND EMISSIONS REDUCTIONS 

3.1 Introduction 

Currently, the Emission Guidelines for existing MSW landfills 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 chapter of the RIA includes three sets of discussions related to the proposed new Emission 

Guidelines: 

• 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 RIA to 

better understand the regulatory impact analysis. However, we provide references to technical 

memoranda for readers interested in a greater level of detail. 

3.2 General Assumptions and Procedures 

The proposed Emission Guidelines will affect existing MSW landfills. Any changes to 

the emission guidelines that might result from this review will ultimately apply to landfills that 

accepted waste on or after November 8, 198711, and that commenced construction, 

reconstruction, or modification prior to July 17, 2014 (the date of publication of proposed 

revisions to the landfills NSPS, 40 CFR part 60, subpart XXX). However, the EPA recognizes 

that many landfills subject to the proposed Subpart Cf are closed or contain inactive areas that do 

not produce as much landfill gas. Therefore, the EPA is proposing a separate subcategory for 

 

11 This date in 1987 is the date on which permit programs were established under the Hazardous and Solid Waste 

Amendments of RCRA. This date was also selected as the regulatory cutoff in the EG for landfills no longer 

receiving wastes because EPA judged States would be able to identify active facilities as of this date. 
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3-2 

landfills that closed after 1987 but on or before the date of this Emission Guidelines proposal. 

These landfills would be subject to a 50 Mg/yr NMOC emission rate threshold, consistent with 

the NMOC thresholds in Subparts Cc and WWW of Part 60. These landfills will also be exempt 

from initial reporting requirements, provided that the landfill already met these requirements 

under Subparts Cc or WWW of Part 60. 

To assess the impacts of the proposal, the EPA drew upon a comprehensive database of 

existing landfills, derived from a landfill and LFG energy project database maintained by the 

EPA’s Landfill Methane Outreach Program (LMOP) and data from the Greenhouse Gas 

Reporting Program (GHGRP). Unfortunately, this dataset was missing some landfill data for 

recent years (2010-2014) and included incomplete data for many landfills. To better represent 

landfills from recent years, model landfills were created. These model future landfills were 

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

and locations of landfills opening in 2010-2014 would be similar to the sizes and locations of 

landfills that opened in the most recent complete 5 years of data (2005-2010). Based on this 

assessment, the EPA created a total of five model landfills to represent landfills opening during 

2010-2014, which combined with the five landfills for which construction was already planned, 

led to ten projected future landfills that would be subject to the Emission Guidelines. In addition, 

11 model landfills were created that would be subject to the NSPS discussed in Chapter 7. 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.” 

To estimate the cost and emission impacts of each regulatory option, EPA determined 

which landfills in the complete dataset met the design capacity and emission rate thresholds for 

each regulatory option, and then calculated the emission reductions and costs for each landfill 

under each regulatory option in 2025 using the methods described below. The EPA is assessing 

impacts in year 2025 as a representative year for the landfills Emission Guidelines. While the 

year 2025 differs somewhat from the expected first year of implementation for the Emission 

Guidelines (year 2020), the number of existing landfills required to install controls under the 

proposed 2.5/34 option in year 2025 is comparable (within 2 percent of those required to control 

in the estimated first year of implementation. Further, year 2025 represents a year in which 

several of the landfills subject to control requirements have had to expand their GCCS according 

the expansion lag times set forth in proposed subpart Cf. While the analysis focuses on impacts 
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3-3 

in 2025, results for alternative years are also presented in Section 3.6. The resulting costs and 

emission reductions incurred by each landfill were used to assess the overall impacts of the 

current Emission Guidelines 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, “Updated Methodology for Estimating 

Cost and Emission Impacts of Proposed MSW Landfill Regulations. 20142015.” 

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 Cc. 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% interest rate, which is consistent with EPA guidance 

for cost evaluations. Costs are also presented using a 3% interest rate, in accordance with 

OMB guidance. 

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 option12. As the landfill is filled over time, the 

 

12 Note that even though the proposed rule allows a 30-month initial lag time, the model actually assumes the 

collection equipment is installed and operational at 36 months. We modeled as a 36 month (3-year) lag time 

since the first-order decay equation used to model emissions is on an annual, instead of monthly, basis. Further, 

because the current rule requires annual NMOC emission reports to be submitted by 6 months into the following 

calendar year, the landfill would have 30 months after the submittal of its first NMOC emission report showing 

an exceedance to install the GCCS, which is approximately 36 months after the excess emissions occurred. 

Commented [A7]: OMB RIA Comment 9: Reviewer 

recommends clearly articulating the analytic timeline since EPA 

only presents results in the RIA for a snapshot of 2025. 

EPA Response: The discussion has been edited to explain the 

choice of 2025 as a representative year. In addition, some results 

from alternative snapshot years are being included in Chapters 3, 4, 

and 7. 

Commented [A8]: OMB RIA Comment 7: Reviewer 

recommends providing additional details on EPA’s methods for 

estimating costs and emissions reductions, and recommends drawing 

additional language citing to the two summary TSDs referenced. 

EPA Response: We feel that the RIA provides an appropriate level 

of detail about the models, as the memos are essentially the 

description of a series of equations from the models. 
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3-4 

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 maximum gas 

production, gas generation will begin to decline once waste is no longer accepted. At this point, 

the analysis assumes that the GCCS no longer needs to be expanded and the GCCS will continue 

to collect all the gas being produced until the gas production falls back below the emission 

threshold of the proposed standard and the GCCS has been installed for at least 15 years. 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 

percent13. 

In addition to direct emission reductions, the proposed Emission Guidelines are expected 

to have secondary air impacts due to the additional energy demand required to operate the 

control system and the by-product emissions from the combustion of LFG. However, these are 

offset by avoided emissions from the national electrical grid as landfills generate electricity from 

the LFG. The methodology used to estimate secondary impacts of the proposed Emission 

Guidelines are detailed in the docketed memorandum from ERG to EPA, “Estimating Secondary 

Impacts of the Landfills Emission Guidelines Review. 2015” 

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. 

The EPA derived the cost equations used in the evaluation from the EPA’s Landfill Gas 

Energy Cost Model (LFGcost-Web), version 3.0, which was developed by the EPA’s Landfill 

 

13 The regulatory analysis models collectable gas (see ERG. 2015. Updated Methodology for Estimating Cost and 

Emission Impacts of MSW Landfills Regulations). As per 60.34(f)(b)(2)(i), the GCCS should be designed to 

handle the maximum expected gas flow rate from the entire area of the landfill that warrants control over the 

intended use period of the gas control system equipment.

Commented [A9]: OMB RIA Comment 13: Reviewer 

recommends additional information on the basis for the assumed 

efficacy of the collection systems, including citations. 

EPA Response: A clarification and reference is provided in a 

footnote. 
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3-5 

Methane Outreach Program (LMOP). LFGcost-Web 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-Web encompasses the types of costs included in the EPA OAQPS control 

cost manual including capital costs, annual costs, and revenue from LFG electricity sales. 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 compliance costs include direct costs, indirect costs, and revenue from LFG electricity 

sales. 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. 

For this evaluation, the EPA assessed costs in 2012$. The costs included in LFGcostWeb are in 2013$ and were adjusted for inflation to 2012$ using a factor of 2 percent for capital 

costs and 2.5 percent for O&M costs.14 For the primary estimate of costs, 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. Costs were also estimated using an interest rate of 3%. 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. 

 

14 The inflation rate for capital equipment is consistent with the default equipment inflation rate in the LFGcost-Web 

model; the inflation rate for O&M costs is consistent with the default general inflation rate in the LFGcost-Web 

model. See further documentation at: http://epa.gov/lmop/publications-tools/lfgcost/LFGcostWebV3_0manual.pdf 

Commented [A10]: OMB RIA Comment 18: Reviewer 

recommends that EPA use PPI data from BLS instead of the 2% 

inflation rate for capital and 2.5% inflation rate for O&M on 3-5 

EPA Response: As noted in footnote 14, the rates used for this 

analysis are consistent with the default rates in the LFGcost-Web 

model. EPA will edit its analysis of impacts in the final rule to use 

the PPI data from BLS, but this request is not feasible for the 

proposal.
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3-6 

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 

(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% and greater than 

$0.0430 per kWh at 3% interest. 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-Web. 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. 
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3-7 

Several of the compliance requirements require labor to complete the activities in 

addition to capital expenses for purchasing the monitoring and control equipment. This analysis 

assumes that a Civil Engineer or Civil Engineer Technician completes compliance requirements 

of the proposed amendments, depending on the complexity of the task. Some landfill owners or 

operators do all or a portion of this work directly while others contract out control installation or 

monitoring requirements. 

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 2.5/40: design capacity retained at 2.5 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/34: design capacity retained at 2.5 Mg, emission threshold reduced 

to 34 NMOC Mg/yr 

• Alternative Option 2.0/34: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 34 Mg NMOC/year 

The baseline reflects the parameters of the current Emission Guidelines. In the baseline, 

the Emission Guidelines affect 989 landfills, with 574 landfills controlling emissions, 211 

landfills reporting but not controlling emissions, and 233 landfills in the closed subcategory in 

2025. 

Commented [A11]: OMB RIA Comment 19: Reviewer 

recommends clarifying on 3-8 what “baseline” means in Table 3-2. 

EPA Response: Requested clarification appears on 3-7 and is 

relevant for all tables and discussion in this section. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-8 

Table 3-1 Number of Affected Landfills in 2025 under the Baseline and Alternative 

Options 

Affected 

Landfills 

(Open and 

Closed) 

Affected 

Open 

Landfills 

Affected 

Closed 

Subcategory

Closed 

Landfills 

Controlling 

Emissions 

Open 

Landfills 

Controlling 

Emissions 

Open 

Landfills 

Reporting 

but Not 

Controlling 

Emissions 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 989 756 233 29 545 211 

 

Alternative EG Options

Alternative 

option 2.5/40 989 756 233 29 607 149 

Proposed option 

2.5/34 989 756 233 29 651 105 

Alternative 

option 2.0/34 1090 803 287 29 667 136 

Note: Affected landfills include landfills subject to rule based on size and open as of 2015 as well as landfills in the closed 

subcategory. Affected open landfills are comprised of open landfills controlling emissions and open landfills reporting but 

not controlling emissions. Some closed landfills are still controlling emissions in 2025. 

Based on the characteristics of the landfills, the proposed option presented in Table 3-1 

would require 106 additional landfills to install controls by 2025. The less stringent alternative 

option would require 62 additional landfills to install controls by 2025, while the more stringent 

alternative option would affect 101 additional landfills, with some being required only to report, 

others being required to control, and some being in the closed subcategory. In that option, 122 

additional landfills are required to install controls by 2025. 

 Under the proposed option 2.5/34, the emission reductions would be an additional 2,770 Mg 

NMOC and 436,100 Mg methane (10,900,000 Mg CO2 Eq.) compared to the baseline in 2025. 

The less stringent alternative option 2.5/40 would yield emissions reductions of 1,720 Mg 

NMOC and 270,700 Mg methane (6,800,000 Mg CO2 Eq.) compared to the baseline, while the 

more stringent alternative option 2.0/34 would result in emissions reductions of 3,040 Mg 

NMOC and 479,100 Mg methane (12,000,000 Mg CO2 Eq.) compared to the baseline. The wide 

range in magnitude of emission reductions among pollutants is due to the composition of landfill 
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3-9 

gas: NMOC represents less than 1 percent of landfill gas, while methane represents 

approximately 50 percent. The emission reductions are summarized in Table 3-2. 

Table 3-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 57,300 9,035,000 226,000,000 

Incremental values versus the current EG 

Alternative option 2.5/40 1,720 270,700 6,800,000 

Proposed option 2.5/34 2,770 436,100 10,900,000 

Alternative option 2.0/34 3,040 479,100 12,000,000 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Under the proposed option 2.5/34, when using a 7% discount rate the additional cost of control 

over the baseline in 2025 would is estimated to be $101 million, $55.3 million of which is 

estimated to be offset by increased revenue from beneficial-use projects, so the net cost is 

estimated to be $46.8 million (

Commented [A12]: OMB RIA Comment 6: Reviewer 

recommends presenting the baseline emissions of methane and 

NMOC in tabular format. 

EPA Response: Requested information appears in this table. 

Commented [A13]: OMB RIA Comment 5: Reviewer 

recommends clarifying the gross cost in the cost discussion. 

EPA Response: This discussion and the discussion in Section 7.2 

have been edited to discuss the control cost, revenue from 

beneficial-use projects, and the resulting net cost. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-10 

Table 3-3Table 3-3). The additional cost of control for the less stringent alternative 

option 2.5/40 would is estimated to be $60.3 million, $33.6 million of which is estimated to be 

offset by increased revenue from beneficial-use projects, so the net cost is estimated to be $27 

million, while. the The cost of control for the more stringent alternative option 2.0/34 would is 

estimated to be $111 million, $60.7 million of which is estimated to be offset by increased 

revenue from beneficial-use projects, so the net cost is estimated to be $51 million. These 

options represent approximately between 9 to 17 percent in additional net costs beyond the 

baseline, with the proposed option 2.5/34 resulting in a 16 percent increase in net costs beyond 

the baseline for the industry as a whole. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-11 

Table 3-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (7% Discount Rate) 

 Estimated Annualized Net Cost (Millions 2012$) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 7.3 1,700 1,410 299 

Incremental values versus the current EG

Alternative option 2.5/40 0.40 60.3 33.6 27.0 

Proposed option 2.5/34 0.69 101 55.3 46.8 

Alternative option 2.0/34 0.84 111 60.7 51.0 

Note: All total are independently rounded and may not sum. 

When using a 3% discount rate, the model predicts a different timing in the investment behavior 

by the landfills, which affects both the costs and revenue that are predicted in 2025. Under the 

proposed option 2.5/34, the additional cost of control over the baseline in 2025 would is 

estimated to be $117 million, $82.5 million of which is estimated to be offset in increased 

revenue from beneficial-use projects, so the net cost is estimated to be $35 million (
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-12 

Table 3-4Table 3-4). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $72.1 million, $52.3 million of which is estimated to be offset by 

increased revenue from beneficial use projects, so the net cost is estimated to be $20.1 million, 

while. the The cost of control for the more stringent alternative option 2.0/34 would is estimated 

to be $126 million, of which $89.1 million is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to be $38.1 million. These options represent 

approximately between 24 to 45 percent in additional net costs beyond the baseline, with the 

proposed option 2.5/34 resulting in a 41 percent increase in net costs beyond the baseline for the 

industry as a whole. However, it is important to note that the baseline value when using a 3% 

discount rate is less than 30 percent of the value when using a 7% discount rate, because the 

increased costs of earlier installation of GCCS and engines are offset by increased revenue from 

energy generation. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-13 

Table 3-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (3% Discount Rate) 

 Estimated Annualized Net Cost (Millions 2012$) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 7.1 2,190 2,120 84.5 

Incremental values versus the current EG

Alternative option 2.5/40 0.37 72.1 52.3 20.1 

Proposed option 2.5/34 0.66 117 82.5 35.0 

Alternative option 2.0/34 0.80 126 89.1 38.1 

Note: All total are independently rounded and may not sum. 

In terms of cost effectiveness, when considering the estimated net cost of the options, the 

overall average cost effectiveness for NMOC reductions is $5,0905,200 per Mg NMOC under 

the baseline and roughly $17,000 per Mg NMOC under the proposed option 2.5/34 and 

alternative option 2.0/34, and roughly $16,000 per Mg NMOC under the alternative option 

2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is roughly $32 33 per Mg methane under the baseline and 

approximately $100 - $110 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34. 

When estimating cost effectiveness excluding the estimated revenue from beneficial-use 

projects, the overall average cost effectiveness for NMOC reductions is $29,800 per Mg NMOC 

under the baseline and roughly $37,000 per Mg NMOC under the proposed option 2.5/34 and 

alternative option 2.0/34, and roughly $36,000 per Mg NMOC under the alternative option 

2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is $189 per Mg methane under the baseline and 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-14 

approximately $225 - $235 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34.

Table 3-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options 

(7% Discount Rate) 

Cost-effectiveness (2012$ per Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Net 

Costb 

/ton 

Total 

Cost 

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 5,200 29,800 33.1 189 1.3 7.6 

 

Incremental values versus the current EG 

Alternative option 2.5/40 15,800 35,500 100 225 4.0 9.0 

Proposed option 2.5/34 17,000 37,000 108 235 4.3 9.4 

Alternative option 2.0/34 16,800 36,900 107 234 4.3 9.4 

Note: The cost-effectiveness of NMOC and methane are estimated as if all of the control cost were attributed to each 

pollutant separately. 

a A global warming potential of 25 is used to convert methane to CO2-equivalents. The secondary CO2 emission 

reductions are not reflected in these estimates. 

b Net Cost is the total control and testing and monitoring cost minus any project revenue. The control costs for 

landfills with energy projects includes costs to install and operate a reciprocating engine (and associated electrical 

equipment), which is more expensive than a standard flare. Reciprocating engines are not required by the regulation 

but are expected to be used as control devices when it is cost-effective to recovery the LFG energy.

3.6 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

Emission Guidelines for existing MSW landfills, the quantity and composition of landfill gas 

does change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a 

more complete picture of the emission reductions and costs of the Emission Guidelines 

alternatives over time by presenting results from the years 2020, 2030, and 2040. Throughout 

this section, costs are presented only at a 7% interest rate, and do not include testing and 

monitoring costs. However, testing and monitoring costs are typically a very small percentage of 

Commented [A14]: OMB RIA Comment 21: Reviewer 

recommends presenting cost-effectiveness both with and without the 

added revenue on 3-12. 

EPA Response: Table 3-5 has been modified to include costeffectiveness with and without added revenue (change is not tracked 

due to Word issues) and surrounding discussion has been modified. 

Similar change made to Table 7-5 and surrounding text for 

supplemental NSPS proposal. 

Commented [A15]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-15 

the overall costs. Tables 3-6 and 3-7 present the emissions reductions and compliance costs, 

respectively, of the alternatives in the 2020 snapshot year. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-16 

Table 3-6 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 56,300 8.9 222 

Incremental values versus the current EG 

Alternative option 2.5/40 1,490 0.24 5.9 

Proposed option 2.5/34 2,270 0.36 9.0 

Alternative option 2.0/34 2,560 0.40 10.1 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-7 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 595 1,660 1,390 262 

Incremental values versus the current EG 

Alternative option 2.5/40 57 53.0 42.9 18.1 

Proposed option 2.5/34 93 88.4 65.8 30.5 

Alternative option 2.0/34 108 96.9 70.0 34.9 

Note: All total are independently rounded and may not sum. 

Tables 3-8 and 3-9 present the emissions reductions and compliance costs, respectively, in the 

2030 snapshot year.
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-17 

Table 3-8 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 55,600 8.8 219 

Incremental values versus the current EG 

Alternative option 2.5/40 1,960 0.31 7.7 

Proposed option 2.5/34 3,150 0.50 12.4 

Alternative option 2.0/34 3,390 0.53 13.4 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-9 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 554 1,680 1,360 325 

Incremental values versus the current EG 

Alternative option 2.5/40 65 69.4 31.5 32.9 

Proposed option 2.5/34 107 112.9 58.5 49.4 

Alternative option 2.0/34 123 122.4 63.9 53.5 

Note: All total are independently rounded and may not sum. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-18 

Tables 3-10 and 3-11 present the emissions reductions and compliance costs, respectively, in the 

2040 snapshot year. 

Table 3-10 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 49,500 7.8 195 

Incremental values versus the current EG 

Alternative option 2.5/40 1,340 0.21 5.3 

Proposed option 2.5/34 2,130 0.34 8.4 

Alternative option 2.0/34 2,210 0.35 8.7 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-11 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$)

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 464 1,500 1,100 398 

Incremental values versus the current EG 

Alternative option 2.5/40 47 51.6 26.7 27.0 

Proposed option 2.5/34 74 89.4 56.4 35.0 

Alternative option 2.0/34 81 93.0 58.2 36.7 

Note: All total are independently rounded and may not sum. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-1 

4 BENEFITS OF EMISSIONS REDUCTIONS 

4.1 Introduction 

The proposed Emission Guidelines are expected to result in significant emissions 

reductions of landfill gas (LFG) from existing MSW landfills. For the proposed Emission 

Guidelines, there will be climate benefits and HAP, ozone and PM2.5 health “co-benefits”. These 

co-benefits occur because the control techniques to meet the standards simultaneously reduce 

methane, VOC, and HAP emissions. By lowering the NMOC emissions threshold to 34 Mg/yr, 

the proposal is anticipated to achieve reductions of 2,770 Mg/yr NMOC and 436,100 Mg/yr 

methane in 2025. The NMOC portion of LFG can contain a variety of air pollutants, including 

VOC and various organic HAP. VOC emissions are precursors to both fine particulate matter 

(PM2.5) and ozone formation, while methane is a GHG and a precursor to global ozone 

formation. As described in the subsequent sections, these pollutants are associated with 

substantial health effects, climate effects, and other welfare effects. The only categories of 

benefits monetized in this RIA are methane-related climate effects and CO2 co-benefits 

associated with reduced electricity demand due to increased generation of electricity by landfills 

through the burning of LFG in engines. The methane-related climate benefits are estimated to 

range from $310 million (2012$) to $1.7 billion (2012$); these benefits are estimated to be $660 

million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are estimated to range 

from $3.6 million (2012$) to $36 million (2012$) in 2025; estimated CO2 benefits are $12 

million (2012$) in 2025 using a 3% discount rate. 

While we expect that these avoided emissions will also result in improvements in air 

quality and reduce health and welfare effects associated with exposure to HAP, ozone, and fine 

particulate matter (PM2.5), we have determined that quantification of those health benefits cannot 

be accomplished for this rule in a defensible way. This is not to imply that these benefits do not 

exist; rather, it is a reflection of the difficulties in modeling the direct and indirect impacts of the 

reductions in emissions for this industrial sector with the data currently available. With the data 

available, we are not able to provide a credible health co-PM2.5 benefits estimates for this rule, 

due to the differences in the locations of MSW landfill emission points relative to existing 

information and the highly localized nature of air quality responses associated with HAP and 

Commented [A16]: OMB RIA Comment 22: Reviewer 

recommends clearly articulating which reductions are primary 

benefits and which are co-benefits on 4.1 

EPA Response: Section has been edited to make this clearer. 

Formatted: Not Superscript/ Subscript
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-2 

VOC reductions.15 Nearly 30 organic HAPs have been identified in uncontrolled LFG, including 

benzene, ethylbenzene, toluene, and vinyl chloride, and they will be reduced by this rule. In this 

chapter, we provide a qualitative assessment of the health benefits associated with reducing 

exposure to these pollutants, as well as visibility impairment and ecosystem benefits. Table 4-1 

summarizes the quantified and unquantified benefits in this analysis. 

Table 4-1 Climate and Human Health Effects of Emission Reductions in this Rule 

Category Specific Effect 

Effect Has 

Been 

Quantified 

Effect Has 

Been 

Monetized 

More 

Information 

Improved Environment 

Reduced climate 

effects 

Global climate impacts from methane (CH4) 

and carbon dioxide (CO2) —1 

Marten et al. 

(2014), SC-CO2

TSDs 

Other climate impacts (e.g., ozone, black 

carbon, aerosols, other impacts) — — 

IPCC, Ozone ISA, 

PM ISA2

Improved Human Health 

Reduced incidence of 

premature mortality 

from exposure to 

PM2.5

Adult premature mortality based on cohort 

study estimates and expert elicitation estimates 

(age >25 or age >30)

— — PM ISA3

Infant mortality (age <1) — — PM ISA3

Reduced incidence of 

morbidity from 

exposure to PM2.5

Non-fatal heart attacks (age > 18) — — PM ISA3

Hospital admissions—respiratory (all ages) — — PM ISA3

Hospital admissions—cardiovascular (age >20) — — PM ISA3

Emergency room visits for asthma (all ages) — — PM ISA3

Acute bronchitis (age 8-12) — — PM ISA3

Lower respiratory symptoms (age 7-14) — — PM ISA3

Upper respiratory symptoms (asthmatics age 9-

11) — — PM ISA3

Asthma exacerbation (asthmatics age 6-18) — — PM ISA3

Lost work days (age 18-65) — — PM ISA3

Minor restricted-activity days (age 18-65) — — PM ISA3

Chronic Bronchitis (age >26) — — PM ISA3

Emergency room visits for cardiovascular 

effects (all ages) — — PM ISA3

 

15 Previous studies have estimated the monetized benefits-per-ton of reducing VOC emissions associated with the 

effect that those emissions have on ambient PM2.5 levels and the health effects associated with PM2.5 exposure 

(Fann, Fulcher, and Hubbell, 2009). While these ranges of benefit-per-ton estimates provide useful context, the 

geographic distribution of VOC emissions from the MSW landfill sector are not consistent with emissions 

modeled in Fann, Fulcher, and Hubbell (2009). In addition, the benefit-per-ton estimates for VOC emission 

reductions in that study are derived from total VOC emissions across all sectors. Coupled with the larger 

uncertainties about the relationship between VOC emissions and PM2.5 and the highly localized nature of air 

quality responses associated with VOC reductions, these factors lead us to conclude that the available VOC 

benefit-per-ton estimates are not appropriate to calculate monetized benefits of these rules, even as a bounding 

exercise. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-3 

Category Specific Effect 

Effect Has 

Been 

Quantified 

Effect Has 

Been 

Monetized 

More 

Information 

Strokes and cerebrovascular disease (age 50-

79) — — PM ISA3

Other cardiovascular effects (e.g., other ages) — — PM ISA2

Other respiratory effects (e.g., pulmonary 

function, non-asthma ER visits, non-bronchitis 

chronic diseases, other ages and populations) 

— — PM ISA2

Reproductive and developmental effects (e.g., 

low birth weight, pre-term births, etc) — — PM ISA2,4

Cancer, mutagenicity, and genotoxicity effects — — PM ISA2,4

Reduced incidence of 

mortality from 

exposure to ozone 

Premature mortality based on short-term study 

estimates (all ages) — — Ozone ISA3

Premature mortality based on long-term study 

estimates (age 30–99) — — Ozone ISA3

Reduced incidence of 

morbidity from 

exposure to ozone 

Hospital admissions—respiratory causes (age > 

65) — — Ozone ISA3

Hospital admissions—respiratory causes (age 

<2) — — Ozone ISA3

Emergency department visits for asthma (all 

ages) — — Ozone ISA3

Minor restricted-activity days (age 18–65) — — Ozone ISA3

School absence days (age 5–17) — — Ozone ISA3

Decreased outdoor worker productivity (age 

18–65) — — Ozone ISA3

Other respiratory effects (e.g., premature aging 

of lungs) — — Ozone ISA2

Cardiovascular and nervous system effects — — Ozone ISA2

Reproductive and developmental effects — — Ozone ISA2,4

Reduced incidence of 

morbidity from 

exposure to HAP 

Effects associated with exposure to hazardous 

air pollutants such as benzene — — ATSDR, IRIS2,3

Improved Environment 

Reduced visibility 

impairment 

Visibility in Class 1 areas — — PM ISA3

Visibility in residential areas — — PM ISA3

Reduced effects from 

PM deposition 

(organics) 

Effects on Individual organisms and 

ecosystems 

— — PM ISA2

Reduced vegetation 

and ecosystem effects 

from exposure to 

ozone 

Visible foliar injury on vegetation — — Ozone ISA3

Reduced vegetation growth and reproduction — — Ozone ISA3

Yield and quality of commercial forest 

products and crops — — Ozone ISA3

Damage to urban ornamental plants — — Ozone ISA2

Carbon sequestration in terrestrial ecosystems — — Ozone ISA3

Recreational demand associated with forest 

aesthetics — — Ozone ISA2

Other non-use effects Ozone ISA2

Ecosystem functions (e.g., water cycling, 

biogeochemical cycles, net primary 

productivity, leaf-gas exchange, community 

composition) 

— — Ozone ISA2

1

 The global climate and related impacts of CO2 and CH4 emissions changes, such as sea level rise, are estimated within each 

integrated assessment model as part of the calculation of the SC-CO2 and SC-CH4. The resulting monetized damages, which 

are relevant for conducting the benefit-cost analysis, are used in this RIA to estimate the welfare effects of quantified changes 

in CO2 emissions. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-4 

2

 We assess these benefits qualitatively because we do not have sufficient confidence in available data or methods. 

3

 We assess these benefits qualitatively due to data limitations for this analysis, but we have quantified them in other analyses. 

 4 We assess these benefits qualitatively because current evidence is only suggestive of causality or there are other significant 

concerns over the strength of the association. 

4.2 Methane (CH4) 

4.2.1 Methane climate effects and valuation 

Methane is the one of the principal components of landfill gas. Methane is also a potent 

greenhouse gas (GHG) that once emitted into the atmosphere absorbs terrestrial infrared 

radiation that contributes to increased global warming and continuing climate change. Methane 

reacts in the atmosphere to form ozone and ozone also impacts global temperatures. Methane, in 

addition to other GHG emissions, contributes to warming of the atmosphere, which over time 

leads to increased air and ocean temperatures, changes in precipitation patterns, melting and 

thawing of global glaciers and ice, increasingly severe weather events, such as hurricanes of 

greater intensity, and sea level rise, among other impacts. 

According to the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment 

Report (AR5, 2015), changes in methane concentrations since 1750 contributed 0.48 W/m2 of 

forcing, which is about 17% of all global forcing due to increases in anthropogenic GHG 

concentrations, and which makes methane the second leading long-lived climate forcer after 

CO2. However, after accounting for changes in other greenhouse substances such as ozone and 

stratospheric water vapor due to chemical reactions of methane in the atmosphere, historical 

methane emissions were estimated to have contributed to 0.97 W/m2 of forcing today, which is 

about 30% of the contemporaneous forcing due to historical greenhouse gas emissions. 

MSW landfills emit significant amounts of methane. The Inventory of U.S. Greenhouse 

Gas Emissions and Sinks: 1990-2013 (published April 2015) estimates 2013 methane emissions 

from MSW landfills to be 97.5 MMt CO2 Eq. In 2013, total methane emissions from MSW 

landfills represented approximately 15 percent of the total methane emissions from all sources 

and account for about 1.5 percent of all CO2-equivalent (CO2 Eq.) emissions in the U.S., with 

landfills being the third largest contributor to U.S. anthropogenic methane emissions (EPA, 

2015). 
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4-5 

This rulemaking proposes emission control technologies and regulatory alternatives that 

are expected to significantly decrease methane emissions from existing MSW landfills. By 

lowering the NMOC emissions threshold to 34 Mg/yr, the proposal would achieve reductions of 

2,770 Mg/yr NMOC and 436,100 Mg/yr methane in 2025. 

We calculated the global social benefits of methane emissions reductions expected from 

the proposed guidelines for existing MSW landfills using estimates of the social cost of methane 

(SC-CH4), a metric that estimates the monetary value of impacts associated with marginal 

changes in methane emissions in a given year. It includes a wide range of anticipated climate 

impacts, such as net changes in agricultural productivity and human health, property damage 

from increased flood risk, and changes in energy system costs, such as reduced costs for heating 

and increased costs for air conditioning. The SC-CH4 estimates applied in this analysis were 

developed by Marten et al. (2014) and are discussed in greater detail below. 

A similar metric, the social cost of CO2 (SC-CO2), provides important context for 

understanding the Marten et al. SC-CH4 estimates. Estimates of the SC-CO2 have been used by 

EPA and other federal agencies to value the impacts of CO2 emissions changes in benefit cost 

analysis for GHG-related rulemakings since 2008. The SC-CO2 is a metric that estimates the 

monetary value of impacts associated with marginal changes in CO2 emissions in a given year. 

Similar to the SC-CH4, it includes a wide range of anticipated climate impacts, such as net 

changes in agricultural productivity, property damage from increased flood risk, and changes in 

energy system costs, such as reduced costs for heating and increased costs for air conditioning. It 

is used to quantify the benefits of reducing CO2 emissions, or the disbenefit from increasing 

emissions, in regulatory impact analyses. 

The SC-CO2 estimates were developed over many years, using the best science available, 

and with input from the public. Specifically, an interagency working group (IWG) that included 

EPA and other executive branch agencies and offices used three integrated assessment models 

(IAMs) to develop the SC-CO2 estimates and recommended four global values for use in 

regulatory analyses. The SC-CO2 estimates were first released in February 2010 and updated in 

2013 using new versions of each IAM. The 2013 update did not revisit the 2010 modeling 

decisions with regards to the discount rate, reference case socioeconomic and emission scenarios, 
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4-6 

and equilibrium climate sensitivity distribution. Rather, improvements in the way damages are 

modeled are confined to those that have been incorporated into the latest versions of the models 

by the developers themselves and published in the peer-reviewed literature. The 2010 SC-CO2

Technical Support Document (2010 SC-CO2 TSD) provides a complete discussion of the 

methods used to develop these estimates and the current SC-CO2 TSD presents and discusses the 

2013 update (including recent minor technical corrections to the estimates).16 

The 2010 SC-CO2 TSD noted a number of limitations to the SC-CO2 analysis, including 

the incomplete way in which the IAMs capture catastrophic and non-catastrophic impacts, their 

incomplete treatment of adaptation and technological change, uncertainty in the extrapolation of 

damages to high temperatures, and assumptions regarding risk aversion. Currently IAMs do not 

assign value to all of the important physical, ecological, and economic impacts of climate change 

recognized in the climate change literature due to a lack of precise information on the nature of 

damages and because the science incorporated into these models understandably lags behind the 

most recent research. Nonetheless, these estimates and the discussion of their limitations 

represent the best available information about the social benefits of CO2 reductions to inform 

benefit-cost analysis; see RIA of this rule and the SC-CO2 TSDs for additional details. The new 

versions of the models offer some improvements in these areas, although further work is 

warranted. 

Accordingly, EPA and other agencies continue to engage in research on modeling and 

valuation of climate impacts with the goal to improve these estimates. The EPA and other 

agencies also continue to consider feedback on the SC-CO2 estimates from stakeholders through 

a range of channels, including public comments on Agency rulemakings that use the SC-CO2 in 

supporting analyses and through regular interactions with stakeholders and research analysts 

implementing the SC-CO2 methodology used by the interagency working group. In addition, 

OMB’s Office of Information and Regulatory Affairs sought public comment on the approach 

 

16 Both the 2010 SC-CO2 TSD and the current TSD are available at: https://www.whitehouse.gov/omb/oira/socialcost-of-carbonhttps://www.whitehouse.gov/omb/inforeg_regpol_agency_review. 
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used to develop the SC-CO2 estimates through a separate comment period that ended on 

February 26, 2014. 

After careful evaluation of the full range of comments, the interagency working group 

continues to recommend the use of the SC-CO2 estimates in regulatory impact analysis. With 

the release of the response to comments, the interagency working group announced plans to 

obtain expert independent advice from the National Academiesy of Sciences, Engineering, and 

Medicine to ensure that the SC-CO2 estimates continue to reflect the best available scientific and 

economic information on climate change. The NRC Academies review will be informed by the 

public comments received and focus on the technical merits and challenges of potential 

approaches to improving the SC-CO2 estimates in future updates. 

Concurrent with OMB’s publication of the response to comments on SC-CO2 and 

announcement of the NRC Academies process, OMB posted a revised TSD that includes two 

minor technical corrections to the current estimates. 17 One technical correction addressed an 

inadvertent omission of climate change damages in the last year of analysis (2300) in one model 

and the second addressed a minor indexing error in another model. On average the revised SCCO2 estimates are one dollar less than the mean SC-CO2 estimates reported in the November 

2013 TSD. The change in the estimates associated with the 95th percentile estimates when using 

a 3% discount rate is slightly larger, as those estimates are heavily influenced by the results from 

the model that was affected by the indexing error. 

The four SC-CO2 estimates are: $15, $50, $73, and $150 per metric ton of CO2 emissions 

in the year 2025 (2012 dollars).18 The first three values are based on the average SC-CO2 from 

the three IAMs, at discount rates of 5, 3, and 2.5 percent, respectively. Estimates of the SC-CO2

for several discount rates are included because the literature shows that the SC-CO2 is sensitive 

 

17 See https://www.whitehouse.gov/omb/oira/social-cost-of-carbon for the response to comments, the blog post 

announcing the Academies’ process, and the current TSD. 

18 The current version of the SCC TSD is available at: 

https://www.whitehouse.gov/omb/inforeg_regpol_agency_review. The TSDs present SC-CO2 in $2007. The 

estimates were adjusted to 2012$ using the GDP Implicit Price Deflator. Also available at: 

http://www.gpo.gov/fdsys/pkg/ECONI-2013-02/pdf/ECONI-2013-02-Pg3.pdf. The SC-CO2 values have been 

rounded to two significant digits. Unrounded numbers from the 2013 SCC TSD were adjusted to 2012$ and used 

to calculate the CO2 benefits. 
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4-8 

to assumptions about the discount rate, and because no consensus exists on the appropriate rate 

to use in an intergenerational context (where costs and benefits are incurred by different 

generations). The fourth value is the 95th percentile of the SC-CO2 across all three models at a 

3% discount rate. It is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SC-CO2 distribution. The SC-CO2 increases over time 

because future emissions are expected to produce larger incremental damages as economies grow 

and physical and economic systems become more stressed in response to greater climate change. 

A challenge particularly relevant to this proposal is that the IWG did not estimate the 

social costs of non-CO2 GHG emissions at the time the SC-CO2 estimates were developed. One 

alternative approach to value methane impacts is to use the global warming potential (GWP) to 

convert the emissions to CO2 equivalents which are then valued using the SC-CO2 estimates. 

The GWP measures the cumulative radiative forcing from a perturbation of a non-CO2

GHG relative to a perturbation of CO2 over a fixed time horizon, often 100 years. The GWP 

mainly reflects differences in the radiative efficiency of gases and differences in their 

atmospheric lifetimes. While the GWP is a simple, transparent, and well-established metric for 

assessing the relative impacts of non-CO2 emissions compared to CO2 on a purely physical basis, 

there are several well-documented limitations in using it to value non-CO2 GHG benefits, as 

discussed in the 2010 SCC TSD and previous rulemakings (e.g., EPA 2012b, 2012d).19 In 

particular, several recent studies found that GWP-weighted benefit estimates for methane are 

likely to be lower than the estimates derived using directly modeled social cost estimates for 

these gases. Gas comparison metrics, such as the GWP, are designed to measure the impact of 

non-CO2 GHG emissions relative to CO2 at a specific point along the pathway from emissions to 

monetized damages (depicted in Figure 4-1), and this point may differ across measures. 

 

19 See also Reilly and Richards 1993; Schmalensee 1993; Fankhauser 1994; Marten and Newbold 2012. 
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4-9 

Figure 4-1 Path from GHG Emissions to Monetized Damages (Source: Marten et al., 

2014) 

The GWP is not ideally suited for use in benefit-cost analyses to approximate the social 

cost of non-CO2 GHGs because it ignores important nonlinear relationships beyond radiative 

forcing in the chain between emissions and damages. These can become relevant because gases 

have different lifetimes and the SC-CO2 takes into account the fact that marginal damages from 

an increase in temperature are a function of existing temperature levels. Another limitation of gas 

comparison metrics for this purpose is that some environmental and socioeconomic impacts are 

not linked to all of the gases under consideration, or radiative forcing for that matter, and will 

therefore be incorrectly allocated. For example, the economic impacts associated with increased 

agricultural productivity due to higher atmospheric CO2 concentrations included in the SC-CO2

would be incorrectly allocated to methane emissions with the GWP-based valuation approach. 

Also of concern, is the fact that the assumptions made in estimating the GWP are not 

consistent with the assumptions underlying SC-CO2 estimates in general, and the SC-CO2

estimates developed by the IWG specifically. For example, the 100 year time horizon usually 

used in estimating the GWP is less than the 300 year horizon the IWG used in developing the 

SC-CO2 estimates. The GWP approach also treats all impacts within the time horizon equally, 

independent of the time at which they occur. This is inconsistent with the role of discounting in 

economic analysis, which accounts for a basic preference for earlier over later gains in utility and 

expectations regarding future levels of economic growth. In the case of methane, which has a 

relatively short lifetime compared to CO2, the temporal independence of the GWP could lead the 
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4-10 

GWP approach to underestimate the SC-CH4 with a larger downward bias under higher discount 

rates (Marten and Newbold 2012).20 

EPA sought public comments on the valuation of non-CO2 GHG impacts in previous 

rulemakings (EPA, 2012b; EPA, 2012d). In general, the commenters strongly encouraged EPA 

to incorporate the monetized value of non-CO2 GHG impacts into the benefit cost analysis, 

however they noted the challenges associated with the GWP-approach, as discussed above, and 

encouraged the use of directly-modeled estimates of the SC-CH4 to overcome those challenges. 

EPA had cited several researchers that had directly estimated the social cost of non-CO2

emissions using IAMs but noted that the number of such estimates was small compared to the 

large number of SC-CO2 estimates available in the literature. EPA found considerable variation 

among these published estimates in terms of the models and input assumptions they employ 

(EPA, 2012b; EPA, 2012d). These studies differed in the emissions perturbation year, employed 

a wide range of constant and variable discount rate specifications, and considered a range of 

baseline socioeconomic and emissions scenarios that have been developed over the last 20 years. 

Furthermore, at the time, none of the other published estimates of the social cost of non-CO2

GHG were consistent with the SC-CO2 estimates developed by the IWG, and most were likely 

underestimates due to changes in the underlying science since their publication. 

Therefore, EPA concluded that the GWP approach would serve as an interim method of 

analysis until directly modeled social cost estimates for non-CO2 GHGs, consistent with the SCCO2 estimates developed by the IWG, were developed. EPA presented GWP-weighted estimates 

in sensitivity analyses rather than the main benefit-cost analyses. 

Since then, a paper by Marten et al. (2014) has provided the first set of published SC-CH4

estimates in the peer-reviewed literature that are consistent with the modeling assumptions 

underlying the SC-CO2 estimates.21 Specifically, the estimation approach of Marten et al. used 

 

20 We note that the truncation of the time period in the GWP calculation could lead to an overestimate of SC-CH4 for 

near term perturbation years in cases where the SC-CO2 is based on a sufficiently low or steeply declining 

discount rate. 

21 Marten et al. (2014) also provided the first set of SC-N2O estimates that are consistent with the assumptions 

underlying the SC-CO2 estimates. 

Commented [A17]: OMB RIA comment 24: Reviewer 

recomends providing a citation for Marten and Newbold 2012, 

which is not in the reference list. See 4-10. 

EPA response: Updated the reference list. 

Commented [A18]: OMB RIA Comment 23: Reviewer 

recommends on 4-9 footnoting that the bias is unknown for other 

GHG. 

EPA Response: Both the text and footnote are written to be specific 

to methane rather than non-GHGs more broadly. Given that this text 

is precise and does not make any suggestions about other non-CO2 

GHGs and that the rulemaking has no implications for other nonCO2 GHGs, we recommend leaving the text unchanged. Other 

GHGs are not relevant to this section. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-11 

the same set of three IAMs, five socioeconomic and emissions scenarios, equilibrium climate 

sensitivity distribution, three constant discount rates, and aggregation approach used by the IWG 

to develop the SC-CO2 estimates. The aggregation method involved distilling the 45 distributions 

of the SC-CH4 produced for each emissions year into four estimates: the mean across all models 

and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95th percentile 

of the pooled estimates from all models and scenarios using a 3 percent discount rate. The 

atmospheric lifetime radiative efficacy of methane used by Marten et al. is based on the estimates 

reported by the IPCC in their Fourth Assessment Report (AR4, 2007), including an adjustment in 

the radiative efficacy of methane to account for its role as a precursor for tropospheric ozone and 

stratospheric water. These values represent the same ones used by in the IPCC in AR4 for 

calculating GWPs. At the time Marten et al. developed their estimates of the SC-CH4, AR4 was 

the latest assessment report by the IPCC. The IPCC updates GWP estimates with each new 

assessment, and in the latest assessment, AR5, the latest estimate of the methane GWP ranged 

from 28-36, compared to a GWP of 25 in AR4. The updated values reflect a number of changes: 

changes in the lifetime and radiative efficiency estimates for CO2, changes in the lifetime 

estimate for methane, and changes in the correction factor applied to methane’s GWP to reflect 

the effect of methane emissions on other climatically important substances such as tropospheric 

ozone and stratospheric water vapor. In addition, the range presented in the latest IPCC report 

reflects different choices regarding whether to account for how biogenic and fossil methane have 

different carbon cycle effects, and for whether to account for climate feedbacks on the carbon 

cycle for both methane and carbon dioxide (rather than just for carbon dioxide as was done in 

AR4).22,23 

 

22 Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment 

Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, 

S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, 

Cambridge, United Kingdom and New York, NY, USA. 

23 Note that this proposal uses a GWP value for methane of 25 for CO2 equivalency calculations, consistent with the 

GHG emissions inventories and the IPCC Fourth Assessment Report. 
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4-12 

Marten et al. (2014) discuss these estimates (SC-CH4 estimates presented below in Table 

4-2), and compare them with other recent estimates in the literature.24 The authors noted that a 

direct comparison of their estimates with all of the other published estimates is difficult, given 

the differences in the models and socioeconomic and emissions scenarios, but results from three 

relatively recent studies offer a better basis for comparison (see Hope (2006), Waldhoff et al. 

(20141), Marten and Newbold (2012)). Marten et al. found that in general the SC-CH4 estimates 

from their 2014 paper are higher than previous estimates. The higher SC-CH4 estimates are 

partially driven by the higher effective radiative forcing due to the inclusion of indirect effects 

from methane emissions in their modeling. Marten et al., similar to other recent studies, also find 

that their directly modeled SC-CH4 estimates are higher than the GWP-weighted estimates. 

More detailed discussion of the SC-CH4 estimation methodology, results and a comparison to 

other published estimates can be found in Marten et al. 

Table 4-2 Social Cost of CH4, 2012 – 2050a [in 2012$ per metric ton] (Source: Marten et 

al., 2014b) 

Year 

SC-CH4

5% 

Average 

3% 

Average 

2.5% 

Average 

3% 

95th percentile 

2012 $430 $1,000 $1,400 $2,800 

2015 $490 $1,100 $1,500 $3,000 

2020 $580 $1,300 $1,700 $3,500 

2025 $700 $1,500 $1,900 $4,000 

2030 $820 $1,700 $2,200 $4,500 

2035 $970 $1,900 $2,500 $5,300 

2040 $1,100 $2,200 $2,800 $5,900 

2045 $1,300 $2,500 $3,000 $6,600 

2050 $1,400 $2,700 $3,300 $7,200 

a

 The values are emissions-year specific and are defined in real terms, i.e., adjusted for inflation using the GDP 

implicit price deflator. 

b

 The estimates in this table have been adjusted to reflect the minor technical corrections to the SC-CO2 estimates 

described above. See erratum for more details. 

 

24 Marten et al. (2014) estimates are presented in 2007 dollars. These estimates were adjusted for inflation using 

National Income and Product Accounts Tables, Table 1.1.9, Implicit Price Deflators for Gross Domestic Product 

(US Department of Commerce, Bureau of Economic Analysis), http://www.bea.gov/iTable/index_nipa.cfm 

Accessed 3/3/15. 

Formatted: Not Highlight

Commented [A19]: OP should be able to provide complete 

citation for erratum by the end of the week. 
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4-13 

The application of directly modeled estimates from Marten et al. (2014) to benefit-cost 

analysis of a regulatory action is analogous to the use of the SC-CO2 estimates. Specifically, the 

SC-CH4 estimates in Table 4-2 are used to monetize the benefits of reductions in methane 

emissions expected as a result of the proposed rulemaking. Forecast changes in methane 

emissions in a given year, expected as a result of the proposed regulatory action, are multiplied 

by the SC-CH4 estimate for that year. To obtain a present value estimate, the monetized stream 

of future non-CO2 benefits are discounted back to the analysis year using the same discount rate 

used to estimate the social cost of the non-CO2 GHG emission changes. In addition, the 

limitations for the SC-CO2 estimates discussed above likewise apply to the SC-CH4 estimates, 

given the consistency in the methodology. 

EPA recently conducted a peer review of the application of the Marten et al. (2014) nonCO2 social cost estimates in regulatory analysis and received responses that supported this 

application. Three reviewers considered seven charge questions that covered issues such as the 

EPA’s interpretation of the Marten et al. estimates, the consistency of the estimates with the SCCO2 estimates, EPA’s characterization of the limits of the GWP-approach to value non-CO2

GHG impacts, and the appropriateness of using the Marten et al. estimates in regulatory impact 

analyses. The reviewers agreed with EPA’s interpretation of Marten et al.’s estimates; generally 

found the estimates to be consistent with the SC-CO2 estimates; and concurred with the 

limitations of the GWP approach, finding directly modeled estimates to be more appropriate. 

While outside of the scope of the review, the reviewers briefly considered the limitations in the 

SC-CO2 methodology (e.g., those discussed earlier in this section) and noted that because the 

SC-CO2 and SC-CH4 methodologies are similar, the limitations also apply to the resulting SCCH4 estimates. Two of the reviewers concluded that use in RIAs of the SC-CH4 estimates 

developed by Marten et al. and published in the peer-reviewed literature is appropriate, provided 

that the Agency discuss the limitations, similar to the discussion provided for SC-CO2 and other 

economic analyses. All three reviewers encouraged continued improvements in the SC-CO2

estimates and suggested that as those improvements are realized they should also be reflected in 

the SC-CH4 estimates, with one reviewer suggesting the SC-CH4 estimates lag this process. EPA 

supports continued improvement in the SC-CO2 estimates developed by the U.S. government and 
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4-14 

agrees that improvements in the SC-CO2 estimates should also be reflected in the SC-CH4

estimates. The fact that the reviewers agree that the SC-CH4 estimates are generally consistent 

with the SC-CO2 estimates that are recommended by OMB’s guidance on valuing CO2 emissions 

reductions leads EPA to conclude that use of the SC-CH4 estimates is an analytical improvement 

over excluding methane emissions from the monetized portion of the benefit cost analysis. 

In light of the favorable peer review and past comments urging EPA to value non-CO2

GHG impacts in its rulemakings, the Agency has used the Marten et al. (2014) SC-CH4 estimates 

to value methane impacts expected from this proposed rulemaking and has included those 

benefits in the main benefits analysis. EPA seeks comments on the use of these directly modeled 

estimates, from the peer-reviewed literature, for the social cost of non-CO2 GHG. 

The methane benefits calculated using Marten et al. (2014) are presented below in Table 

4-3 for 2025. Applying this approach to the methane reductions estimated for this proposal, the 

2025 methane benefits vary by discount rate and range from about $310 million to approximately 

$1.7 billion; for the proposed option, the mean SC-CH4 at the 3% discount rate results in an 

estimate of about $660 million in 2025. 

Table 4-3 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.27 6.8 $190 $410 $530 $1,100 

Proposed Option 2.5/34 0.44 11 $310 $660 $850 $1,700 

Alternative Option 2.0/34 0.48 12 $340 $720 $930 $1,900 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

While the vast majority of this proposal’s climate-related benefits are associated with 

methane reductions, additional climate-related benefits are expected from the proposal’s 

secondary air impacts, specifically, a net reduction in CO2 emissions due to reduced demand for 
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4-15 

electricity from the grid as landfills generate electricity from landfill gas.25 These benefits are 

presented in Table 4-4 below. Monetizing the net CO2 reductions with the SC-CO2 estimates 

described in this section yields benefits that vary by discount rate and range from about $3.6 

million to approximately $36 million in 2025. For the proposed option, the mean SC-CO2 at the 

3% discount rate results in an estimate of about $12 million in 2025, which is about 2 percent of 

the estimated methane benefits in 2025 (average SC-CH4, 3 percent discount rate). 

Table 4-4 Estimated Global Benefits of Net CO2 Reductions in 2025* (in millions, 2012$) 

Metric tonnes of net 

CO2 reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 102,000 $1.5 $5.0 $7.5 $15 

Proposed Option 2.5/34 238,000 $3.6 $12 $18 $36 

Alternative Option 2.0/34 238,000 $3.6 $12 $18 $36 

*The SC-CO2 values are dollar-year and emissions-year specific. SC-CO2 values represent only a partial 

accounting of climate impacts.

Finally, in addition to the CO2 impacts discussed above, there is a small increase in CO2

emissions resulting from flaring of methane in response to this rule. We are not estimating the 

monetized disbenefits of these secondary emissions of CO2 because much of the methane that 

would have been released in the absence of the flare would have eventually oxidized into CO2 in 

the atmosphere. Note that the CO2 produced from the methane oxidizing in the atmosphere is not 

included in the calculation of the SC-CH4. 

However, EPA does recognize that because the growth rate of the SC-CO2 estimates are 

lower than their associated discount rates, the estimated impact of CO2 produced in the future 

from oxidized methane would be less than the estimated impact of CO2 released immediately 

from flaring, which would imply a small disbenefit associated with flaring. Assuming an average 

methane oxidation period of 8.7 years, consistent with the lifetime used in IPCC AR4, the 

 

25 The reduced demand for electricity from the grid more than offsets the additional energy demand required to 

operate the control system and the by-product emissions from the combustion of LFG. 

Commented [A20]: This discussion added in response to 

question during OMB call. 
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4-16 

disbenefits associated with destroying one metric ton of methane and releasing the CO2

emissions in 2020 instead of being released in the future via the methane oxidation process is 

estimated to be $5 to $25 per metric ton CH4 depending on the SC-CO2 value or 0.7 percent to 

0.9 percent of the SC-CH4 estimates per metric ton for 2020. The analogous estimates for 2025 

are $7 to $34 per metric ton CH4 or 0.8 percent to 1.0 percent of the SC-CH4 estimates per metric 

ton for 2025.26 While EPA is not accounting for the CO2 disbenefits at this time, we request 

comment on the appropriateness of the monetization of such impacts using the SC-CO2 and 

aspects of the calculation.

4.2.2 Methane as an ozone precursor 

This rulemaking would reduce emissions of methane, a GHG and also a precursor to 

ozone. In remote areas, methane is a dominant precursor to tropospheric ozone formation (EPA, 

2013). Approximately 40% of the global annual mean ozone increase since preindustrial times is 

believed to be due to anthropogenic methane (HTAP, 2010). Projections of future emissions also 

indicate that methane is likely to be a key contributor to ozone concentrations in the future 

(HTAP, 2010). Unlike NOX and VOC, which affect ozone concentrations regionally and at 

hourly time scales, methane emissions affect ozone concentrations globally and on decadal time 

scales given methane’s relatively long atmospheric lifetime (HTAP, 2010). Reducing methane 

emissions, therefore, can reduce global background ozone concentrations, human exposure to 

ozone, and the incidence of ozone-related health effects (West et al., 2006, Anenberg et al., 2009, 

Sarofim et al., 2015). These benefits are global and occur in both urban and rural areas. 

Reductions in background ozone concentrations can also have benefits for agriculture and 

ecosystems (UNEP/WMO, 2011). Studies show that controlling methane emissions can reduce 

global ozone concentrations and climate change simultaneously, but controlling other shorterlived ozone precursors such as NOX, carbon monoxide, or non-methane VOC has larger local 

 

26 To calculate the disbenefits associated the complete destruction of a ton of CH4 through flaring, EPA took the 

difference between the SC-CO2 at the time of the flaring and in 8.7 years and discounted that value to the time of 

the flaring using the same discount rate as used to estimate the SC-CO2. This value was then scaled by 44/16 to 

account for the relative mass of carbon contained in a ton of CH4 versus a ton of CO2. The value of the SC-CO2

8.7 years after flaring was estimated by linearly interpolating between the annual SC-CO2 estimates reported in 

the TSD and inflated to 2012 dollars.
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4-17 

health benefits from greater reductions in local ozone concentrations (West and Fiore, 2005; 

West et al., 2006; Fiore et al. 2008; Dentener et al., 2005; Shindell et al., 2005, 2012; 

UNEP/WMO, 2011). The health, welfare, and climate effects associated with ozone are 

described in the preceding sections. Without air quality modeling, we are unable to estimate the 

effect that reducing methane will have on ozone concentrations at particular locations.Examining 

mortality benefits in isolation, However, the global monetized benefit of ozone reduction due to 

methane mitigation have been estimated to be on the order of $1000 per metric ton of methane 

emissions reducedin several studies (Anenberg et al., 2012; Shindell et al., 2012), an estimate 

similar in magnitude to the climate benefits of methane reductions estimated by the Marten et al. 

(2014) or GWP methods.

Recently, a paper was published in the peer-reviewed scientific literature that presented a 

range of estimates of the monetized ozone-related mortality benefits of reducing methane 

emissions (Sarofim et al. 2015). For example, under their base case assumptions using a 3% 

discount rate, Sarofim et al. find global ozone-related mortality benefits of methane emissions 

reductions to be $790 per tonne of methane in 2020, with 10.6%, or $80, of this amount resulting 

from mortality reductions in the United States. The methodology used in this study is consistent 

in some (but not all) aspects with the modeling underlying the SC-CO2 and SC-CH4 estimates 

discussed above, and required a number of additional assumptions such as baseline mortality 

rates and mortality response to ozone concentrations. The Sarofim et al. (2015) study may have 

implications for this benefits analysis as it provides a potential approach to estimating the ozone 

related mortality benefits resulting from the methane reductions expected from this proposed 

rulemaking. The EPA requests comment on Sarofim et al.’s approach to estimating the ozone 

related mortality benefits of methane emissions reductions, including technical considerations in 

applying their methodology to this regulatory impact analysis. 

4.2.3 Combined methane climate and ozone effects of methane

A recent United Nations Environment Programme (UNEP) assessment provided a 

comprehensive analysis of the health, climate, and agricultural benefits of measures to reduce 

methane, as well as black carbon, a component of fine particulate matter that absorbs radiation 

Commented [A21]: Updated based on recently published 

research. 
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(UNEP/WMO, 2011; Shindell et al., 2012). The UNEP assessment found that while reducing 

longer-lived GHGs such as CO2 is necessary to protect against long-term climate change, 

reducing global methane and black carbon emissions would have global health benefits by 

reducing exposure to ozone and PM2.5 as well as potentially slowing the rate of climate change 

within the first half of this century. Relative to a business as usual reference scenario, 

implementing methane mitigation measures that achieve approximately 40% reductions in global 

methane emissions were estimated to avoid approximately 0.3°C globally averaged warming in 

2050 (including the impacts of both methane itself and subsequently formed ozone) and 47,000 

ozone-related premature deaths and 27 million metric tons of ozone-related crop yield losses 

globally in 2030 (Shindell et al., 2012). These benefits, including global climate impacts of 

methane and resulting ozone changes, and global ozone-related health and agricultural impacts, 

were valued at $700 to $5,000 per metric ton.27 The methane measures examined include 

extended methane recovery/utilization and reduced fugitive emissions from oil and gas 

production, which contributed the greatest climate benefit of all methane mitigation measures in 

North America and Europe (UNEP, 2011). Examining mortality benefits in isolation, the 

monetized benefit of ozone reduction due to methane mitigation have been estimated to be on the 

order of $1000 per metric ton of methane emissions reduced (Anenberg et al., 2012; Shindell et 

al., 2012), an estimate similar in magnitude to the climate benefits of methane reductions 

estimated by the Marten et al. (2014) or GWP methods. While monetized per-ton benefits of the 

climate, health, and agriculture impacts of methane mitigation have been estimated, there has not 

yet been a similar monetization of the parallel impacts on broader ecosystems. EPA continues to 

monitor developments in this area of research, but is not yet utilizing monetized estimates of the 

benefits of methane mitigation on mortality and agriculture due to ozone reductions. 

 

27 Benefit per ton values derived from Shindell et al. (2012) cannot be directly compared to, nor are they additive 

with, the ozone health benefit-per-ton estimates for the U.S. reported in Section 4.4.1, since they include climate 

and agricultural impacts, are calculated for global rather than U.S. impacts, and use different assumptions for the 

value of a statistical life. Similarly, these values cannot be compared to, nor are they additive with, the methane 

climate valuation estimates in Section 4.2.1 since they include health and agricultural benefits and use different 

assumptions for the Social Cost of Carbon. 
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4.3 VOC as a PM2.5 precursor 

This rulemaking would reduce emissions of VOC, which are a precursor to PM2.5. Most 

VOC emitted are oxidized to carbon dioxide (CO2) rather than to PM, but a portion of VOC 

emission contributes to ambient PM2.5 levels as organic carbon aerosols (EPA, 2009a). 

Therefore, reducing these emissions would reduce PM2.5 formation, human exposure to PM2.5, 

and the incidence of PM2.5-related health effects. However, we have not quantified the PM2.5-

related benefits in this analysis. Analysis of organic carbon measurements suggest only a 

fraction of secondarily formed organic carbon aerosols are of anthropogenic origin. The current 

state of the science of secondary organic carbon aerosol formation indicates that anthropogenic 

VOC contribution to secondary organic carbon aerosol is often lower than the biogenic (natural) 

contribution. Given that a fraction of secondarily formed organic carbon aerosols is from 

anthropogenic VOC emissions and the extremely small amount of VOC emissions from this 

sector relative to the entire VOC inventory it is unlikely this sector has a large contribution to 

ambient secondary organic carbon aerosols. Photochemical models typically estimate secondary 

organic carbon from anthropogenic VOC emissions to be less than 0.1 μg/m3. 

Data resources and methodological limitations prevented EPA from monetizing the 

benefits of reducing VOCs. We were unable to perform air quality modeling for this rule to 

quantify the PM2.5 benefits associated with reducing VOC emissions. Due to the high degree of 

variability in the responsiveness of PM2.5 formation to VOC emission reductions, we are unable 

to estimate the effect that reducing VOC will have on ambient PM2.5 levels without air quality 

modeling. However, we provide the discussion below for context regarding findings from 

previous modeling. 

4.3.1 PM2.5 health effects and valuation 

Reducing VOC emissions would reduce PM2.5 formation, human exposure, and the 

incidence of PM2.5-related health effects. Reducing exposure to PM2.5 is associated with 

significant human health benefits, including avoiding mortality and respiratory morbidity. 

Researchers have associated PM2.5 exposure with adverse health effects in numerous 

toxicological, clinical and epidemiological studies (EPA, 2009a). When adequate data and 

resources are available, EPA generally quantifies several health effects associated with exposure 
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to PM2.5 (e.g., EPA, 2011d). These health effects include premature mortality for adults and 

infants, cardiovascular morbidity such as heart attacks, hospital admissions, and respiratory 

morbidity such as asthma attacks, acute and chronic bronchitis, hospital and ER visits, work loss 

days, restricted activity days, and respiratory symptoms. Although EPA has not quantified these 

effects in previous benefits analyses, the scientific literature suggests that exposure to PM2.5 is 

also associated with adverse effects on birth weight, pre-term births, pulmonary function, other 

cardiovascular effects, and other respiratory effects (EPA, 2009a). 

When EPA quantifies PM2.5-related benefits, the Agency assumes that all fine particles, 

regardless of their chemical composition, are equally potent in causing premature mortality 

because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by 

particle type (EPA, 2009a). Based on our review of the current body of scientific literature, EPA 

estimates PM-related mortality without applying an assumed concentration threshold. This 

decision is supported by the data, which are quite consistent in showing effects down to the 

lowest measured levels of PM2.5 in the underlying epidemiology studies. 

Previous studies have estimated the monetized benefits-per-ton of reducing VOC 

emissions associated with the effect that those emissions have on ambient PM2.5 levels and the 

health effects associated with PM2.5 exposure (Fann, Fulcher, and Hubbell, 2009), and these 

estimates can provide useful context for this rulemaking. Using the estimates in Fann, Fulcher, 

and Hubbell (2009), the monetized benefit-per-ton of reducing VOC emissions in nine urban 

areas of the U.S. ranges from $560 in Seattle, WA to $5,700 in San Joaquin, CA, with a national 

average of $2,400. These estimates assume a 50 percent reduction in VOC, the Laden et al. 

(2006) mortality function (based on the Harvard Six Cities study, a large cohort epidemiology 

study in the Eastern U.S.), an analysis year of 2015, a 3% discount rate, and 2006$. 

 Additional benefit-per-ton estimates are available from this dataset using alternate 

assumptions regarding the relationship between PM2.5 exposure and premature mortality from 

empirical studies and supplied by experts (e.g., Pope et al., 2002; Laden et al., 2006; Roman et 

al., 2008). EPA generally presents a range of benefits estimates derived from the American 

Cancer Society cohort (e.g., Pope et al., 2002; Krewski et al., 2009) to the Harvard Six Cities 

cohort (e.g., Laden et al., 2006; Lepuele et al., 2012) because the studies are both well-designed 
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and extensively peer reviewed, and EPA provides the benefit estimates derived from expert 

opinions in Roman et al. (2008) as a characterization of uncertainty. As shown in Table 4-5Table 

4-5, the range of VOC benefits that reflects the range of epidemiology studies and the range of 

the urban areas is $300 to $7,500 per ton of VOC reduced (2012$).28 Since these estimates were 

presented in the 2012 Oil and Gas NSPS RIA (EPA, 2012b), we updated our methods to apply 

more recent epidemiological studies for these cohorts (i.e., Krewski et al., 2009; Lepeule et al., 

2012) as well as additional updates to the morbidity studies and population data.29 Because these 

updates would not lead to significant changes in the benefit-per-ton estimates for VOC, we have 

not updated them here. 

While these ranges of benefit-per-ton estimates provide useful context, the geographic 

distribution of VOC emissions from the MSW landfill sector are not consistent with emissions 

modeled in Fann, Fulcher, and Hubbell (2009). In addition, the benefit-per-ton estimates for 

VOC emission reductions in that study are derived from total VOC emissions across all sectors. 

Coupled with the larger uncertainties about the relationship between VOC emissions and PM2.5, 

these factors lead the EPA to conclude that the available VOC benefit per ton estimates are not 

appropriate to calculate monetized benefits of this rule, even as a bounding exercise. 

 

28 We also converted the estimates from Fann, Fulcher, and Hubbell (2009) to 2012$ and applied EPA’s current 

value of a statistical life (VSL) estimate. For more information regarding EPA’s current VSL estimate, please see 

Section 5.6.5.1 of the RIA for the PM NAAQS RIA (EPA, 2012c). EPA continues to work to update its 

guidance on valuing mortality risk reductions. 

29 For more information regarding these updates, please see Section 5.3 of the RIA for the final PM NAAQS (EPA, 

2012c). 
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Table 4-5 Monetized Benefits-per-Ton Estimates for VOC based on Previous Modeling in 2015 (2012$) 

Area Pope et al. (2002) Laden et al. (2006) Expert A Expert B Expert C Expert D Expert E Expert F Expert G Expert H Expert I Expert J Expert K Expert L 

Atlanta $660 $1,600 $1,700 $1,300 $1,300 $920 $2,100 $1,200 $780 $980 $1,300 $1,000 $260 $1,000

Chicago $1,600 $4,000 $4,200 $3,300 $3,200 $2,300 $5,300 $3,000 $1,900 $2,400 $3,200 $2,600 $640 $2,500

Dallas $320 $790 $830 $650 $630 $450 $1,000 $580 $380 $480 $630 $510 $130 $490 

Denver $770 $1,900 $2,000 $1,500 $1,500 $1,100 $2,400 $1,400 $910 $1,100 $1,500 $1,200 $300 $910 

NYC/ Philadelphia $2,300 $5,600 $5,900 $4,600 $4,500 $3,200 $7,300 $4,100 $2,700 $3,400 $4,500 $3,600 $890 $3,300

Phoenix $1,100 $2,700 $2,800 $2,200 $2,100 $1,500 $3,500 $2,000 $1,300 $1,600 $2,100 $1,700 $420 $1,600

Salt Lake $1,400 $3,300 $3,500 $2,700 $2,700 $1,900 $4,400 $2,500 $1,600 $2,000 $2,700 $2,200 $570 $2,100

San Joaquin $3,100 $7,500 $7,900 $6,100 $6,000 $4,300 $9,700 $5,500 $3,600 $4,500 $6,000 $4,900 $1,400 $4,600

Seattle $300 $730 $770 $570 $590 $420 $950 $540 $350 $440 $580 $470 $120 $350 

National average $1,300 $3,200 $3,400 $2,600 $2,600 $1,800 $4,200 $2,300 $1,500 $1,900 $2,500 $2,100 $520 $1,900

* These estimates assumed a 50 percent reduction in VOC emissions, an analysis year of 2015, and a 3 percent discount rate. All estimates are rounded to two 

significant digits. These estimates have been adjusted from Fann, Fulcher, and Hubbell (2009) to reflect a more recent currency year and EPA’s current VSL estimate. However, these estimates have not been updated to reflect recent epidemiological studies for mortality studies, morbidity studies, or population data. Using a discount rate of 7 percent, the benefit-per-ton estimates would be approximately 9 percent lower. Assuming a 75 percent reduction in VOC emissions would increase the benefit-per-ton estimates by approximately 4 percent to 52 percent. Assuming a 25 percent reduction in VOC emissions would decrease the benefit-per-ton estimates by 5 percent to 52 percent. EPA generally presents a range of benefits estimates derived from the expert functions from Roman et al. (2008) as a characterization of uncertainty. 
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4.3.2 Visibility Effects 

Reducing secondary formation of PM2.5 from VOC emissions would improve visibility 

throughout the U.S. Fine particles with significant light-extinction efficiencies include sulfates, 

nitrates, organic carbon, elemental carbon, and soil (Sisler, 1996). Suspended particles and gases 

degrade visibility by scattering and absorbing light. Higher visibility impairment levels in the 

East are due to generally higher concentrations of fine particles, particularly sulfates, and higher 

average relative humidity levels. Visibility has direct significance to people’s enjoyment of daily 

activities and their overall sense of wellbeing. Good visibility increases the quality of life where 

individuals live and work, and where they engage in recreational activities. Previous analyses 

(EPA, 2006b; EPA, 2011d; EPA, 2011a; EPA, 2012c) show that visibility benefits are a 

significant welfare benefit category. Without air quality modeling, we are unable to estimate 

visibility related benefits, nor are we able to determine whether VOC emission reductions would 

be likely to have a significant impact on visibility in urban areas or Class I areas. 

4.4 VOC as an Ozone Precursor 

This rulemaking would reduce emissions of VOC, which are also precursors to secondary 

formation of ozone. Ozone is not emitted directly into the air, but is created when its two 

primary components, volatile organic compounds (VOC) and oxides of nitrogen (NOX), react in 

the presence of sunlight. In urban areas, compounds representing all classes of VOC and CO are 

important compounds for ozone formation, but biogenic VOC emitted from vegetation tend to be 

more important compounds in non-urban vegetated areas (EPA, 2013). Therefore, reducing 

these emissions would reduce ozone formation, human exposure to ozone, and the incidence of 

ozone-related health effects. However, we have not quantified the ozone-related benefits in this 

analysis for several reasons. First, previous rules have shown that the monetized benefits 

associated with reducing ozone exposure are generally smaller than PM-related benefits, even 

when ozone is the pollutant targeted for control (EPA, 2010a; EPA, 2014a). Second, the 

complex non-linear chemistry of ozone formation introduces uncertainty to the development and 

application of a benefit-per-ton estimate, particularly for sectors with substantial new growth. 

Third, the impact of reducing VOC emissions is spatially heterogeneous depending on local air 
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chemistry. Urban areas with a high population concentration are often VOC-limited, which 

means that ozone is most effectively reduced by lowering VOC. Rural areas and downwind 

suburban areas are often NOX-limited, which means that ozone concentrations are most 

effectively reduced by lowering NOX emissions, rather than lowering emissions of VOC. 

Between these areas, ozone is relatively insensitive to marginal changes in both NOX and VOC. 

Due to data limitations, we did not perform air quality modeling for this rule needed to 

quantify the ozone benefits associated with reducing VOC emissions. Due to the high degree of 

variability in the responsiveness of ozone formation to VOC emission reductions and data 

limitations regarding the location of the emissions reductions, we are unable to estimate the 

effect that reducing VOC will have on ambient ozone concentrations without air quality 

modeling. 

4.4.1 Ozone health effects and valuation 

Reducing ambient ozone concentrations is associated with significant human health 

benefits, including mortality and respiratory morbidity (EPA, 2010a). Researchers have 

associated ozone exposure with adverse health effects in numerous toxicological, clinical and 

epidemiological studies (EPA, 2013). When adequate data and resources are available, EPA 

generally quantifies several health effects associated with exposure to ozone (e.g., EPA, 2010a; 

EPA, 2011a). These health effects include respiratory morbidity such as asthma attacks, hospital 

and emergency department visits, school loss days, as well as premature mortality. The scientific 

literature is also suggestive that exposure to ozone is also associated with chronic respiratory 

damage and premature aging of the lungs. 

In a recent EPA analysis, EPA estimated that reducing 15,000 tons of VOC from 

industrial boilers resulted in $3.6 to $15 million (2008$) of monetized benefits from reduced 

ozone exposure (EPA, 2011b).30 After updating the currency year to 2012$, this implies a 

benefit-per-ton for ozone of $260 to $1,070 per ton of VOC reduced. Since EPA conducted the 

 

30 While EPA has estimated the ozone benefits for many scenarios, most of these scenarios also reduce NOX

emissions, which make it difficult to isolate the benefits attributable to VOC reductions. 
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4-25 

analysis of industrial boilers, EPA published the Integrated Science Assessment for Ozone (EPA, 

2013), the Health Risk and Exposure Assessment for Ozone (EPA, 2014a), and the RIA for the 

proposed Ozone NAAQS (EPA, 2014b). Therefore, the ozone mortality studies applied in the 

boiler analysis, while current at that time, do not reflect the most updated literature available. 

The selection of ozone mortality studies used to estimate benefits in RIAs was revisited in the 

RIA for the proposed Ozone NAAQS. Applying the more recent studies would lead to benefitper-ton estimates for ozone within the range shown here. While these ranges of benefit-per-ton 

estimates provide useful context, the geographic distribution of VOC emissions from the MSW 

landfill sector are not consistent with emissions modeled in the boiler analysis. Therefore, we do 

not believe that those estimates to provide useful estimates of the monetized benefits of this rule, 

even as a bounding exercise. 

4.4.2 Ozone vegetation effects 

Exposure to ozone has been associated with a wide array of vegetation and ecosystem 

effects in the published literature (EPA, 2013a). Sensitivity to ozone is highly variable across 

species, with over 66 vegetation species identified as “ozone-sensitive”, many of which occur in 

state and national parks and forests. These effects include those that damage or impair the 

intended use of the plant or ecosystem. Such effects are considered adverse to the public welfare 

and can include reduced growth and/or biomass production in sensitive trees, reduced yield and 

quality of crops, visible foliar injury, species composition shift, and changes in ecosystems and 

associated ecosystem services. 

4.4.3 Ozone climate effects 

Ozone is a well-known short-lived climate forcing (SLCF) greenhouse gas (GHG) (EPA, 

2006a). Stratospheric ozone (the upper ozone layer) is beneficial because it protects life on Earth 

from the sun’s harmful ultraviolet (UV) radiation. In contrast, tropospheric ozone (ozone in the 

lower atmosphere) is a harmful air pollutant that adversely affects human health and the 

environment and contributes significantly to regional and global climate change. Due to its short 

atmospheric lifetime, tropospheric ozone concentrations exhibit large spatial and temporal 

variability (EPA, 2009b). A recent United Nations Environment Programme (UNEP) study 
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4-26 

reports that the threefold increase in ground level ozone during the past 100 years makes it the 

third most important contributor to human contributed climate change behind CO2 and methane. 

This quantifiable influence of ground level ozone on climate leads to increases in global surface 

temperature and changes in hydrological cycles. 

4.5 Hazardous Air Pollutant (HAP) Benefits 

Even though emissions of air toxics from all sources in the U.S. declined by approximately 

42 percent since 1990, the 2005 National-Scale Air Toxics Assessment (NATA) predicts that 

most Americans are exposed to ambient concentrations of air toxics at levels that have the 

potential to cause adverse health effects (EPA, 2011c).31 The levels of air toxics to which people 

are exposed vary depending on where they live and work and the kinds of activities in which 

they engage. In order to identify and prioritize air toxics, emission source types and locations 

that are of greatest potential concern, the U.S. EPA conducts the NATA. 32 The most recent 

NATA was conducted for calendar year 2005 and was released in March 2011. NATA includes 

four steps: 

1) Compiling a national emissions inventory of air toxics emissions from outdoor sources 

2) Estimating ambient concentrations of air toxics across the United States utilizing 

dispersion models 

3) Estimating population exposures across the United States utilizing exposure models 

4) Characterizing potential public health risk due to inhalation of air toxics including both 

cancer and noncancer effects 

 

31 The 2005 NATA is available on the Internet at http://www.epa.gov/ttn/atw/nata2005/.

32 The NATA modeling framework has a number of limitations that prevent its use as the sole basis for setting 

regulatory standards. These limitations and uncertainties are discussed on the 2005 NATA website. Even so, 

this modeling framework is very useful in identifying air toxic pollutants and sources of greatest concern, setting 

regulatory priorities, and informing the decision making process. U.S. EPA. (2011) 2005 National-Scale Air 

Toxics Assessment. http://www.epa.gov/ttn/atw/nata2005/

Commented [A22]: OMB RIA Comment 25: Reviewer 

recommends more specificity in the HAP benefits discussion on 4.5. 

If there are known HAP emissions please focus the discussion to 

those emissions. The current discussion doesn’t seem very relevant 

to these rulemakings. 

EPA Response: Section 4.5 only includes a qualitative discussion of 

four HAP that are known to be part of landfill gas: benzene, toluene, 

ethylbenzene, and vinyl chloride. Even though we cannot quantify 

the emission reductions of these HAP, we anticipate reduced 

exposure to them as a result of this rulemaking. The NATA 

discussion provides context for evaluating these qualitative HAP 

benefits. 
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4-27 

Based on the 2005 NATA, EPA estimates that about 5 percent of census tracts 

nationwide have increased cancer risks greater than 100 in a million. The average national 

cancer risk is about 50 in a million. Nationwide, the key pollutants that contribute most to the 

overall cancer risks are formaldehyde and benzene. 33,34 Secondary formation (e.g., formaldehyde 

forming from other emitted pollutants) was the largest contributor to cancer risks, while 

stationary, mobile and background sources contribute almost equal portions of the remaining 

cancer risk. 

Noncancer health effects can result from chronic,35 subchronic,36 or acute37 inhalation 

exposures to air toxics, and include neurological, cardiovascular, liver, kidney, and respiratory 

effects as well as effects on the immune and reproductive systems. According to the 2005 

NATA, about three-fourths of the U.S. population was exposed to an average chronic 

concentration of air toxics that has the potential for adverse noncancer respiratory health effects.

Results from the 2005 NATA indicate that acrolein is the primary driver for noncancer 

respiratory risk. 

Figure 4-2 and Figure 4-3 depict the estimated census tract-level carcinogenic risk and 

noncancer respiratory hazard from the assessment. It is important to note that large reductions in 

HAP emissions may not necessarily translate into significant reductions in health risk because 

toxicity varies by pollutant, and exposures may or may not exceed levels of concern. For 

 

33 Details on EPA’s approach to characterization of cancer risks and uncertainties associated with the 2005 NATA 

risk estimates can be found at http://www.epa.gov/ttn/atw/nata1999/riskbg.html#Z2. 

34 Details about the overall confidence of certainty ranking of the individual pieces of NATA assessments including 

both quantitative (e.g., model-to-monitor ratios) and qualitative (e.g., quality of data, review of emission 

inventories) judgments can be found at http://www.epa.gov/ttn/atw/nata/roy/page16.html. 

35 Chronic exposure is defined in the glossary of the Integrated Risk Information System (IRIS) database 

(http://www.epa.gov/iris) as repeated exposure by the oral, dermal, or inhalation route for more than 

approximately 10% of the life span in humans (more than approximately 90 days to 2 years in typically used 

laboratory animal species).

36 Defined in the IRIS database as repeated exposure by the oral, dermal, or inhalation route for more than 30 days, 

up to approximately 10% of the life span in humans (more than 30 days up to approximately 90 days in typically 

used laboratory animal species).

37 Defined in the IRIS database as exposure by the oral, dermal, or inhalation route for 24 hours or less. 
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example, acetaldehyde mass emissions were more than double acrolein emissions on a national 

basis in EPA’s 2005 National Emissions Inventory (NEI). However, the Integrated Risk 

Information System (IRIS) reference concentration (RfC) for acrolein is considerably lower than 

that for acetaldehyde, suggesting that acrolein could be potentially more toxic than 

acetaldehyde.38 Thus, it is important to account for the toxicity and exposure, as well as the mass 

of the targeted emissions. 

Figure 4-2 2005 NATA Model Estimated Census Tract Carcinogenic Risk from HAP 

Exposure from Emissions of All Outdoor Sources (inclusive of Residental Wood Heaters) 

based on the 2005 National Toxic Inventory. 

 

38 Details on the derivation of IRIS values and available supporting documentation for individual chemicals (as well 

as chemical values comparisons) can be found at http://cfpub.epa.gov/ncea/iris/compare.cfm. 

Commented [A23]: OMB RIA Comment 1: Reviewer 

recommends deleting the discussion in the RIA (starting on page 4-

25) because acrolein and acetaldehyde are HAPS but not key 

landfills gases. Further, the discussion of acrolein being “more 

toxic” is uncertain because there is no information about doseresponse. Without dose response, all that can be said is that adverse 

health effects can start to manifest at lower concentrations for 

acrolein than acetaldehyde. 

EPA Response: Text has been deleted. 
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4-29 

Figure 4-3 2005 NATA Model Estimated Census Tract Noncancer Risk from HAP 

Exposure from Emissions of All Outdoor Sources (inclusive of Residental Wood Heaters) 

based on the 2005 National Toxic Inventory 

Due to methodology and data limitations, we were unable to estimate the benefits 

associated with the hazardous air pollutants that would be reduced as a result of this rule. In a 

few previous analyses of the benefits of reductions in HAP, EPA has quantified the benefits of 

potential reductions in the incidences of cancer and noncancer risk (e.g., EPA, 1995). In those 

analyses, EPA relied on unit risk factors (URF) and reference concentrations (RfC) developed 

through risk assessment procedures. The URF is a quantitative estimate of the carcinogenic 

potency of a pollutant, often expressed as the probability of contracting cancer from a 70-year 

lifetime continuous exposure to a concentration of one μg/m3 of a pollutant. These URFs are 

designed to be conservative, and as such, are more likely to represent the high end of the 

distribution of risk rather than a best or most likely estimate of risk. 
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4-30 

An RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a 

continuous inhalation exposure to the human population (including sensitive subgroups) that is 

likely to be without an appreciable risk of deleterious noncancer health effects during a lifetime. 

As part of the second prospective analysis of the benefits and costs of the Clean Air Act (EPA, 

2011a), EPA conducted a case study analysis of the health effects associated with reducing 

exposure to benzene in Houston from implementation of the Clean Air Act (IEc, 2009). While 

reviewing the draft report, EPA’s Advisory Council on Clean Air Compliance Analysis 

concluded that “the challenges for assessing progress in health improvement as a result of 

reductions in emissions of hazardous air pollutants (HAP) are daunting...due to a lack of 

exposure-response functions, uncertainties in emissions inventories and background levels, the 

difficulty of extrapolating risk estimates to low doses and the challenges of tracking health 

progress for diseases, such as cancer, that have long latency periods” (EPA-SAB, 2008). 

In 2009, EPA convened a workshop to address the inherent complexities, limitations, and 

uncertainties in current methods to quantify the benefits of reducing HAP. Recommendations 

from this workshop included identifying research priorities, focusing on susceptible and 

vulnerable populations, and improving dose-response relationships (Gwinn et al., 2011). 

In summary, monetization of the benefits of reductions in cancer incidences requires 

several important inputs, including central estimates of cancer risks, estimates of exposure to 

carcinogenic HAP, and estimates of the value of an avoided case of cancer (fatal and non-fatal). 

Due to methodology and data limitations, we did not attempt to monetize the health benefits of 

reductions in HAP in this analysis. Instead, we provide a qualitative analysis of the health effects 

associated with the HAP anticipated to be reduced by this rule. EPA remains committed to 

improving methods for estimating HAP benefits by continuing to explore additional concepts of 

benefits, including changes in the distribution of risk. 

In the subsequent sections, we describe the health effects associated with the main HAP 

of concern from the MSW landfill sector: benzene, ethylbenzene, toluene, and vinyl chloride. 

This rule is anticipated to avoid or reduce 2,770 tons of NMOC per year. With the data 

available, it was not possible to estimate the tons of each individual HAP that would be reduced. 
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4-31 

Therefore, in addition to the reasons identified above, we cannot estimate the monetized benefits 

associated with reducing HAP emissions for this rule.

4.5.1 Benzene 

The EPA’s IRIS database lists benzene as a known human carcinogen (causing leukemia) 

by all routes of exposure, and concludes that exposure is associated with additional health effects, 

including genetic changes in both humans and animals and increased proliferation of bone marrow 

cells in mice.39,40,41 EPA states in its IRIS database that data indicate a causal relationship between 

benzene exposure and acute lymphocytic leukemia and suggest a relationship between benzene 

exposure and chronic non-lymphocytic leukemia and chronic lymphocytic leukemia. The IARC 

has determined that benzene is a human carcinogen and the U.S. Department of Health and Human 

Services has characterized benzene as a known human carcinogen.42,43

A number of adverse noncancer health effects including blood disorders, such as 

preleukemia and aplastic anemia, have also been associated with long-term exposure to 

benzene.44,45

 

39 U.S. Environmental Protection Agency (EPA). 2000. Integrated Risk Information System File for Benzene. 

Research and Development, National Center for Environmental Assessment, Washington, DC. This material is 

available electronically at: http://www.epa.gov/iris/subst/0276.htm. 

40 International Agency for Research on Cancer, IARC monographs on the evaluation of carcinogenic risk of 

chemicals to humans, Volume 29, Some industrial chemicals and dyestuffs, International Agency for Research 

on Cancer, World Health Organization, Lyon, France, p. 345-389, 1982. 

41 Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry, V.A. (1992) Synergistic action of the benzene metabolite 

hydroquinone on myelopoietic stimulating activity of granulocyte/macrophage colony-stimulating factor in vitro, 

Proc. Natl. Acad. Sci. 89:3691-3695. 

42 International Agency for Research on Cancer (IARC). 1987. Monographs on the evaluation of carcinogenic risk 

of chemicals to humans, Volume 29, Supplement 7, Some industrial chemicals and dyestuffs, World Health 

Organization, Lyon, France. 

43 U.S. Department of Health and Human Services National Toxicology Program 11th Report on Carcinogens 

available at: http://ntp.niehs.nih.gov/go/16183 . 

44 Aksoy, M. (1989). Hematotoxicity and carcinogenicity of benzene. Environ. Health Perspect. 82: 193-197. 

45 Goldstein, B.D. (1988). Benzene toxicity. Occupational medicine. State of the Art Reviews. 3: 541-554. 

Commented [A24]: OMB RIA Comment 2: Reviewer 

recommends clarifying in the RIA that EPA cannot estimate how 

much HAPs would be reduced because of this rule, and therefore 

cannot estimate benefits. 

EPA Response: This has been clarified in this section. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-32 

4.5.2 Ethylbenzene 

Ethylbenzene is a major industrial chemical produced by alkylation of benzene. The pure 

chemical is used almost exclusively for styrene production. It is also a constituent of crude 

petroleum and is found in gasoline and diesel fuels. Acute (short-term) exposure to ethylbenzene 

in humans results in respiratory effects such as throat irritation and chest constriction, and 

irritation of the eyes, and neurological effects such as dizziness. Chronic (long-term) exposure 

of humans to ethylbenzene may cause eye and lung irritation, with possible adverse effects on 

the blood. Animal studies have reported effects on the blood, liver, and kidneys and endocrine 

system from chronic inhalation exposure to ethylbenzene. No information is available on the 

developmental or reproductive effects of ethylbenzene in humans, but animal studies have 

reported developmental effects, including birth defects in animals exposed via inhalation. 

Studies in rodents reported increases in the percentage of animals with tumors of the nasal and 

oral cavities in male and female rats exposed to ethylbenzene via the oral route.46,47 The reports of 

these studies lacked detailed information on the incidence of specific tumors, statistical analysis, 

survival data, and information on historical controls, thus the results of these studies were 

considered inconclusive by the International Agency for Research on Cancer (IARC, 2000) and 

the National Toxicology Program (NTP).48,49 The NTP (1999) carried out a chronic inhalation 

bioassay in mice and rats and found clear evidence of carcinogenic activity in male rats and some 

evidence in female rats, based on increased incidences of renal tubule adenoma or carcinoma in 

male rats and renal tubule adenoma in females. NTP (1999) also noted increases in the incidence 

 

46 Maltoni C, Conti B, Giuliano C and Belpoggi F, 1985. Experimental studies on benzene carcinogenicity at the 

Bologna Institute of Oncology: Current results and ongoing research. Am J Ind Med 7:415-446.

47 Maltoni C, Ciliberti A, Pinto C, Soffritti M, Belpoggi F and Menarini L, 1997. Results of long-term experimental 

carcinogenicity studies of the effects of gasoline, correlated fuels, and major gasoline aromatics on rats. Annals 

NY Acad Sci 837:15-52.

48International Agency for Research on Cancer (IARC), 2000. Monographs on the Evaluation of Carcinogenic Risks 

to Humans. Some Industrial Chemicals. Vol. 77, p. 227-266. IARC, Lyon, France.

49 National Toxicology Program (NTP), 1999. Toxicology and Carcinogenesis Studies of Ethylbenzene (CAS No. 

100-41-4) in F344/N Rats and in B6C3F1 Mice (Inhalation Studies). Technical Report Series No. 466. NIH 

Publication No. 99-3956. U.S. Department of Health and Human Services, Public Health Service, National 

Institutes of Health. NTP, Research Triangle Park, NC.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-33 

of testicular adenoma in male rats. Increased incidences of lung alveolar/bronchiolar adenoma or 

carcinoma were observed in male mice and liver hepatocellular adenoma or carcinoma in female 

mice, which provided some evidence of carcinogenic activity in male and female mice (NTP, 

1999). IARC (2000) classified ethylbenzene as Group 2B, possibly carcinogenic to humans, 

based on the NTP studies. 

4.5.3 Toluene50

Under the 2005 Guidelines for Carcinogen Risk Assessment, there is inadequate 

information to assess the carcinogenic potential of toluene because studies of humans chronically 

exposed to toluene are inconclusive, and toluene was not carcinogenic in adequate inhalation 

cancer bioassays of rats and mice exposed for life.

51,52,53, and increased Increased incidences of 

mammary cancer and leukemia were reported in a lifetime rat oral bioassay;

54

 however, this 

evidence was considered equivocal since cancers were observed at the low dose tested 

(500mg/kg/day) but not at the higher dose tested (800 mg/kg/day). In support of EPA’s cancer 

classification, IARC has classified toluene as Group 3 (not classifiable as to its carcinogenicity 

in humans) with a supporting statement that there is inadequate evidence in humans and evidence 

suggesting a lack of carcinogenicity of toluene in experimental animals.

55

 

50 All health effects language for this section came from: U.S. EPA. 2005. “Full IRIS Summary for Toluene 

(CASRN 108-88-3)” Environmental Protection Agency, Integrated Risk Information System (IRIS), Office of 

Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH. 

Available on the Internet at <http://www.epa.gov/iris/subst/0118.htm>.

51 CIIT (Chemical Industry Institute of Toxicology). (1980) A twenty-four month inhalation toxicology study in 

Fischer-344 rats exposed to atmospheric toluene. Conducted by Industrial Bio-Test Laboratories, Inc., Decatur, 

IL, and Experimental Pathology Laboratories, Inc., Raleigh, NC, for CIIT, Research Triangle Park, NC..

52 NTP (National Toxicology Program), 1990. Toxicology and carcinogenesis studies of toluene (CAS No. 108-88-

3) in F344/N rats and B5C3F1 mice (inhalation studies). Public Health Service, U.S. Department of Health and 

Human Services; NTP TR 371. Available from: National Institute of Environmental Health Sciences, Research 

Triangle Park, NC.

53 Huff, J., 2003. Absence of carcinogenic activity in Fischer rats and B6C3F1 mice following 103-week inhalation 

exposures to toluene. Int J Occup Environ Health 9:138-146.

54 Maltoni, C; Ciliberti, A; Pinto, C; et al., 1997. Results of long-term experimental carcinogenicity studies of the 

effects of gasoline, correlated fuels, and major gasoline aromatics on rats. Ann NY Acad Sci 837:15-52. 

55 IARC. (International Agency for Research on Cancer), 1999. IARC monographs on the evaluation of carcinogenic 

risks of chemicals to humans. Vol. 71, Part 2. Re-evaluation of some organic chemicals, hydrazine and hydrogen 

peroxide. Lyon, France: International Agency for Research on Cancer, pp. 829-864.

Commented [A25]: OMB RIA Comment 3: Reviewer 

recommends clarifying the first paragraph of the RIA on toluene. It 

currently says “toluene was not carcinogenic in adequate inhalation 

cancer bioassays of rats and mice exposed for life, and increased 

evidence of mammary cancer and leukemia were reported in a 

lifetime rat oral bioassay.” Were the increased incidences of 

mammary cancer and leukemia observed in inadequate oral cancel 

bioassays? 

The cancer classification is just hazard identification, so there should 

be discussion on why the evidence is inadequate despite a positive 

oral cancer bioassay. 

EPA Response: This discussion has been clarified. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-34 

The central nervous system (CNS) is the primary target for toluene toxicity in both 

humans and animals for acute and chronic exposures. CNS dysfunction (which is often 

reversible) and narcosis have been frequently observed in humans acutely exposed to low or 

moderate levels of toluene by inhalation: symptoms include fatigue, sleepiness, headaches, and 

nausea. Central nervous system depression has been reported to occur in chronic abusers 

exposed to high levels of toluene. Symptoms include ataxia, tremors, cerebral atrophy, 

nystagmus (involuntary eye movements), and impaired speech, hearing, and vision. Chronic 

inhalation exposure of humans to toluene also causes irritation of the upper respiratory tract, eye 

irritation, dizziness, headaches, and difficulty with sleep. 

Human studies have also reported developmental effects, such as CNS dysfunction, 

attention deficits, and minor craniofacial and limb anomalies, in the children of women who 

abused toluene during pregnancy. A substantial database examining the effects of toluene in 

subchronic and chronic occupationally exposed humans exists. The weight of evidence from 

these studies indicates neurological effects (i.e., impaired color vision, impaired hearing, 

decreased performance in neurobehavioral analysis, changes in motor and sensory nerve 

conduction velocity, headache, and dizziness) as the most sensitive endpoint. 

4.5.4 Vinyl Chloride56

Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products. 

Acute (short-term) exposure to high levels of vinyl chloride in air has resulted in central nervous 

system effects (CNS), such as dizziness, drowsiness, and headaches in humans. Chronic (longterm) exposure to vinyl chloride through inhalation and oral exposure in humans has resulted in 

liver damage. Cancer is a major concern from exposure to vinyl chloride via inhalation, as vinyl 

chloride exposure has been shown to increase the risk of a rare form of liver cancer in humans. 

 

56 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Vinyl Chloride. 2000. 

Available online at http://www.epa.gov/iris/subst/1001.htm. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-35 

EPA has classified vinyl chloride as a Group A, “human carcinogen”. IARC has classified vinyl 

chloride as carcinogenic to humans (Group 1).57

4.5.5 Other Air Toxics 

In addition to the compounds described above, other air toxic compounds might be 

affected by this rule. Information regarding the health effects of those compounds can be found 

in EPA’s IRIS database.58

4.6 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

Emission Guidelines for existing MSW landfills, the quantity and composition of landfill gas 

does change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a 

more complete picture of the climate benefits of the Emission Guidelines alternatives over time 

by presenting results from the years 2020, 2030, and 2040. 

Table 4-6 presents the climate benefits of the alternatives in the 2020 snapshot year. 

Table 4-6 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.24 5.9 $140 $310 $410 $810 

Proposed Option 2.5/34 0.36 9.0 $210 $460 $620 $1,200 

Alternative Option 2.0/34 0.40 10.1 $240 $520 $700 $1,400 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

 

57 International Agency for Research on Cancer (IARC). 2008. Monographs on the Evaluation of the Carcinogenic 

Risk of Chemicals for Humans. Vol. 97, pp311. Lyon, France: International Agency for Research on Cancer. 

Available online at http://monographs.iarc.fr/ENG/Monographs/vol97/index.php. 

58 U.S. EPA Integrated Risk Information System (IRIS) database is available at: www.epa.gov/iris 

Commented [A26]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-36 

Table 4-7 presents the climate benefits of the alternatives in the 2030 snapshot year.

Table 4-7 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.31 7.7 $250 $530 $670 $1,400 

Proposed Option 2.5/34 0.50 12 $410 $860 $1,100 $2,300 

Alternative Option 2.0/34 0.53 13 $440 $920 $1,200 $2,400 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 4-8 presents the climate benefits of the alternatives in the 2040 snapshot year.

Table 4-8 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.21 5.3 $230 $450 $590 $1,300 

Proposed Option 2.5/34 0.34 8.4 $360 $720 $940 $2,000 

Alternative Option 2.0/34 0.35 8.7 $380 $750 $980 $2,100 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

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March. < http://www.epa.gov/ttn/atw/nata2005/> Accessed March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2011d. Regulatory Impact Analysis for the 

Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter 

and Ozone in 27 States; Correction of SIP Approvals for 22 States. Office of Air Quality 

Planning and Standards, Research Triangle Park, NC. July. 

<http://www.epa.gov/airtransport/pdfs/FinalRIA.pdf>. Accessed March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2011e. Draft Residual Risk Assessment for the 

Oil and Natural Gas Source Category. Office of Air Quality Planning and Standards. 

Office of Air and Radiation. 

 U.S. Environmental Protection Agency (EPA). 2012a. Residual Risk Assessment for the Oil and 

Gas Production and Natural Gas Transmission and Storage Source Categories. Office of 

Air Quality Planning and Standards, Research Triangle Park, NC. 

U.S. Environmental Protection Agency (EPA). 2012b. Regulatory Impact Analysis Final New 

Source Performance Standards and Amendments to the National Emissions Standards for 

Hazardous Air Pollutants for the Oil and Natural Gas Industry. Office of Air Quality 

Planning and Standards, Health and Environmental Impacts Division. April. < 

http://www.epa.gov/ttn/ecas/regdata/RIAs/oil_natural_gas_final_neshap_nsps_ria.pdf >. 

Accessed March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2012c. Regulatory Impact Analysis for the Final 

Revisions to the National Ambient Air Quality Standards for Particulate Matter. EPA452/R-12-003. Office of Air Quality Planning and Standards, Health and Environmental 

Impacts Division. December. Available at: 

<http://www.epa.gov/ttnecas1/regdata/RIAs/oil_natural_gas_final_neshap_nsps_ria.pdf>. 

Accessed March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2012d. Regulatory Impact Analysis: Final 

Rulemaking for 2017-2025 Light-Duty Vehicle Greenhouse Gas Emission Standards and 

Corporate Average Fuel Economy Standards. EPA-420-R-12-016. Office of 

Transportation and Air Quality, Assessment and Standards Division. August. < 

http://www.epa.gov/otaq/climate/documents/420r12016.pdf>. Accessed March 30, 2015. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

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U.S. Environmental Protection Agency (EPA). 2013. Integrated Science Assessment of Ozone 

and Related Photochemical Oxidants (Final Report). U.S. Environmental Protection 

Agency, Washington, DC, EPA/600/R-10/076F. February. 

<http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492#Download>. Accessed 

March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2014a. Health Risk and Exposure Assessment for 

Ozone (Final Report). U.S. Environmental Protection Agency, Research Triangle Park, 

NC, EPA-452/R-14-004a. August. 

<http://www.epa.gov/ttn/naaqs/standards/ozone/data/20140829healthrea.pdf>. Accessed 

March 30, 2015. 

U.S. Environmental Protection Agency (EPA). 2014b. Regulatory Impact Analysis for the 

Proposed Ozone NAAQS. U.S. Environmental Protection Agency, Research Triangle 

Park, NC, EPA-452/P-14-006. December. 

<http://www.epa.gov/ttnecas1/regdata/RIAs/20141125ria.pdf>. Accessed March 30, 

2015. 

U.S. Environmental Protection Agency (EPA). 2015. Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990-2013. Office of Atmospheric Programs, Washington, DC. 

EPA 430-R-15-004. Annex 3.14, Tables A-265 and Table ES-2. April 2015. 

<http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html>. Accessed 

April 28, 2015.

U.S. Environmental Protection Agency—Science Advisory Board (EPA-SAB). 2002. Workshop 

on the Benefits of Reductions in Exposure to Hazardous Air Pollutants: Developing Best 

Estimates of Dose-Response Functions An SAB Workshop Report of an EPA/SAB 

Workshop (Final Report). EPA-SAB-EC-WKSHP-02-001. January. 

<http://yosemite.epa.gov/sab%5CSABPRODUCT.NSF/34355712EC011A358525719A0

05BF6F6/$File/ecwkshp02001%2Bappa-g.pdf>. Accessed March 30, 2015. 

U.S. Environmental Protection Agency—Science Advisory Board (EPA-SAB). 2008. Benefits of 

Reducing Benzene Emissions in Houston, 1990–2020. EPA-COUNCIL-08-001. July. 

<http://yosemite.epa.gov/sab/sabproduct.nsf/D4D7EC9DAEDA8A548525748600728A8

3/$File/EPA-COUNCIL-08-001-unsigned.pdf>. Accessed March 30, 2015. 

Waldhoff, S., D. Anthoff, S. Rose, R.S.J. Tol. 2014. “The Marginal Damage Costs of Different 

Greenhouse Gases: An Application of FUND.” The Open-Access, Open Assessment EJournal. 8(31): 1-33. http://dx.doi.org/10.5018/economics-ejournal.ja.2014-31. Accessed 

July 13, 2015. 

West, J.J., A. M. Fiore , L. W. Horowitz, and D. L. Mauzerall. 2006. “Global health benefits of 

mitigating ozone pollution with methane emission controls.” PNAS 103:11:3988-3993. 

West, J.J., A.M. Fiore. 2005. “Management of tropospheric ozone by reducing methane 

emissions.” Environ Sci Technol, 39:4685-4691. 
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5-1 

5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS 

5.1 Introduction 

This chapter of the RIA includes three sets of discussions related to the proposed 

Emission Guidelines for MSW landfills: 

• Economic Impact Analysis 

• Employment Analysis 

• Small Business Analysis 

These discussions are intended to assist the reader of the RIA to better understand the potential 

economic impacts of the proposal, though data and methodological limitations prevented a 

complete assessment of the economic impacts of the proposed Emission Guidelines. 

5.2 Economic Impact Analysis 

The impacts shown for the proposal reflect the incremental difference between facilities 

in the baseline and for an option that reduces the NMOC emission rate threshold to 34 Mg/yr 

from the current emissions guideline level of 50 Mg/yr (proposed option 2.5/34). The proposal 

retains the design capacity threshold of 2.5 million Mg or 2.5 million cubic feet. Because the 

proposed option 2.5/34 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 Chapter 3 of this 

RIA to be about $46.8 million in 2025 for the proposed option. 

Assessing the economic impacts of these costs is difficult due to the nature of the MSW 

industry. As previously discussed in Chapter 2, landfills are owned by private companies, 

government (local, state, or federal), or individuals. In 2014, 58 percent of landfills were owned 

by public entities. Households served by public landfills may not respond to price increases in 

the same way as they would if served by private firms, since these households typically pay their 

collection fees through property taxes or other mandatory payments. In these cases, affected 

landfills may be more readily able to pass through increased costs to customers. Households 

served by private landfills may choose to alter their behavior in response to increased collection 

fees, but research into the price elasticity of demand for waste services has typically found the 
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demand for waste services to be price inelastic (Bel and Gradus, 2014; Kinnaman, 2006). As was 

shown in Table 2-5, tipping fees have for the most part increased over time, and industry reports 

indicate that “firms have generally managed to hold the line on pricing and win 2-3 percent 

increases to maintain positive revenue amid slow volume growth” (WBJ, 2012a). This suggests 

that firms will, for the most part, be able to pass along increased costs to their consumers. While 

households faced with higher costs will have less income to spend on other goods and services, 

the large number of households served by any particular landfill suggests that any individual 

household will be only modestly impacted. 

As previously discussed in Chapter 2, the handling of MSW in the United States 

generated $55 billion of revenue in 2011, of which landfilling contributed $13 billion (WBJ, 

2012a). Of the $46.8 million of costs in 2025 for the proposed option, 15 percent are borne by 

the five largest firms in the industry, who together accounted for nearly $30 billion in revenue in 

2013 (see Table 2-3). An additional 79 percent of the costs are expected to be incurred by entities 

that are large by SBA standards. Small public entities are predicted to incur approximately six 

percent of the costs, while small private entities are predicted to incur less than one percent of the 

total cost. 

Because of the relatively low net cost of proposed option 2.5/34 compared to the overall 

size of the MSW industry, as well as 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. However, because of the relatively low incremental costs of the proposed option 2.5/34, 

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. 

5.3 Employment Impacts 

In addition to addressing the costs and benefits of the final rule, EPA has analyzed the 

impacts of this rulemaking on employment, which are presented in this section. While a 

standalone analysis of employment impacts is not included in a standard cost-benefit analysis, 

such an analysis is of particular concern in the current economic climate given continued interest 

Commented [A29]: OMB RIA Comment 26: Reviewer 

recommends that given the current unemployment rate of 5.3%, the 

compelling need for an extensive discussion on employment on 5.3 

isn’t clear. For the final rule, reviewer recommends abbreviating this 

discussion. 

EPA Response: Discussion will be revised for final rule. 
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5-3 

in the employment impact of regulations such as this final rule. Executive Order 13563, states, 

“Our regulatory system must protect public health, welfare, safety, and our environment while 

promoting economic growth, innovation, competitiveness, and job creation.” 59 While 

disaggregated compliance costs are not available for the analyzed options, a brief discussion of 

the labor requirements associated with the installation, operation, and maintenance of control 

requirements, as well as reporting and recordkeeping requirements is included in Section 3.4, on 

engineering and administrative costs, of this RIA. However, due to data and methodology 

limitations, we have not quantified the rule’s effects on employment. What follows is an 

overview of the various ways that environmental regulation can affect employment. EPA 

continues to explore the relevant theoretical and empirical literature and to seek public comments 

in order to ensure that the way EPA characterizes the employment effects of its regulations is 

valid and informative.60

5.3.1 Background on the Regulated Industry 

This regulation is expected to affect domestic employment in the regulated sector – 

municipal solid waste landfills. Municipal solid waste (MSW) is the stream of garbage collected 

by sanitation services from homes, businesses, and institutions. 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. 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 (NMOC) 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 landfill. LFG can be collected and combusted in 

flares or energy recovery devices to reduce emissions. In this rulemaking EPA is proposing to 

lower the annual NMOC emissions threshold from 50 Mg/year to 34 Mg/year. Because of the 

 

59Executive Order 13563 (January 21, 2011). Improving Regulation and Regulatory Review. Section 1. General 

Principles of Regulation, Federal Register, Vol. 76, Nr. 14, p. 3821. 

60 The employment analysis in this RIA is part of EPA’s ongoing effort to “conduct continuing evaluations of 

potential loss or shifts of employment which may result from the administration or enforcement of [the Act]” 

pursuant to CAA section 321(a).
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lack of appropriate economic parameters or model, EPA is unable to estimate the impacts of the 

rule options on the supply and demand for MSW landfill services. However, because of the 

relatively low incremental costs of the proposed option, 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. 

As described in Chapter 2 of this RIA, EPA estimates the total amount of MSW 

generated in the United States in 2012 was approximately 251 million tons, a 20 percent increase 

from 1990. The number of active MSW landfills in the United States has decreased from 

approximately 7,900 in 1988 to approximately 1,800 in 2014 (EPA, 2010; WBJ, 2014). 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). 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, 2012a). 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). See Chapter 2, Table 2-3, for a 

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

MSW landfills and transfer stations. 

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

individuals. In 2014, 58 percent of active MSW landfills were owned by public entities while 

42 percent were privately owned (EPA, 2014). As older local public landfills approach their 

capacities, many communities are finding that the most economically viable solution to their 

waste disposal needs is shipping their waste to large 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, 2002). Waste transfer stations are facilities where MSW is unloaded from 

collection vehicles and reloaded into long-distance transport vehicles for delivery to regional 

landfills or other treatment/disposal facilities. By combining the loads of several waste collection 
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trucks into a single shipment, communities and waste management companies can reduce labor 

used and operating costs for 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, 2012b). 

The industry that collects, transfers, deposits and manages 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. For employment estimates related to publicly-owned landfills, solid waste 

management departments of local governments reported, in 2013, 95,674 full-time employees 

and 14,638 part-time employees (U.S. Census Bureau, 2013); however, statistics from the U.S. 

Census Bureau are not readily available solely for landfill-related aspects of these departments. 

An additional government source of employment data by detailed industry is the Bureau of 

Labor Statistics (BLS). The BLS Quarterly Census of Employment and Wages, which gathers 

employment data from state unemployment insurance programs, reports employment data for 

publicly-owned solid waste landfills (NAICS 562212) owned by local governments: in March 

2013, they report 22,586 employees (U.S. Bureau of Labor Statistics, 2013). For employment 

estimates related to private landfills, both the U.S. Census Bureau and the Bureau of Labor 

Statistics provide employment data. However, because these agencies use different methods to 

gather and classify employment data, their estimates indicate a range of employment within 

NAICS 562212, “solid waste landfills”.61 For March 2012, the most recent estimate from the 

U.S. Census Bureau’s County Business Patterns, the Census estimate is 18,208 employees at 

privately-owned solid waste landfills (U.S. Census Bureau, 2012). However, for privately-owned 

solid waste landfills, the BLS estimate for March 2012 is 37,628 employees (U.S. Bureau of 

Labor Statistics, 2012). When data series differ, it can be instructive to look at more aggregated 

industry categories, and in this case, more aggregated employment estimates are very similar 

 

61 BLS QCEW methodology for “industrial classification”: http://www.bls.gov/opub/hom/homch5_b.htm. Census 

methodology for “industry classification of establishments”: 

https://www.census.gov/econ/cbp/methodology.htm. 
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between Census and BLS at the 3-digit level NAICS, 562 Waste Management and Remediation 

Services. Based on observed within NAICS 562, the range in estimates at the 6-digit NAICS 

562212 may be driven by methodological differences in categorizing establishments by their 

“main economic activity”, which for this detailed industry, is likely a combination of waste 

treatment, waste disposal, and waste remediation and recovery services, and therefore difficult to 

classify by a single economic activity.62 

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 

due to recycling and other diversion activities (EPA, 2012c). 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 as the trend towards increased use of 

regional landfills and waste transfer stations continues. In addition, employment may be affected 

as landfills add technologies in response to the proposed regulation. Whether the technology 

added will capture and flare landfill gas, or capture and combust it for energy recovery, 

employment will be associated with these activities. 

5.3.2 Employment Impacts of Environmental Regulation 

From an economic perspective labor is an input into producing goods and services; if a 

regulation requires that more labor be used to produce a given amount of output, that additional 

labor is reflected in an increase in the cost of production. Moreover, when the economy is at full 

employment, we would not expect an environmental regulation to have an impact on overall 

employment because labor is being shifted from one sector to another. On the other hand, in 

periods of high unemployment, employment effects (both positive and negative) are possible. 

For example, an increase in labor demand due to regulation may result in a short-term net 

increase in overall employment as workers are hired by the regulated sector to help meet new 

requirements (e.g., to install new equipment) or by the environmental protection sector to 

 

62 2-, 3-, 4-, 5-, and 6-digit NAICS listings for NAICS 56 “Administrative and Support and Waste Management and 

Remediation Services” < http://www.census.gov/cgibin/sssd/naics/naicsrch?chart_code=56&search=2012%20NAICS%20Search>.
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5-7 

produce new abatement capital resulting in hiring previously unemployed workers . When 

significant numbers of workers are unemployed, the opportunity costs associated with displacing 

jobs in other sectors are likely to be smaller. And, in general, if a regulation imposes high costs 

and does not increase the demand for labor, it may lead to a decrease in employment. The 

responsiveness of industry labor demand depends on how these forces all interact. Economic 

theory indicates that the responsiveness of industry labor demand depends on a number of 

factors: price elasticity of demand for the product, substitutability of other factors of production, 

elasticity of supply of other factors of production, and labor’s share of total production costs. 

Berman and Bui (2001) put this theory in the context of environmental regulation, and suggest 

that, for example, if all firms in the industry are faced with the same compliance costs of 

regulation and product demand is inelastic, then industry output may not change much at all. 

Regulations set in motion new orders for pollution control equipment and services. New 

categories of employment have been created in the process of implementing environmental 

regulations. When a regulation is promulgated, one typical response of industry is to order 

pollution control equipment and services in order to comply with the regulation when it becomes 

effective. On the other hand, the closure of plants that choose not to comply – and any changes in 

production levels at plants choosing to comply and remain in operation - occur after the 

compliance date, or earlier in anticipation of the compliance obligation. Environmental 

regulation may increase revenue and employment in the environmental technology industry. 

While these increases represent gains for that industry, they translate into costs to the regulated 

industries required to install the equipment. 

Environmental regulations support employment in many basic industries. Regulated firms 

either hire workers to design and build pollution controls directly or purchase pollution control 

devices from a third party for installation. Once the equipment is installed, regulated firms hire 

workers to operate and maintain the pollution control equipment—much like they hire workers 

to produce more output. In addition to the increase in employment in the environmental 

protection industry (via increased orders for pollution control equipment), environmental 

regulations also support employment in industries that provide intermediate goods to the 

environmental protection industry. The equipment manufacturers, in turn, order steel, tanks, 

vessels, blowers, pumps, and chemicals to manufacture and install the equipment. Currently in 
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most cases there is no scientifically defensible way to generate sufficiently reliable estimates of 

the employment impacts in these intermediate goods sectors. 

It is sometimes claimed that new or more stringent environmental regulations raise 

production costs thereby reducing production which in turn must lead to lower employment. 

However, the peer-reviewed literature indicates that determining the direction of net employment 

effects in a regulated industry is challenging due to competing effects. Environmental regulations 

are assumed to raise production costs and thereby the cost of output, so we expect the “output” 

effect of environmental regulation to be negative (higher prices lead to lower sales). On the other 

hand, complying with the new or more stringent regulation requires additional inputs, including 

labor, and may alter the relative proportions of labor and capital used by regulated firms in their 

production processes. Two sets of researchers discussed here, Berman and Bui (2001) and 

Morgenstern, Pizer, and Shih (2002),63 demonstrate using standard neoclassical microeconomics 

that environmental regulations have an ambiguous effect on employment in the regulated sector. 

These theoretical results imply that the effect of environmental regulation on employment in the 

regulated sector is an empirical question and both sets of authors tested their models empirically 

using different methodologies. Both Berman and Bui and Morgenstern et al. examine the effect 

of environmental regulations on employment and both find that overall they had no significant 

net impact on employment in the sectors they examined. 

Berman and Bui (2001) developed an innovative approach to examine how an increase in 

local air quality regulation that reduces nitrogen oxides (NOX) emissions affects manufacturing 

employment in the South Coast Air Quality Management District (SCAQMD), which 

incorporates Los Angeles and its suburbs. During the time frame of their study, 1979 to 1992, the 

SCAQMD enacted some of the country’s most stringent air quality regulations. Using 

 

63 Berman, E. and L. T. M. Bui (2001). “Environmental Regulation and Labor Demand: Evidence from the South 

Coast Air Basin.” Journal of Public Economics 79(2): 265-295. Morgenstern, R. D., W. A. Pizer, and J. S. Shih. 

2002. Jobs versus the Environment: An Industry-Level Perspective. Journal of Environmental Economics and 

Management 43(3):412-436. 
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SCAQMD’s local air quality regulations, Berman and Bui identify the effect of environmental 

regulations on net employment in the regulated industries.64,65 The authors find that “while 

regulations do impose large costs, they have a limited effect on employment” (Berman and Bui, 

2001, p. 269). Their conclusion is that local air quality regulation “probably increased labor 

demand slightly” but that “the employment effects of both compliance and increased stringency 

are fairly precisely estimated zeros, even when exit and dissuaded entry effects are included” 

(Berman and Bui, 2001, p. 269).66

Morgenstern et al. (2002) estimated the effects of pollution abatement expenditures from 

1979 to 1991 at the plant level on net employment in four highly regulated sectors (pulp and 

paper, plastics, steel, and petroleum refining). Thus, in contrast to Berman and Bui (2001), this 

study identifies employment effects by examining differences in abatement expenditures rather 

than geographical differences in stringency. They conclude that increased abatement 

expenditures generally have not caused a significant change in net employment in those sectors. 

While the specific sectors Morgenstern et al. examined are different than the sectors considered 

here, the methodology that Morgenstern et al. developed is still an informative way to 

qualitatively, if not quantitatively, assess the effects of this rulemaking on employment at MSW 

landfills. For example, as firms add new technologies to capture landfill gases for flaring or for 

conversion to energy, there will be a demand for labor to install, monitor, and operate these new 

approaches to waste management and energy production. 

While there is an extensive empirical, peer-reviewed literature analyzing the effect of 

environmental regulations on various economic outcomes including productivity, investment, 

competitiveness as well as environmental performance, there are only a few papers that examine 

the impact of environmental regulation on employment, but this area of the literature has been 

growing. As stated previously in this RIA section, empirical results from Berman and Bui (2001) 

and Morgenstern et al (2002) suggest that new or more stringent environmental regulations do 

 

64 Note, like Morgenstern, Pizer, and Shih (2002), this study does not estimate the number of jobs created in the 

environmental protection sector. 

65 Berman and Bui include over 40 4-digit SIC industries in their sample. 

66 Including the employment effect of exiting plants and plants dissuaded from opening will increase the estimated 

impact of regulation on employment. 
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not have a substantial impact on net employment (either negative or positive) in the regulated 

sector. Similarly, Ferris, Shadbegian, and Wolverton (2014) also find that regulation-induced net 

employment impacts are close to zero in the regulated sector. Furthermore, Gray et al. (2014) 

find that pulp mills that had to comply with both the air and water regulations in EPA’s 1998 

“Cluster Rule” experienced relatively small and not always statistically significant, decreases in 

employment. Nevertheless, other empirical research suggests that more highly regulated 

counties may generate fewer jobs than less regulated ones (Greenstone 2002, Walker 2011). 

However, the methodology used in these two studies cannot estimate whether aggregate 

employment is lower or higher due to more stringent environmental regulation, it can only imply 

that relative employment growth in some sectors differs between more and less regulated areas. 

List et al. (2003) find some evidence that this type of geographic relocation, from more regulated 

areas to less regulated areas may be occurring. Overall, the peer-reviewed literature does not 

contain evidence that environmental regulation has a large impact on net employment (either 

negative or positive) in the long run across the whole economy. 

While the theoretical framework laid out by Berman and Bui (2001) and Morgenstern et 

al. (2002) still holds for the industries affected under these emission guidelines, important 

differences in the markets and regulatory settings analyzed in their study and the setting 

presented here lead us to conclude that it is inappropriate to utilize their quantitative estimates to 

estimate the employment impacts from this proposed regulation. In particular, the industries used 

in these two studies as well as the timeframe (late 1970’s to early 1990’s) are quite different than 

those in the proposed Emission Guidelines. Furthermore, the control strategies analyzed for this 

RIA include gas collection systems, destruction, and utilization, which are very different than the 

control strategies examined by Berman and Bui and Morgenstern et al.67 For these reasons we 

conclude there are too many uncertainties as to the transferability of the quantitative estimates in 

these two studies to apply their estimates to quantify the employment impacts within the 

regulated sectors for this regulation, though these studies have usefulness for qualitative 

assessment of employment impacts. 

 

67 More detail on how emission reductions expected from compliance with this rule can be obtained can be found in 

Chapter 3 of this RIA. 
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The preceding sections have outlined the challenges associated with estimating net 

employment effects in the regulated sector and in the environmental protection sector. These 

challenges make it very difficult to accurately produce net employment estimates for the whole 

economy that would appropriately capture the way in which costs, compliance spending, and 

environmental benefits propagate through the macro-economy. Quantitative estimates are further 

complicated by the fact that macroeconomic models often have very little sectoral detail and 

usually assume that the economy is at full employment. EPA’s Science Advisory Board (SAB) is 

currently in the process of seeking input from an independent expert panel on modeling 

economy-wide impacts, including employment effects. 

5.3.3 Conclusion 

Economic theory predicts that the total effect of an environmental regulation on labor 

demand in regulated sectors is not necessarily positive or negative. Peer-reviewed econometric 

studies that use a structural approach, applicable to in the regulated sectors, converge on the 

finding that such effects, whether positive or negative, have been small. 

Because of the lack of appropriate economic parameters or model, the EPA is unable to 

estimate the impacts of the regulatory options on the supply and demand for MSW landfill 

services. However, because of the relatively low incremental costs of the proposed option, 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. 

MSW landfill activities 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. 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 due to recycling or other waste diversion (EPA, 

2012c). 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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Employment to design, construct and operate new technologies for managing landfill gases 

either through flaring or conversion to energy may also increase. 

5.4 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. 

For the purposes of assessing the impact of the proposed Emission Guidelines on small 

entities, a small entity is defined as: (1) A small business that is primarily engaged in the 

collections and disposal of refuse in a landfill operation as defined by NAICS code 562212 with 

annual receipts less than $38.5 million; (2) a small governmental jurisdiction that is a 

government of a city, county, town, school district, or school 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. 

After considering the economic impact of the proposed Emission Guidelines on small 

entities, the EPA certifies that the proposed regulation will not have a Significant Impact on a 

Substantial Number of Small Entities (SISNOSE). 

The proposed rule will not impose any requirements on small entities. Specifically, 

Emission Guidelines established under CAA section 111(d) do not impose any requirements on 

regulated entities and, thus, will not have a significant economic impact upon a substantial 

number of small entities. After Emission Guidelines are promulgated, states establish standards 

on existing sources and it is those state requirements that could potentially impact small entities. 

Our analysis here is consistent with the analysis of the analogous situation arising when the EPA 

establishes NAAQS, which do not impose any requirements on regulated entities. As here, any 

impact of a NAAQS on small entities would only arise when states take subsequent action to 

maintain and/or achieve the NAAQS through their state implementation plans. See American 
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Trucking Associations v. EPA, 175 F.3d 1029, 1043-45 (D.C. Cir. 1999) (NAAQS do not have 

significant impacts upon small entities because NAAQS themselves impose no regulations upon 

small entities). 

5.5 References 

Bel, Germà and Raymond Gradus. 2014. “Effects of Unit-based Pricing on the Waste Collection 

Demand: a Meta-regression Analysis.” Working Paper 2014/20. Research Institute of 

Applied Economics. <http://www.ub.edu/irea/working_papers/2014/201420.pdf>. 

Berman, E. and L. T. M. Bui. 2001. “Environmental Regulation and Labor Demand: Evidence 

from the South Coast Air Basin.” Journal of Public Economics 79(2): 265-295, docket nr. 

EPA-HQ-OAR-2011-0135 at http://www.regulations.gov. 

Bloomberg Businessweek. 2014RSG. 2013 SEC Filings - Republic Services Inc (RSG). 10-K, 

Annual Financials, February 13, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=RSG

>. 

Bloomberg Businessweek. 2014WM. 2013 SEC Filings - Waste Management Inc (WM). 10-K, 

Annual Financials, February 18, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=WM

>. 

Ferris, Ann, Ronald J. Shadbegian, and Ann Wolverton. 2014. “The Effect of Environmental 

Regulation on Power Sector Employment: Phase I of the Title IV SO2 Trading Program.” 

Journal of the Association of Environmental and Resource Economists 5, 173-193. 

Gray, Wayne B., Ronald J. Shadbegian, Chunbei Wang, and Merve Meral. 2014. “Do EPA 

Regulations Affect Labor Demand? Evidence from the Pulp and Paper Industry.” Journal 

of Environmental Economics and Management: 68, 188-202. 

Greenstone, M. 2002. “The Impacts of Environmental Regulations on Industrial Activity: 

Evidence from the 1970 and 1977 Clean Air Act Amendments and the Census of 

Manufactures.” Journal of Political Economy 110(6): 1175-1219. 

Kinnaman, Thomas C. 2006. “Examining the Justification for Residential Recycling.” Journal of 

Economic Perspectives 20(4): 219-232. 

List, J. A., D. L. Millimet, P. G. Fredriksson, and W. W. McHone. 2003. “Effects of 

Environmental Regulations on Manufacturing Plant Births: Evidence from a Propensity 

Score Matching Estimator.” The Review of Economics and Statistics 85(4): 944-952. 
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5-14 

Morgenstern, Richard D., William A. Pizer, and Jhih-Shyang Shih. 2002. “Jobs Versus the 

Environment: An Industry-Level Perspective.” Journal of Environmental Economics and 

Management 43: 412-436, docket nr. EPA-HQOAR-2011-0135-0057 at 

http://www.regulations.gov. 

U.S. Bureau of Labor Statistics. 2012. Quarterly Census of Employment and Wages. Private, 

NAICS 562212 Solid waste landfill, All States and U.S. 2012 First Quarter, All 

establishment sizes < 

http://www.bls.gov/cew/apps/table_maker/v3/table_maker.htm#type=0&year=2012&qtr

=1&own=5&ind=562&supp=1>. 

U.S. Bureau of Labor Statistics. 2013. Quarterly Census of Employment and Wages. Local 

Government, NAICS 562212 Solid waste landfill, All States and U.S. 2013 First Quarter, 

All establishment sizes < 

http://www.bls.gov/cew/apps/table_maker/v3/table_maker.htm#type=0&year=2013&qtr

=1&own=3&ind=562212&supp=1>. 

U.S. Census Bureau (Census). 2012. County Business Patterns. Solid Waste Landfill (NAICS 

562212). < 

http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=BP_201

2_00A1&prodType=table>. 

U.S. Census Bureau (Census). 2013. Annual Survey of Public Employment & Payroll. Local 

Government Employment and Payroll Data. March 2013. 

<http://www.census.gov/govs/apes/>. 

U.S. Environmental Protection Agency (EPA). 2002. Solid Waste and Emergency Response. 

“Waste Transfer Stations: A Manual for Decision-Making.” June 2002. EPA-530-R-02-

002. <http://www.epa.gov/waste/nonhaz/municipal/pubs/r02002.pdf>. 

U.S. Environmental Protection Agency (EPA). 2010. “Municipal Solid Waste in the United 

States: 2009 Facts and Figures.” December 2010. EPA-530-R-10-012. Washington, DC: 

U.S EPA. <http://www.epa.gov/waste/nonhaz/municipal/pubs/msw2009rpt.pdf>. 

Accessed January 6, 2015. 

U.S. Environmental Protection Agency (EPA). 2012a. Office of Solid Waste and Emergency 

Response (OSWER), Office of Resource Conservation and Recovery (ORCR). Web 

page: Municipal Solid Waste Landfills. 

<http://www.epa.gov/osw/nonhaz/municipal/landfill.htm>. Accessed December 4, 2012. 

U.S. Environmental Protection Agency (EPA). 2012b. OSWER, ORCR. Web page: MSW 

Landfill Criteria Technical Manual. 

<http://www.epa.gov/osw/nonhaz/municipal/landfill/techman/>. Accessed December 4, 

2012. 

U.S. Environmental Protection Agency (EPA). 2012c. Landfill Methane Outreach Program 

(LMOP), Climate Change Division, U.S. EPA. Web page: Frequent Questions: Landfill 

Gas. <http://www.epa.gov/lmop/faq/landfill-gas.html>. Accessed December 3, 2012. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

5-15 

U.S. Environmental Protection Agency (EPA). 2014. “Landfill-level data only (all landfills) – 

updated August 2014.” LMOP, Climate Change Division, U.S. EPA. 

<http://www.epa.gov/lmop/projects-candidates/index.html>. 

Walker, Reed. 2011. “Environmental Regulation and Labor Reallocation.” American Economic 

Review: Papers and Proceedings, 101(2). 

Waste Business Journal (WBJ). 2012a. “Waste Market Overview & Outlook 2012.” 

<http://www.wastebusinessjournal.com/overview.htm>. Accessed January 16, 2015. 

WBJ. 2014. “Directory of Waste Processing and Disposal Sites 2014.” 

<http://www.wastebusinessjournal.com/diratlas.htm>. Accessed January 6, 2015. 
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6-1 

6 COMPARISON OF BENEFITS AND COST 

6.1 Introduction 

The EPA compared the monetized methane-related climate benefits and CO2 co-benefits of 

the proposed Emission Guidelines for existing landfills against the estimated annualized compliance 

costs and found that the benefits of the proposed rule outweigh the costs. The net benefits are likely 

larger since the EPA was not able to monetize the benefits from reducing exposure to 2,770 Mg/yr 

of NMOC. The NMOC portion of LFG can contain a variety of air pollutants, including VOC 

and various organic HAP, and these pollutants are associated with health and welfare effects 

described in Chapter 4.

6.2 Net Benefits of the Proposed Standards 

For the proposed 2.5/34 option, the monetized methane-related climate benefits are 

estimated to range from $310 million to $1.7 billion (2012$)68 in 2025; these benefits are 

estimated to be $660 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $3.6 million to $36 million (2012$)69 in 2025; estimated CO2 benefits 

are $12 million (2012$) in 2025 using a 3% discount rate. Under the proposed option 2.5/34, 

when using a 7% discount rate the additional cost in 2025 would be $47 million. Using a 3% 

discount rate, the additional cost over the baseline in 2025 would be $35 million. Thus, the net 

benefits, using a 7% discount rate, are expected to be $260 million to $1.7 billion, with a central 

estimate of $620 million. These results are summarized in Table 6-1. 

 

 

68 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

69 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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Table 6-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

Emission Guidelines Option 2.5/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $310 million - $1.7 billion 

Monetized CO2 co-benefits1 $3.6 million - $36 million 

Total Costs2 $35 million $47 million 

Net Benefits $270 million - $1.7 billion $260 million - $1.7 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 2,770 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 2,770 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 436,100 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 238,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

6.3 Net Benefits of the Alternate Standards 

For the less stringent 2.5/40 option, the monetized methane-related climate benefits are 

estimated to range from $190 million to $1.1 billion (2012$)70 in 2025; these benefits are 

estimated to be $410 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $1.5 million to $15 million (2012$)71 in 2025; estimated CO2 benefits 

are $5.0 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% 

 

70 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

71 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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6-3 

discount rate the additional cost in 2025 would be $27 million. Using a 3% discount rate, the 

additional cost over the baseline in 2025 would be $20 million. Thus, the net benefits, when 

using a 7% discount rate, would be expected to be $160 million to $1.1 billion, with a central 

estimate of $390 million. These results are summarized in Table 6-2. 

Table 6-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative 

Emission Guidelines Option 2.5/40 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $190 million - $1.1 billion 

Monetized CO2 co-benefits1 $1.5 million - $15 million 

Total Costs2 $20 million $27 million 

Net Benefits $170 million - $1.1 billion $160 million - $1.1 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 1,720 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 1,720 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 270,700 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 102,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

For the more stringent 2.0/34 option, the monetized methane-related climate benefits are 

estimated to range from $340 million to $1.9 billion (2012$)72 in 2025; these benefits are 

 

72 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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6-4 

estimated to be $720 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $3.6 million to $36 million (2012$)73 in 2025; estimated CO2 benefits 

are $12 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% 

discount rate the additional cost in 2025 would be $51 million. Using a 3% discount rate, the 

additional cost over the baseline in 2025 would be $38 million. Thus, the net benefits, when 

using a 7% discount rate, would be expected to be $290 million to $1.9 billion, with a central 

estimate of $690 million. These results are summarized in Table 6-3.

Table 6-3 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative 

Emission Guidelines Option 2.0/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $340 million - $1.9 billion 

Monetized CO2 co-benefits1 $3.6 million - $36 million 

Total Costs2 $38 million $51 million 

Net Benefits $300 million - $1.9 billion $290 million - $1.9 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 3,040 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 3,040 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 479,100 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 238,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

 

73 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7 SUPPLEMENTAL NSPS PROPOSAL 

7.1 Introduction 

On July 17, 2014, the EPA proposed a new NSPS subpart resulting from its ongoing 

review of the landfills NSPS (79 FR 41796). The proposed new subpart retained the same design 

capacity size threshold of 2.5 million m3 or 2.5 million Mg, but presented several options for 

revising the NMOC emission rate at which a MSW landfill must install controls. Since 

presenting these options, the EPA has updated its model that estimates the emission reduction 

and cost impacts based on public comments and new data. 

At proposal, the EPA estimated the emission reductions and costs associated with 17 new 

“greenfield” landfills that the EPA projected to commence construction, reconstruction, or 

modification between 2014 and 2018 and have a design capacity of 2.5 million m3 and 2.5 

million Mg. The basis of the projected number of new landfills and associated emission 

reductions is presented in the landfills NSPS docket EPA-HQ-OAR-2003-0215. Multiple 

commenters on the landfills NSPS proposal stated that the EPA underestimated the cost impacts 

of the landfills NSPS because the EPA failed to consider the number of landfills that are 

expected to undergo a modification, and thus become subject to the proposed NSPS. In response 

to these comments, the EPA consulted with its Regional Offices, as well as state and local 

authorities, to identify landfills expected to undergo a modification within the next 5 years. 

Based on this information, the EPA estimated the number of existing landfills likely to modify 

after July 17, 2014 and become subject to subpart XXX. In addition, the EPA has made several 

changes to its underlying dataset and methodology used to analyze the impacts of potential 

control options, as discussed in Chapter 3 of this RIA. Using the revised dataset, the EPA re-ran 

the model and control options similar to the options presented in the proposed NSPS. As a result 

of these changes, the number and characteristics of the model new landfills and modified 

landfills that are expected to become subject to proposed subpart XXX have changed. The 

revised number of affected landfills, as well as revised estimates of the costs and benefits of the 

previously proposed and newly proposed option, are discussed below. 
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7-2 

7.2 Regulatory Baseline and Options 

The July 2014 proposed new subpart to the NSPS for MSW landfills analyzed options 

slightly different from those analyzed for the current proposed revisions to the emissions 

guidelines. The options analyzed in that Economic Impact Analysis were: 

• Baseline: design capacity retained at 2.5 Mg, emission threshold retained at 50 Mg 

NMOC/year

• Alternative Option 3.0/40: design capacity increased to 3.0 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/40: design capacity retained at 2.5 Mg, emission threshold reduced 

to 40 NMOC Mg/yr 

• Alternative Option 2.0/40: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 40 Mg NMOC/year. 

Consistent with the Methane Strategy that was developed as part of the President’s Climate 

Action Plan, when preparing this supplemental NSPS proposal the EPA considered more 

stringent control options that may achieve additional reductions of methane and NMOC for new 

landfills. As a result of the revised analysis, the EPA is proposing no changes to the design 

capacity threshold for new sources, but is proposing to lower the NMOC emission rate threshold 

to 34 Mg/yr for new and modified sources subject to subpart XXX. In addition to responding to 

feedback received during the NSPS proposal comment period, the EPA believes consistency 

between the thresholds in the emission guidelines and the NSPS is important, given that an 

existing landfill can modify and become subject to the proposed subpart XXX by commencing 

construction on an increase in design capacity. Commenters on the July 17, 2014 notices 

weighed in on consistency between the NSPS and emission guidelines. An environmental 

organization recommended adopting consistent applicability standards, such as design capacity 

and NMOC emission thresholds, between subpart XXX for new landfills and subpart Cf for 

existing landfills to maximize beneficial environmental impacts for existing landfills, which are 

more numerous than anticipated new landfills, and to prevent creating incentives for existing 

landfills subject to modification by allowing them to comply with less rigorous requirements. In 
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7-3 

addition, two regulatory agencies requested harmonizing requirements for existing and new 

landfills between the current regulations in subpart WWW and the new proposed subpart XXX. 

As a result, the options analyzed for this supplemental NSPS proposal for new or 

modified MSW landfills match the options analyzed for the proposed revisions to the emissions 

guidelines for existing MSW landfills, and are: 

• Baseline: design capacity retained at 2.5 Mg, emission threshold retained at 50 Mg 

NMOC/year

• Alternative Option 2.5/40: design capacity retained at 2.5 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/34: design capacity retained at 2.5 Mg, emission threshold reduced 

to 34 NMOC Mg/yr 

• Alternative Option 2.0/34: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 34 Mg NMOC/year 

The baseline and alternative option 2.5/40 correspond to options analyzed in the previous 

NSPS proposal, and can be directly compared to the results in that economic impact analysis to 

better understand the effects of the change in the number of landfills predicted to be affected by 

the NSPS.74 The baseline reflects the parameters of the current NSPS. Specifically, all reported 

results are incremental to the current NSPS (2.5/50) and not the proposed option (2.5/40) from 

the July 2014 proposed new subpart to the NSPS for MSW landfills. In the baseline, the NSPS 

affects 140 landfills, with 28 landfills reporting but not controlling emissions and 112 landfills 

reporting and controlling emissions in 2025. The EPA is assessing impacts in year 2025 as a 

representative year for the both the landfills Emission Guidelines and NSPS. While the analysis 

focuses on impacts in 2025, results for alternative years are also presented in Section 7.8.

 

74 U.S. Environmental Protection Agency (EPA). 2014. “Economic Impact Analysis for the Proposed New 

Subpart to the New Source Performance Standards.” June 2014. Available at < 

http://www.epa.gov/ttn/ecas/regdata/EIAs/LandfillsNSPSProposalEIA.pdf>. 
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Table 7-1 Number of Affected Landfills in 2025 under the Baseline and Alternative 

Options 

 Affected Landfills (no.) 

Landfills 

Affected 

Landfills 

Reporting but 

Not Controlling 

Emissions 

Landfills 

Reporting and 

 Controlling 

Emissions 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 140 28 112 

Incremental values versus the current NSPS

Alternative option 2.5/40 0 -11 11 

Proposed option 2.5/34 0 -15 15 

Alternative option 2.0/34 7 -12 19 

Based on the characteristics of the projected landfills, the proposed option presented in 

Table 7-1Table 7-1 would require 15 additional landfills to install controls by 2025. The less 

stringent alternative option 2.5/40 (which corresponds to the proposed option in the July 2014 

NSPS proposal) would require 11 additional landfills to install controls by 2025, while the more 

stringent alternative option 2.0/34 would affect 22 additional landfills, with some being required 

only to report and others being required to control. In that option, 19 additional landfills are 

required to install controls by 2025. 

Under the proposed option 2.5/34, the emission reductions would be an additional 300 Mg 

NMOC and 51,400 Mg methane (1,300,000 Mg CO2 Eq.) compared to the baseline in 2025. The 

less stringent alternative option 2.5/40 would yield emissions reductions of 300 Mg NMOC and 

44,400 Mg methane (1,100,000 Mg CO2 Eq.) compared to the baseline, while the more stringent 

alternative option 2.0/34 would result in emissions reductions of 400 Mg NMOC and 62,500 Mg 

methane (1,600,000 Mg CO2 Eq.) compared to the baseline. The emission reductions are 

summarized in Table 7-2Table 7-2. 
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Table 7-2 Estimated Annual Average Emissions Reductions in 2025 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 11,600 1,834,000 45,900,000 

Incremental values versus the current NSPS 

Alternative option 2.5/40 300 44,400 1,100,000 

Proposed option 2.5/34 300 51,400 1,300,000 

Alternative option 2.0/34 400 62,500 1,600,000 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Minor secondary air impacts 

are not included in this table. See Section 7.3 for details. 

Costs for the NSPS were estimated in the same manner as the costs for the emissions guidelines. 

This methodology is discussed in Chapter 3. Under the proposed option 2.5/34, when using a 7% 

discount rate the additional cost of control in 2025 would is estimated to be $9.0 million, of 

which approximately $0.6 million is estimated to be offset by increased revenue from beneficialuse projects, so the net cost is estimated to be approximately $8.5 million (
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7-6 

Table 7-3Table 7-3). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $6.6 million, which is estimated to be supplemented by approximately 

$0.65 million in reduced revenue from beneficial-use projects, so the net cost is estimated to be 

approximately $7.4 million., while the The cost of control for the more stringent alternative 

option 2.0/34 would is estimated to be $10.7 million, of which approximately $0.6 million is 

estimated to be offset by increased revenue from beneficial-use projects, so the net cost is 

estimated to be approximately $10.2 million. These options represent approximately between 12 

to 16 percent in additional net costs beyond the baseline, with the proposed option 2.5/34 

resulting in a 14 percent increase in net costs beyond the baseline for the industry as a whole. 
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Table 7-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (7% Discount Rate) 

 Estimated Annualized Net Cost (Millions $2012) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 1.3 322 262 61 

Incremental values versus the current NSPS 

Alternative option 2.5/40 0.06 6.6 -0.65 7.4 

Proposed option 2.5/34 0.08 9.0 0.60 8.5 

Alternative option 2.0/34 0.11 10.7 0.60 10.2 

Note: All total are independently rounded and may not sum. 

When using a 3% discount rate, the model predicts a different timing in the investment behavior 

by the landfills, which affects both the costs and revenue that are predicted in 2025. Under the 

proposed option 2.5/34, the additional cost of control over the baseline in 2025 would is 

estimated to be $12.6 million, of which $5.5 is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to be $7.1 million (
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7-8 

Table 7-4Table 7-4). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $8.0 million, of which $1.6 million is estimated to be offset by 

increased revenue from beneficial-use projects, so the net cost is estimated to be $6.4 million., 

while the The cost of control for the more stringent alternative option 2.0/34 is estimated to be 

$14.9 million, of which $6.3 million is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to would be $8.6 million. These options 

represent approximately between 28 to 38 percent in additional net costs beyond the baseline, 

with the proposed option 2.5/34 resulting in a 31 percent increase in net costs beyond the 

baseline for the industry as a whole. However, it is important to note that the baseline value 

when using a 3% discount rate is less than 40 percent of the cost when using a 7% discount rate, 

because the increased costs of earlier installation of GCCS and engines are offset by increased 

revenue from energy generation. 
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7-9 

Table 7-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (3% Discount Rate) 

 Estimated Annualized Net Cost (Millions $2012) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 1.2 404 382 22 

Incremental values versus the current NSPS 

Alternative option 2.5/40 0.06 8 1.6 6.4 

Proposed option 2.5/34 0.07 12.6 5.5 7.1 

Alternative option 2.0/34 0.10 14.9 6.3 8.6 

Note: All total are independently rounded and may not sum. 

In terms of cost effectiveness, when considering the estimated net cost of the options, the 

overall average cost effectiveness for NMOC reductions is $5,271 per Mg NMOC under the 

baseline and roughly $26,000 per Mg NMOC under the proposed option 2.5/34 and the 

alternative options 2.5/40 and 2.0/34 (Table 7-5Table 7-5). 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 overall average cost effectiveness for methane reductions is roughly $33 per Mg 

methane under the baseline and approximately $160 per Mg methane under the proposed option 

2.5/34 and the alternative options 2.5/40 and 2.0/34.

When estimating cost effectiveness excluding the estimated revenue from beneficial-use 

projects, the overall average cost effectiveness for NMOC reductions is $27,800 per Mg NMOC 

under the baseline and roughly $27,000 to $28,000 per Mg NMOC under the proposed option 

2.5/34 and alternative option 2.0/34, and roughly $24,000 per Mg NMOC under the alternative 

option 2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is $176 per Mg methane under the baseline and 
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7-10 

approximately $150 - $175 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34.

Table 7-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options 

(7% Discount Rate) 

Cost-effectiveness (2012$ per Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 5,271 27,800 33.5 176 1.3 7.10

 

Incremental values versus the current EG 

Alternative option 2.5/40 26,100 23,800 166 151 6.6 6.0 

Proposed option 2.5/34 26,100 27,900 165 177 6.6 7.1 

Alternative option 2.0/34 25,600 27,100 163 172 6.5 6.9 

Note: The cost-effectiveness of NMOC and methane are estimated as if all of the control cost were attributed to each 

pollutant separately. 

a A global warming potential of 25 is used to convert methane to CO2-equivalents. The secondary CO2 emission 

reductions are not reflected in these estimates. 

b Net Cost is the total control and testing and monitoring cost minus any project revenue. The control costs for 

landfills with energy projects includes costs to install and operate a reciprocating engine (and associated electrical 

equipment), which is more expensive than a standard flare. Reciprocating engines are not required by the regulation 

but are expected to be used as control devices when it is cost-effective to recovery the LFG energy.

 

7.3 Benefits 

The proposed subpart to the NSPS is expected to result in significant emissions 

reductions of landfill gas (LFG) from existing new or modified MSW landfills. As in the case of 

the proposed emissions guidelines, there will be climate benefits and HAP, ozone and PM2.5 

health “co-benefits”. These co-benefits occur because the control techniques to meet the 

standards simultaneously reduce methane, VOC, and HAP emissions. By lowering the current 

NMOC emissions threshold of 50 Mg/yr to 34 Mg/yr, the proposal is anticipated to achieve 

reductions of 300 Mg/yr NMOC and 51,400 Mg/yr methane in 2025. The NMOC portion of 

LFG can contain a variety of air pollutants, including VOC and various organic HAP. VOC 
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7-11 

emissions are precursors to both fine particulate matter (PM2.5) and ozone formation, while 

methane is a GHG and a precursor to global ozone formation. As described in detail in Chapter 

4, these pollutants are associated with substantial health effects, climate effects, and other 

welfare effects. As with the proposed emissions guidelines, the only categories of benefits 

monetized for the proposed NSPS are methane-related and CO2-related climate effects. While 

the methane-related climate effects are positive as with the proposed emissions guidelines, for 

the proposed NSPS there are small CO2 disbenefits associated with increased electricity demand 

due to the energy demands of the GCCS exceeding the increased generation of electricity by 

landfills through the burning of LFG in engines. 

While we expect that these avoided emissions will also result in improvements in air 

quality and reduce health and welfare effects associated with exposure to HAP, ozone, and fine 

particulate matter (PM2.5), we have determined that quantification of those health benefits cannot 

be accomplished for this rule in a defensible way. This is not to imply that these benefits do not 

exist; rather, it is a reflection of the difficulties in modeling the direct and indirect impacts of the 

reductions in emissions for this industrial sector with the data currently available. 

The methodology used to calculate methane climate benefits is discussed in detail in Section 4.2 

of this RIA. Applying the approach discussed in that section to the CH4 reductions estimated for 

this proposal, the 2025 methane benefits vary by discount rate and range from about $36 million 

to approximately $210 million; for the proposed option, the mean SC-CH4 at the 3% discount 

rate results in an estimate of about $78 million in 2025. These benefits are presented below in 
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7-12 

Table 7-6Table 7-6. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

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Table 7-6 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.044 1.1 $32 $67 $86 $180 

Proposed Option 2.5/34 0.051 1.3 $36 $78 $100 $210 

Alternative Option 2.0/34 0.063 1.6 $44 $95 $120 $250 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

However, there are climate-related disbenefits that are expected from the proposal’s 

secondary air impacts, specifically, a net increase in CO2 emissions. These disbenefits arise 

because more energy is required to operate the GCCS at some landfills than is produced by these 

landfills through the burning of LFG in engines.75 These disbenefits are presented in Table 7-7 

below. Monetizing the net CO2 increases with the SC-CO2 estimates also described in Section 

4.2 yields disbenefits that vary by discount rate and range from about $0.01 million to 

approximately $0.10 million in 2025. For the proposed option, the mean SC-CO2 at the 3% 

discount rate results in an estimate of about $0.03 million in 2025. 

Table 7-7 Estimated Global Disbenefits of Net CO2 Increases in 2025* (in millions, 2012$) 

Metric tonnes of net 

CO2 increased 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 11,000 $0.17 $0.55 $0.81 $1.6 

Proposed Option 2.5/34 670 $0.010 $0.033 $0.049 $0.10 

Alternative Option 2.0/34 2,000 $0.030 $0.10 $0.14 $0.29 

*The SC-CO2 values are dollar-year and emissions-year specific. SC-CO2 values represent only a partial 

accounting of climate impacts. 

 

75 As in the case of the proposed Emissions Guidelines, there is an additional CO2 impact, specifically a small 

increase in CO2 emissions resulting from flaring of methane in response to this rule. We are not estimating the 

monetized disbenefits of these secondary emissions of CO2 because much of the methane that would have been 

released in the absence of the flare would have eventually oxidized into CO2 in the atmosphere. See Section 4.2.1 

for more discussion.
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7-14 

7.4 Economic Impacts 

7.4.1 Economic Impact Analysis 

As was discussed in Section 5.2, assessing the economic impacts of the costs of the 

proposed option is difficult due to the nature of the MSW industry. The cost of the current 

proposal is estimated to be $8.5 million in 2025. Because of the relatively low net cost of 

proposed option 2.5/34 compared to the overall size of the MSW industry as was discussed in 

Chapter 2 and Section 5.2, as well as 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. However, because of the relatively low incremental costs of the proposed option 2.5/34, 

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. 

7.4.2 Employment Impacts 

As is the case with the proposed emissions guidelines, the EPA is unable to quantify the 

effect of the proposed NSPS on employment. However, a discussion of the potential impacts on 

employment appears in Section 5.3, and is relevant for the proposed NSPS as well as the 

proposed emissions guidelines. 

7.4.3 Small Business Impacts Analysis 

As discussed in Section 5.4, 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. 
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7-15 

It was determined that the July 2014 proposed NSPS subpart would not have a significant 

economic impact on a substantial number of small entities. Given the changes in the number of 

landfills anticipated to become subject to the new proposed NSPS, the potential impact on small 

entities has been reanalyzed. 

For the purposes of assessing the impact of the proposed NSPS on small entities, a small 

entity is defined as: (1) A small business that is primarily engaged in the collections and disposal 

of refuse in a landfill operation as defined by NAICS code 562212 with annual receipts less than 

$38.5 million; (2) a small governmental jurisdiction that is a government of a city, county, town, 

school district, or school 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 EPA typically assessed how the regulatory program may potentially impact owners 

(ultimate parent companies, governmental jurisdictions, or not-for-profit enterprises) by 

comparing pollution control costs to total sales or revenue. This is referred to as a “sales” test or 

cost-to-sales ratio. To perform this test, the total annualized control cost for a small entity (i) is 

divided by its reported revenue: 

		 =

	

	
		

	
	

The “sales test” is the impact metric 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 

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 SBREFA76 and is 

consistent with guidance published by the U.S. SBA’s Office of Advocacy that suggests that cost 

 

76 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> 
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7-16 

as a percentage of total revenues is a metric for evaluating cost increases on small entities in 

relation to increases on large entities.77 The results of the screening analysis appear below in 

Table 7-8. 

Table 7-8 Small Business Impact Screening Assessment Results (Reporters and 

Controllers) 

2.5 million Mg; 

Reduce to 40 Mg/yr 

NMOC 

2.5 million Mg; 

Reduce to 34 Mg/yr 

NMOC 

2.0 million Mg; 

Reduce to 34 Mg/yr 

NMOC 

 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

No. Affected 13 13 13 13 14 14 

No. Affected with Sales Data 11 11 11 11 12 12 

No. Affected > 1% (n) 0 0 2 2 2 2 

No. Affected > 3% (n) 0 0 1 1 1 1 

No. Affected > 1% (%) 0.0% 0.0% 18.2% 18.2% 16.7% 16.7% 

No. Affected > 3% (%) 0.0% 0.0% 9.1% 9.1% 8.3% 8.3% 

After considering the economic impact of the proposed NSPS on small entities, the 

analysis indicates that this rule will not have a significant impact on a substantial number of 

small entities (SISNOSE). First, the proposed revision does not impact a substantial number of 

small entities, since only 13 small entities are projected to be impacted by the proposed option. 

Additionally, the impact to these entities are not significant, because only 2 entities have impacts 

greater than 1 percent of sales, and only 1 of these 2 entities has impacts greater than 3 percent of 

sales.

7.5 Comparison of Benefits and Costs 

The EPA compared the monetized methane-related climate benefits and CO2 co-benefits 

of the proposed NSPS for new or modified MSW landfills against the estimated annualized costs

 

77U.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. 

Commented [A30]: OMB RIA Comment 15: Reviewer notes 

that the basis for no SISNOSE finding isn’t stated and requests the 

analysis to support this conclusion. 

EPA Response: Justification has now been added to this section and 

section 8.3. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-17 

and found that the benefits of the proposed rule outweigh the costs. The net benefits are likely 

larger since the EPA was not able to monetize the benefits from reducing exposure to 300 Mg/yr 

of NMOC. The NMOC portion of LFG can contain a variety of air pollutants, including VOC 

and various organic HAP, and these pollutants are associated with health and welfare effects 

described in Chapter 4. 

7.6 Net Benefits of the Proposed Standards 

For the proposed 2.5/34 option, the monetized methane-related climate benefits are 

estimated to range from $36 million to $210 million (2012$)78 in 2025; these benefits are 

estimated to be $78 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are 

estimated to range from $0.01 million to $0.10 million (2012$)79 in 2025; estimated CO2

disbenefits are $0.033 million (2012$) in 2025 using a 3% discount rate. Under the proposed 

option 2.5/34, when using a 7% discount rate the additional cost in 2025 would be $8.5 million. 

Using a 3% discount rate, the additional cost over the baseline in 2025 would be $7.1 million. 

Thus, the net benefits in 2025, when using a 7% discount rate, are expected to be $28 million to 

$200 million, with a central estimate of $69 million. These results are summarized in Table 7-9. 

Table 7-9 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

NSPS Option 2.5/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $36 million - $210 million 

Monetized CO2 disbenefits1 $0.010 million - $0.10 million 

Total Costs2 $7.1 million $8.5 million 

Net Benefits $29 million - $200 million $28 million - $200 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 

78 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

79 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7-18 

Visibility impairment 

Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 51,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 665 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

7.7 Net Benefits of the Alternate Standards 

For the less stringent 2.5/40 option, the monetized methane-related climate benefits are estimated 

to range from $31 million to $180 million (2012$)80 in 2025; these benefits are estimated to be 

$67 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are estimated to 

range from $0.17 million to $1.6 million (2012$)81 in 2025; estimated CO2 disbenefits are $0.55 

million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% discount 

rate the additional cost in 2025 would be $7.4 million. Using a 3% discount rate, the additional 

cost over the baseline in 2025 would be $6.4 million. Thus, the net benefits, when using a 7% 

discount rate, would be expected to be $23 million to $170 million in 2025, with a primary 

estimate of $59 million. These results are summarized in 

 

80 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

81 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7-19 

Table 7-10Table 7-10. 
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Table 7-10 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Alternative NSPS Option 2.5/40 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $31 million - $180 million 

Monetized CO2 disbenefits1 $0.17 million - $1.60 million 

Total Costs2 $6.4 million $7.4 million 

Net Benefits $24 million - $170 million $23 million - $170 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 44,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 11,000 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

For the more stringent 2.0/34 option, the monetized methane-related climate benefits are 

estimated to range from $44 million to $250 million (2012$)82 in 2025; these benefits are 

estimated to be $95 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are 

estimated to range from $0.03 million to $0.29 million (2012$)83 in 2025; estimated CO2

disbenefits are $0.10 million (2012$) in 2025 using a 3% discount rate. Under this option, when 

using a 7% discount rate the additional cost in 2025 would be $10 million. Using a 3% discount 

rate, the additional cost over the baseline in 2025 would be $8.6 million. Thus, the net benefits, 

 

82 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

83 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7-21 

when using a 7% discount rate, would be expected to be $34 million to $240 million in 2025, 

with a primary estimate of $85 million. These results are summarized in Table 7-11. 

Table 7-11 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Alternative NSPS Option 2.0/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $44 million - $250 million 

Monetized CO2 disbenefits1 $0.03 million - $0.29 million 

Total Costs2 $8.6 million $10.0 million 

Net Benefits $35 million - $240 million $34 million - $240 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 400 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 400 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 62,500 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 1,970 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

7.8 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

NSPS for new or modified MSW landfills, the quantity and composition of landfill gas does 

change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a more 

complete picture of the emission reductions, costs, and benefits of the NSPS alternatives over 

time by presenting results from the years 2020, 2030, and 2040. Throughout this section, costs 

are presented only at a 7% interest rate, and do not include testing and monitoring costs. 

However, testing and monitoring costs are typically a very small percentage of the overall costs. 

Commented [A31]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
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7-22 

Tables 7-12 and 7-13 present the emissions reductions and compliance costs, respectively, of the 

alternatives in the 2020 snapshot year. 

Table 7-12 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 10,100 1.6 39.9 

Incremental values versus the current NSPS 

Alternative option 2.5/40 400 0.06 1.6 

Proposed option 2.5/34 470 0.07 1.9 

Alternative option 2.0/34 550 0.09 2.2 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-13 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 106 294 251 42.0 

Incremental values versus the current NSPS 

Alternative option 2.5/40 13 13.2 6.5 6.7 

Proposed option 2.5/34 16 15.9 8.3 7.6 

Alternative option 2.0/34 20 17.5 8.3 9.3 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 

Tables 7-14 and 7-15 present the emissions reductions and compliance costs, respectively, in the 

2030 snapshot year.
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Table 7-14 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 12,200 1.9 48.1 

Incremental values versus the current NSPS

Alternative option 2.5/40 190 0.03 0.7 

Proposed option 2.5/34 270 0.04 1.1 

Alternative option 2.0/34 330 0.05 1.3 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-15 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 115 331 258 74.0 

Incremental values versus the current EG 

Alternative option 2.5/40 7 3.8 -0.5 4.3 

Proposed option 2.5/34 12 5.9 -1.0 7.0 

Alternative option 2.0/34 16 7.6 -1.0 8.6 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 
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Tables 7-16 and 7-17 present the emissions reductions and compliance costs, respectively, in the 

2040 snapshot year. 

Table 7-16 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 11,600 1.8 45.7 

Incremental values versus the current EG

Alternative option 2.5/40 220 0.03 0.9 

Proposed option 2.5/34 350 0.05 1.4 

Alternative option 2.0/34 360 0.06 1.4 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-17 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 107 321 228 93.0 

Incremental values versus the current EG 

Alternative option 2.5/40 7 5.0 -0.4 5.3 

Proposed option 2.5/34 12 11.6 3.2 8.4 

Alternative option 2.0/34 13 12.0 3.2 8.7 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 

Table 7-18 presents the climate benefits of the alternatives in the 2020 snapshot year.
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Table 7-18 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.063 1.6 $37 $82 $110 $220 

Proposed Option 2.5/34 0.074 1.9 $43 $96 $130 $260 

Alternative Option 2.0/34 0.087 2.2 $51 $110 $150 $300 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 7-19 presents the climate benefits of the alternatives in the 2030 snapshot year.

Table 7-19 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.029 0.73 $24 $50 $63 $130 

Proposed Option 2.5/34 0.042 1.1 $35 $73 $92 $190 

Alternative Option 2.0/34 0.052 1.3 $42 $89 $110 $230 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 7-20 presents the climate benefits of the alternatives in the 2040 snapshot year. 

Table 7-20 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.035 0.87 $38 $75 $98 $210 

Proposed Option 2.5/34 0.055 1.4 $59 $120 $150 $330 

Alternative Option 2.0/34 0.056 1.4 $61 $120 $160 $330 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 
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8 STATUTORY AND EXECUTIVE ORDER REVIEWS 

8.1 Executive Order 12866, Regulatory Planning and Review and Executive Order 

13563, Improving Regulation and Regulatory Review 

Under section 3(f)(1) of Executive Order (EO) 12866 (58 FR 51735, October 4, 1993), 

this action is an “economically significant regulatory action” because it is likely to have an 

annual effect on the economy of $100 million or more. Accordingly, the EPA submitted this 

action to the Office of Management and Budget (OMB) for review under EO 12866 and 13563 

(76 FR 3821, January 21, 2011) and any changes made in response to OMB recommendations 

have been documented in the docket for this action. In addition, the EPA prepared this RIA of 

the potential costs and benefits associated with this action. For the proposed Emission 

Guidelines, the monetized methane-related climate benefits are estimated to range from $310 

million to $1.7 billion (2012$); these benefits are estimated to be $660 million (2012$) in 2025 

using a 3% discount rate. The CO2 co-benefits are estimated to range from $3.6 million to $36 

million (2012$) in 2025; estimated CO2 benefits are $12 million (2012$) in 2025 using a 3% 

discount rate. Under the proposed option 2.5/34, when using a 3% discount rate, the additional 

cost over the baseline in 2025 would be $47 million. When using a 7% discount rate, the 

additional cost in 2025 would be $35 million. Thus, the net benefits are expected to be $260 

million to $1.7 billion, with a primary estimate of $620 million. Table 6-1 shows the results of 

the cost and benefits analysis for this proposed rule. 

The EPA also considered the impacts associated with the proposed revision to the NSPS 

and has concluded that the proposed NSPS is also economically significant. For the proposed 

rule, the monetized methane-related climate benefits are estimated to range from $36 million to 

$210 million (2012$) in 2025, depending on the discount rate; these benefits are estimated to be 

$78 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are estimated to 

range from $0.01 million to $0.10 million (2012$) in 2025, depending on the discount rate; 

estimated CO2 disbenefits are $0.033 million (2012$) in 2025 using a 3% discount rate. Under 

the proposed option 2.5/34, when using a 7% discount rate the additional cost in 2025 would be 

$8.5 million. Using a 3% discount rate, the additional cost over the baseline in 2025 would be 
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$7.1 million. Thus, the net benefits in 2025 are expected to be $28 million to $200 million, with 

a central estimate of $69 million. These results are summarized in Table 7-9. 

8.2 Paperwork Reduction Act 

The information collection requirements in the proposed Emission Guidelines have been 

submitted for approval to OMB under the PRA. The Information Collection Request (ICR) 

document that the EPA prepared for the proposed Emission Guidelines has been assigned EPA 

ICR number [2522.01]. You can find a copy of the ICR in the docket for this rule, and it is 

briefly summarized here. 

The information required to be collected is necessary to identify the regulated entities 

subject to the proposed rule and to ensure their compliance with the proposed Emission 

Guidelines. The recordkeeping and reporting requirements are mandatory and are being 

established under authority of CAA section 114 (42 U.S.C. 7414). All information other than 

emissions data submitted as part of a report to the agency for which a claim of confidentiality is 

made will be safeguarded according to CAA section 114(c) and the EPA’s implementing 

regulations at 40 CFR part 2, subpart B. 

Respondents/affected entities: Municipal solid waste landfills that accepted waste on or 

after November 8, 1987 and commenced construction, reconstruction, or modification on 

or before July 17, 2014. 

Respondent’s obligation to respond: Mandatory (40 CFR part 60, subpart Cf). 

Estimated number of respondents: 988 municipal solid waste landfills. 

Frequency of response: Initially, occasionally and annually. 

Total estimated burden: 621,947 hours (per year) for the responding facilities and 16,054 

hours (per year) for the agency. These are estimates for the average annual burden for the 

first 3 years after the rule is final. Burden is defined at 5 CFR 1320.3(b). 
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Total estimated cost: $41,755,793 (per year), which includes annualized capital or 

operation and maintenance costs, for the responding facilities and $1,029,658 (per year) 

for the agency. These are estimates for the average annual cost for the first 3 years after 

the rule is final. 

The information collection requirements in the supplemental NSPS proposal have been 

submitted for approval to OMB under the PRA. The Information Collection Request (ICR) 

document that the EPA prepared for this supplemental proposal has been assigned EPA ICR 

number 2498.02. You can find a copy of the ICR in the docket for this rule, and it is briefly 

summarized here. 

The information required to be collected is necessary to identify the regulated entities 

subject to the proposed NSPS and to ensure their compliance with the proposed NSPS and this 

supplemental proposal. The recordkeeping and reporting requirements are mandatory and are 

being established under authority of CAA section 114 (42 U.S.C. 7414). All information other 

than emissions data submitted as part of a report to the agency for which a claim of 

confidentiality is made will be safeguarded according to CAA section 114(c) and the EPA’s 

implementing regulations at 40 CFR part 2, subpart B. 

The information collection requirements in the proposed NSPS (79 FR 41828, July 17, 

2014) were submitted for approval to OMB under the PRA. The ICR document that the EPA 

prepared was assigned EPA ICR number 2498.01. Since the NSPS review was proposed on July 

17, 2014, the EPA updated the number of existing landfills likely to modify after July 17, 2014, 

and, thus, become subject to proposed 40 CFR part 60, subpart XXX, as discussed in this 

preamble. The supplemental proposal to lower the emission threshold for new and modified 

sources affects the burden estimates the EPA presented in EPA ICR number 2498.01. As a result, 

the EPA updated the EPA ICR number 2498.01 and re-submitted it to OMB for approval as EPA 

ICR 2498.02 to reflect the estimated number of respondents and a lower NMOC emission rate. A 

copy of the ICR is in Docket ID No. EPA-HQ-OAR-2003-0215, and it is briefly summarized 

here. 
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Respondents/affected entities: Municipal solid waste landfills that commence 

construction, reconstruction, or modification after July 17, 2014. 

Respondent’s obligation to respond: Mandatory (40 CFR part 60, subpart XXX). 

Estimated number of respondents: 144 Municipal solid waste landfills that commence 

construction, reconstruction, or modification after July 17, 2014. 

Frequency of response: Initially, occasionally, and annually. 

Total estimated burden: 101,031 Hours (per year) for the responding facilities and 2,790 

hours (per year) for the agency. These are estimates for the average annual burden for the 

first 3 years after the rule is final. Burden is defined at 5 CFR 1320.3(b). 

Total estimated cost: $6,701,401 (per year), which includes annualized capital or 

operation and maintenance costs, for the responding facilities and $177,680 (per year) for 

the agency. These are estimates for the average annual cost for the first 3 years after the 

rule is final. 

8.3 Regulatory Flexibility Act 

The Regulatory Flexibility Act (RFA) 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 (SISNOSE). Small entities include small businesses, small organizations, and small 

governmental jurisdictions. 

For purposes of assessing the impacts of this proposed rule on small entities, small entity 

is defined as: (1) a small business that is a small industrial entity as defined by the Small 

Business Administration’s (SBA) regulations at 13 CFR 121.201; (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 

which is independently owned and operated and is not dominant in its field. 
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After considering the economic impact of the proposed Emission Guidelines on small 

entities, the EPA certifies that the proposed regulation will not have a Significant Impact on a 

Substantial Number of Small Entities (SISNOSE). 

The proposed rule will not impose any requirements on small entities. Specifically, 

Emission Guidelines established under CAA section 111(d) do not impose any requirements on 

regulated entities and, thus, will not have a significant economic impact upon a substantial 

number of small entities. After emission guidelines are promulgated, states and U.S. territories 

establish standards on existing sources, and it is those requirements that could potentially impact 

small entities. 

Our analysis here is consistent with the analysis of the analogous situation arising when 

the EPA establishes NAAQS, which do not impose any requirements on regulated entities. As 

here, any impact of a NAAQS on small entities would only arise when states take subsequent 

action to maintain and/or achieve the NAAQS through their state implementation plans. See 

American Trucking Associations v. EPA, 175 F.3d 1029, 1043-45 (D.C. Cir. 1999) (NAAQS do 

not have significant impacts upon small entities because NAAQS themselves impose no 

regulations upon small entities). 

After considering the economic impact of the supplemental proposed NSPS on small 

entities, the analysis indicates that this rule will not have a significant impact on a substantial 

number of small entities (SISNOSE). First, the proposed revision does not impact a substantial 

number of small entities, since only 13 small entities are projected to be impacted by the 

proposed option. Additionally, the impact to these entities are not significant, because only 2 

entities have impacts greater than 1 percent of sales, and only 1 of these 2 entities has impacts 

greater than 3 percent of sales. These results are summarized in Table 7-8.

8.4 Unfunded Mandates Reform Act 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Public Law 104-4, 

establishes requirements for federal agencies to assess the effects of their regulatory actions on 

state, local, and tribal governments and the private sector. Under section 202 of the UMRA, the 
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EPA generally must prepare a written statement, including a cost-benefit analysis, for proposed 

and final rules with “federal mandates” that may result in expenditures to state, local, and tribal 

governments, in the aggregate, or to the private sector, of $100 million or more in any 1 year. 

Before promulgating an EPA rule for which a written statement is needed, section 205 of the 

UMRA generally requires the EPA to identify and consider a reasonable number of regulatory 

alternatives and to adopt the least costly, most cost-effective or least burdensome alternative that 

achieves the objectives of the rule. The provisions of section 205 do not apply when they are 

inconsistent with applicable law. Moreover, section 205 allows the EPA to adopt an alternative 

other than the least costly, most cost-effective or least burdensome alternative if the 

Administrator publishes with the final rule an explanation for why that alternative was not 

adopted. Before the EPA establishes any regulatory requirements that may significantly or 

uniquely affect small governments, including tribal governments, it must have developed under 

section 203 of the UMRA a small government agency plan. The plan must provide for notifying 

potentially affected small governments, enabling officials of affected small governments to have 

meaningful and timely input in the development of the EPA regulatory proposals with significant 

federal intergovernmental mandates, and informing, educating, and advising small governments 

on compliance with the regulatory requirements. 

This action does not contain any unfunded mandate of $100 million or more as described 

in UMRA, 2 U.S.C. 1531–1538. The proposed Emission Guidelines apply to landfills that were 

constructed, modified, or reconstructed on or after November 8, 1987, and that commenced 

construction, reconstruction, or modification on or before July 17, 2014. Impacts resulting from 

the proposed Emission Guidelines are below the applicable threshold. 

However, the proposed Emission Guidelines may significantly or uniquely affect small 

governments because small governments operate landfills. The EPA consulted with small 

governments concerning the regulatory requirements that might significantly or uniquely affect 

them. In developing this rule, the EPA consulted with small governments pursuant to a plan 

established under section 203 of the UMRA to address impacts of regulatory requirements in the 

rule that might significantly or uniquely affect small governments. The EPA held meetings as 

discussed in Section 7.5 under Federalism consultations. 
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The supplemental proposal for the NSPS does not contain a federal mandate that may 

result in expenditures of $100 million or more for state, local, and tribal governments, in the 

aggregate, or the private sector in any one year. This action applies to landfills that were 

constructed, modified, or reconstructed on or after July 17, 2014. Impacts resulting from the 

proposed NSPS are far below the applicable threshold. Thus, the proposed NSPS is not subject to 

the requirements of sections 202 or 205 of the UMRA. 

8.5 Executive Order 13132: Federalism 

Executive Order 13132, entitled “Federalism” (64 FR 43255, August 10, 1999), requires 

the EPA to develop an accountable process to ensure “meaningful and timely input by state and 

local officials in the development of regulatory policies that have federalism implications.” 

“Policies that have federalism implications” are defined in the Executive Order to include 

regulations that have “substantial direct effects on the states, on the relationship between the 

national government and the states, or on the distribution of power and responsibilities among 

the various levels of government.” The EPA has concluded that the proposed Emission 

Guidelines have federalism implications, because the rule imposes substantial direct compliance 

costs on state or local governments, and the federal government will not provide the funds 

necessary to pay those costs. 

The EPA has concluded that the supplemental proposal for the NSPS does not have 

Federalism implications. The proposed NSPS will not have substantial direct effects on the 

states, on the relationship between the national government and the states, or on the distribution 

of power and responsibilities among the various levels of government, as specified in Executive 

Order 13132. The supplemental proposal will not have impacts of $25 million or more in any 

one year. Thus, Executive Order 13132 does not apply to the supplemental. Although section 6 

of Executive Order 13132 does not apply to the supplemental proposal NSPS, the EPA consulted 

with state and local officials and representatives of state and local governments early in the 

process of developing the proposed rules for MSW landfills (both the NSPS and Emission 

Guidelines) to permit them to have meaningful and timely input into the rules’ development. The 

EPA conducted a Federalism Consultation Outreach Meeting on September 10, 2013. Due to 

interest in that meeting, additional outreach meetings were held on November 7, 2013 and 
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November 14, 2013. With the pending proposal of these Emission Guidelines, an additional 

Federalism outreach meeting was conducted on April 15, 2015. Participants included the 

National Governors’ Association, the National Conference of State Legislatures, the Council of 

State Governments, the National League of Cities, the U.S. Conference of Mayors, the National 

Association of Counties, the International City/County Management Association, the National 

Association of Towns and Townships, the County Executives of America, the Environmental 

Council of States, National Association of Clean Air Agencies, Association of State and 

Territorial Solid Waste Management Officials, environmental agency representatives from 43 

states, and approximately 60 representatives from city and county governments. The comment 

period was extended to allow sufficient time for interested parties to review briefing materials 

and provide comments. Concerns raised during the consultations include: implementation 

concerns associated with shortening of gas collection system installation and/or expansion 

timeframes, concerns regarding significant lowering of the design capacity or emission 

thresholds, the need for clarifications associated with wellhead operating parameters and the 

need for consistent, clear and rigorous surface monitoring requirements. 

8.6 Executive Order 13175: Consultation and Coordination with Indian Tribal 

Governments 

Executive Order 13175, entitled “Consultation and Coordination with Indian Tribal 

Governments” (65 FR 67249, November 9, 2000), requires the EPA to develop an accountable 

process to ensure “meaningful and timely input by tribal officials in the development of 

regulatory policies that have tribal implications.” This action has tribal implications. However, it 

will neither impose substantial direct compliance costs on federally recognized tribal 

governments, nor preempt tribal law. The database used to estimate impacts of the proposed 40 

CFR part 60, subpart Cf identified one tribe, the Salt River Pima-Maricopa Indian Community, 

which owns three landfills potentially subject to the proposed Emission Guidelines. One of these 

landfills is open, the Salt River Landfill, and is already controlling emissions under the current 

NSPS/EG framework, so while subject to this subpart, the costs of this proposal are not 

substantial. The two other landfills are closed and anticipated to meet the definition of the closed 

landfill subcategory. One of the landfills, the Tri Cities Landfill is already controlling emissions 
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under the current NSPS/EG framework and will not incur substantial additional compliance costs 

under Cf. The other landfill, North Center Street Landfill, is not estimated to install controls 

under the current NSPS/EG framework. 

The supplemental NSPS proposal does not have tribal implications, as specified in 

Executive Order 13175. Based on the EPA’s review of existing landfills as outlined in the 

docketed memorandum, “Summary of Landfill Dataset Used in the Cost and Emission Reduction 

Analysis of Landfills Regulations. 2014,” tribal landfills are not anticipated to be large enough to 

become subject to the rulemaking. Thus, Executive Order 13175 does not apply to the 

supplemental NSPS proposal. Nevertheless, the EPA specifically solicits comment on this action 

from tribal officials. 

8.7 Executive Order 13045: Protection of Children from Environmental Health Risks 

and Safety Risks 

Executive Order 13045, “Protection of Children from Environmental Health Risks and 

Safety Risks” (62 FR 19885, April 23, 1997) applies to any rule that: (1) is determined to be 

“economically significant” as defined under Executive Order 12866, and (2) concerns an 

environmental health or safety risk that the EPA has reason to believe may have a 

disproportionate effect on children. If the regulatory action meets both criteria, the Agency must 

evaluate the environmental health or safety effects of the planned rule on children, and explain 

why the planned regulation is preferable to other potentially effective and reasonably feasible 

alternatives considered by the Agency. 

The EPA interprets Executive Order 13045 as applying only to those regulatory actions 

that concern environmental health or safety risks that the EPA has reason to believe may 

disproportionately affect children, per the definition of “covered regulatory action” in section 2-

202 of the Executive Order. The proposed Emission Guidelines and the supplemental NSPS 

proposal are not subject to Executive Order 13045 because they do not concern an environmental 

health risk or safety risk. We also note that the methane and NMOC reductions expected from 

the proposed Emission Guidelines and NSPS will have positive health effects including for 

children as previously discussed in Chapter 4. 
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8.8 Executive Order 13211: Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use 

This proposed action is not a “significant energy action” as defined in Executive Order 

13211, “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, 

or Use” (66 FR 28355 (May 22, 2001)) because in the Agency’s judgment it is not likely to have 

a significant adverse effect on the supply, distribution, or use of energy. The EPA has concluded 

that this rule is not likely to have any adverse energy effects because there are a small number of 

landfills subject to control requirements under subpart Cf. Further, the EPA has concluded that 

the proposed Emission Guidelines and supplemental NSPS proposal are not likely to have any 

adverse energy effects because the energy demanded to operate these control systems will be 

offset by additional energy supply from landfill gas energy projects. 

8.9 National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, §12(d) (15 U.S.C. 272 note) directs the EPA to use 

voluntary consensus standards in its regulatory activities unless to do so would be inconsistent 

with applicable law or otherwise impractical. Voluntary consensus standards are technical 

standards (e.g., materials specifications, test methods, sampling procedures, and business 

practices) that are developed or adopted by voluntary consensus standards bodies. The NTTAA 

directs the EPA to provide Congress, through OMB, explanations when the Agency decides not 

to use available and applicable voluntary consensus standards. 

This action involves technical standards. The EPA has decided to use EPA Methods 2, 

2E, 3, 3A, 3C, 21, 25, 25A, and 25C of 40 CFR part 60, appendix A. While the EPA identified 

10 VCS as being potentially applicable (ANSI/ASME PTC 19-10-1981 Part 10, ASME B133.9-

1994 (2001), ISO 10396:1993 (2007), ISO 12039:2001, ASTM D5835-95 (2013), ASTM 

D6522-11, CAN/CSA Z223.2-M86 (1999), ASTM D6060-96 (2009), ISO 14965:2000(E), EN 

12619(1999)), the agency decided not to use these methods. The EPA determined that the 10 

candidate VCS identified for measuring emissions of pollutants or their surrogates subject to 

emission standards in the rule would not be practical due to lack of equivalency, documentation, 
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validation data, and other important technical and policy considerations. The agency identified 

no such standards for Methods 2E, 21, and 25C. The EPA’s review, including review comments 

for these 10 methods, is documented in the memorandum, “Voluntary Consensus Standard 

Results for Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills” in 

the docket for this rulemaking. 

8.10 Executive Order 12898: Environmental Justice 

Executive Order 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive policy 

on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and low 

income populations in the United States. 

To gain a better understanding of the Municipal Solid Waste Landfills source category 

and near‐source populations, the EPA conducted a proximity analysis at a study area of 3 miles 

of the source category for this rulemaking. This analysis identifies, on a limited basis, the 

subpopulations that may be exposed to air pollution from the regulated sources and thus are 

expected to benefit most from this regulation. This analysis does not identify the demographic 

characteristics of the most highly affected individuals or communities, nor does it quantify the 

level of risk faced by those individuals or communities. To the extent that any minority, low‐

income or indigenous subpopulation is disproportionately impacted by hazardous air emissions 

due to the proximity of their homes to sources of these emissions, that subpopulation also stands 

to see increased environmental and health benefit from the emission reductions called for by this 

rule. 

The EPA believes the human health or environmental risk addressed by this action will 

not have potential disproportionately high and adverse human health or environmental effects on 

minority, low-income or indigenous populations because the proposed subpart would reduce 

emissions of landfill gas, which contains both nonmethane organic compounds and methane. 

These avoided emissions will improve air quality and reduce public health and welfare effects 
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associated with exposure to landfill gas emissions. The results of the proximity analysis 

conducted for the proposed Emission Guidelines are presented in the April 22, 2015 document 

entitled, “2015 Environmental Justice Screening Report for Municipal Solid Waste Landfills,” a 

copy of which is available in the docket (Docket ID No. EPA–HQ–OAR–2003–0215). 

In regards to the supplemental landfills NSPS proposal, the EPA has concluded that it is 

not practicable to determine whether there would be disproportionately high and adverse human 

health or environmental effects on minority, low income, or indigenous populations from this 

proposed rule because it is unknown where new or modified facilities will be located. However, 

the previously mentioned proximity analysis conducted for the proposed Emission Guidelines 

provides information about the populations likely to be impacted. 
From: Thundiyil, Karen 

Sent: Thursday, August 06, 2015 6:27 PM 

To: Andrea_L_Grossman@omb.eop.gov

Cc: Ward, Hillary; Marsh, Karen; Cozzie, David; Vetter, Rick 

Subject: Follow-up on remaining Landfills items 

Hi Andrea, 

Following up on the minor issues we discussed over the phone, here are the responses from the program. Please 

let us know if you have any questions. 

1. C&D waste exclusion 

See the last sentence in the currently proposed regulatory definition of Household waste at 60.41f: 

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). Household waste 

does not include fully segregated yard waste. Segregated yard waste means vegetative matter resulting 

exclusively from the cutting of grass, the pruning and/or removal of bushes, shrubs, and trees, the weeding of 

gardens, and other landscaping maintenance activities. Household waste does not include construction, 

renovation, or demolition wastes. 

See also Section IX.C of current preamble: We intend for subpart Cf to apply to municipal solid waste landfills 

that accept general household waste (including garbage, trash, sanitary waste), as indicated in the definitions. 

We do not intend the landfills rules to apply to landfills that accept only segregated yard waste or a 

combination of segregated yard waste and non-household waste such as construction and demolition waste. 

This rationale is consistent with 2006 proposed amendments to NSPS. See 71 FR 53277, September 8, 2006. 

2. SSM provisions 

We added a request for comment on p181: EPA requests comment on alternate ways to prevent free 

venting of landfill gas to the atmosphere during control device malfunctions. 

3. Oxygen/temperature monitoring requirement 

We added a request for other parameters at the end of Section X.C of the preamble, after asking about 

flowrate specifically. We inserted a very generic request for comment: The EPA is also requesting comment on 

any other wellhead monitoring parameters that would help ensure a well-operated GCCS. 

Separately, we made minor changes to text in the RIA: 

Updated the footnote to the table on p4-12 to include a reference (now reads “The estimates in this table 

have been adjusted to reflect the minor technical corrections to the SC-CO2 estimates described above. See 

erratum Marten et al. (2015) for more details.” and removed the comment (“OP should be able to provide 

complete citation for erratum by the end of the week”). The citation added to the reference list is “Marten AL, 

Kopits KA, Griffiths CW, Newbold SC, Wolverton A. 2015. “Corrigendum to: Incremental CH4 and N2O 

mitigation benefits consistent with the US Government's SC-CO2 estimates,” Climate Policy 15, 5: 678-679.” 
Additionally, a couple of sentences and a footnote have just been added to section 1.1 per our Office of 

General Counsel. Those sentences say “In accordance with Executive Order 12866, Executive Order 13563, 

OMB Circular A-4, and the EPA’s “Guidelines for Preparing Economic Analyses,” the EPA prepared this RIA for 

these “significant regulatory actions.” These actions are economically significant regulatory actions because 

they may have an annual effect on the economy of $100 million or more or adversely affect in a material way 

the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or 

safety, or state, local, or tribal governments or communities.6” And the footnote says “6 The analysis in this 

draft RIA constitutes the economic assessment required by CAA section 317. In the EPA’s judgment, the 

assessment is as extensive as practicable taking into account the EPA’s time, resources, and other duties and 

authorities.” 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

EO12866_LandfillsEG 2060 AS23 RIA 2015072020150805

Regulatory Impact Analysis for the Proposed 

Revisions to the Emission Guidelines for Existing 

Sources and Supplemental Proposed New Source 

Performance Standards in the Municipal Solid Waste 

Landfills Sector 

U.S. Environmental Protection Agency 

Office of Air and Radiation 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

June JulyAugust 2015
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

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 

Charles Fulcher, 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: fulcher.charles@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. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

iii 

TABLE OF CONTENTS 

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

LIST OF TABLES .................................................................................................................................. VI

LIST OF FIGURES ......................................................................................................................... VIIIVII

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

ES.1 BACKGROUND ........................................................................................................................................... 1

ES.2 RESULTS FOR PROPOSED REVISIONS TO EMISSION GUIDELINES ................................................................... 1

ES.3 RESULTS FOR SUPPLEMENTAL PROPOSED NEW SOURCE PERFORMANCE STANDARDS ................................... 3

ES.3 ORGANIZATION OF THIS REPORT ................................................................................................................ 5

1 INTRODUCTION ........................................................................................................................ 1-1

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

1.2 STATEMENT OF NEED FOR POLICY ACTION ......................................................................................... 1-31-2

1.2.1 Protection of Human Health and the Environment .................................................................... 1-31-2

1.2.2 Need for Regulatory Intervention Because of Market Failure .................................................... 1-41-3

1.2.2.1 Air Pollution as an Externality ............................................................................................. 1-4

1.3 ORGANIZATION OF THIS REPORT ........................................................................................................ 1-51-4

1.4 REFERENCES ..................................................................................................................................... 1-61-5

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 MSW............................................................................................................. 2-3

2.2.1.2 Landfills Covered Under the 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 ........................................................................ 2-242-23

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 .......................................................................................................................... 2-272-26

2.6.4 Utilization .................................................................................................................................. 2-28

2.6.4.1 Technologies ..................................................................................................................... 2-28

2.6.4.2 Revenues and Incentives .................................................................................................... 2-33

2.7 INTEGRATED WASTE MANAGEMENT STRATEGIES .................................................................................. 2-36

2.7.1 Introduction ................................................................................................................................ 2-36
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

iv 

2.7.2 Organics Management ................................................................................................................ 2-37

2.7.2.1 Trends ............................................................................................................................... 2-38

2.7.2.2 Benefits ...................................................................................................................... 2-412-40

2.7.2.3 Barriers ...................................................................................................................... 2-412-40

2.8 REFERENCES ................................................................................................................................. 2-432-42

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

3.1 INTRODUCTION ...................................................................................................................................... 3-1

3.2 GENERAL ASSUMPTIONS AND PROCEDURES ............................................................................................ 3-1

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

3.4 ENGINEERING AND ADMINISTRATIVE COST ANALYSIS ............................................................................. 3-4

3.5 REGULATORY BASELINE AND OPTIONS ................................................................................................... 3-7

3.6 ALTERNATIVE YEARS OF ANALYSIS ............................................................................................... 3-143-12

4 BENEFITS OF EMISSIONS REDUCTIONS .................................................................................. 4-1

4.1 INTRODUCTION ...................................................................................................................................... 4-1

4.2 METHANE (CH4) .................................................................................................................................... 4-4

4.2.1 Methane climate effects and valuation ........................................................................................... 4-4

4.2.2 Methane as an ozone precursor ................................................................................................... 4-16

4.2.3 Combined climate and ozone effects of methane ......................................................................... 4-17

4.3 VOC AS A PM2.5PRECURSOR .......................................................................................................... 4-194-18

4.3.1 PM2.5 health effects and valuation ................................................................................................ 4-19

4.3.2 Visibility Effects......................................................................................................................... 4-23

4.4 VOC AS AN OZONE PRECURSOR ........................................................................................................... 4-23

4.4.1 Ozone health effects and valuation .............................................................................................. 4-24

4.4.2 Ozone vegetation effects ............................................................................................................. 4-25

4.4.3 Ozone climate effects.................................................................................................................. 4-25

4.5 HAZARDOUS AIR POLLUTANT (HAP)BENEFITS ..................................................................................... 4-26

4.5.1 Benzene...................................................................................................................................... 4-31

4.5.2 Ethylbenzene .............................................................................................................................. 4-32

4.5.3 Toluene ...................................................................................................................................... 4-33

4.5.4 Vinyl Chloride ............................................................................................................................ 4-34

4.5.5 Other Air Toxics ......................................................................................................................... 4-35

4.6 ALTERNATIVE YEARS OF ANALYSIS ...................................................................................................... 4-35

4.7 REFERENCES ........................................................................................................................................ 4-36

5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS ................................ 5-1

5.1 INTRODUCTION ...................................................................................................................................... 5-1

5.2 ECONOMIC IMPACT ANALYSIS ................................................................................................................ 5-1

5.3 EMPLOYMENT IMPACTS .......................................................................................................................... 5-2

5.3.1 Background on the Regulated Industry .......................................................................................... 5-3

5.3.2 Employment Impacts of Environmental Regulation ....................................................................... 5-6

5.3.3 Conclusion ................................................................................................................................. 5-11

5.4 SMALL BUSINESS IMPACTS ANALYSIS ................................................................................................... 5-12

5.5 REFERENCES ........................................................................................................................................ 5-13

6 COMPARISON OF BENEFITS AND COST .................................................................................. 6-1

6.1 INTRODUCTION ...................................................................................................................................... 6-1

6.2 NET BENEFITS OF THE PROPOSED STANDARDS ........................................................................................ 6-1

6.3 NET BENEFITS OF THE ALTERNATE STANDARDS ...................................................................................... 6-2

7 SUPPLEMENTAL NSPS PROPOSAL ......................................................................................... 7-1

7.1 INTRODUCTION ...................................................................................................................................... 7-1

7.2 REGULATORY BASELINE AND OPTIONS ................................................................................................... 7-2

7.3 BENEFITS ........................................................................................................................................ 7-107-8
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

v 

7.4 ECONOMIC IMPACTS ...................................................................................................................... 7-147-11

7.4.1 Economic Impact Analysis................................................................................................... 7-147-11

7.4.2 Employment Impacts ........................................................................................................... 7-147-11

7.4.3 Small Business Impacts Analysis ......................................................................................... 7-147-11

7.5 COMPARISON OF BENEFITS AND COSTS .......................................................................................... 7-167-13

7.6 NET BENEFITS OF THE PROPOSED STANDARDS ............................................................................... 7-177-14

7.7 NET BENEFITS OF THE ALTERNATE STANDARDS ............................................................................. 7-187-15

7.8 ALTERNATIVE YEARS OF ANALYSIS ............................................................................................... 7-217-17

8 STATUTORY AND EXECUTIVE ORDER REVIEWS ................................................................... 8-1

8.1 EXECUTIVE ORDER 12866, REGULATORY PLANNING AND REVIEW AND EXECUTIVE ORDER 13563,

IMPROVING REGULATION AND REGULATORY REVIEW ...................................................................................... 8-1

8.2 PAPERWORK REDUCTION ACT ................................................................................................................ 8-2

8.3 REGULATORY FLEXIBILITY ACT.............................................................................................................. 8-4

8.4 UNFUNDED MANDATES REFORM ACT ..................................................................................................... 8-5

8.5 EXECUTIVE ORDER 13132: FEDERALISM ................................................................................................ 8-7

8.6 EXECUTIVE ORDER 13175: CONSULTATION AND COORDINATION WITH INDIAN TRIBAL GOVERNMENTS ... 8-8

8.7 EXECUTIVE ORDER 13045: PROTECTION OF CHILDREN FROM ENVIRONMENTAL HEALTH RISKS AND SAFETY 

RISKS .............................................................................................................................................................. 8-9

8.8 EXECUTIVE ORDER 13211: ACTIONS CONCERNING REGULATIONS THAT SIGNIFICANTLY AFFECT ENERGY 

SUPPLY, DISTRIBUTION, OR USE ..................................................................................................................... 8-10

8.9 NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT ............................................................. 8-10

8.10 EXECUTIVE ORDER 12898: ENVIRONMENTAL JUSTICE .......................................................................... 8-11
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

vi 

LIST OF TABLES 

Table ES-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed Emission Guidelines for 

Existing MSW Landfills in 2025 (2012$) ................................................................................................................ 3

Table ES-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Supplemental Proposed New 

Source Performance Standards for MSW Landfills in 2025 (2012$) ........................................................................ 5

Table 2-1 Generation and Discards of MSW, 1960 to 2012 (in pounds per person per day) ................................ 2-5

Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2012 (in thousands of tons) ................................... 2-7

Table 2-3 Top 5 Waste Management Companies That Owned or Operated MSW Landfills in the United States in 

2013a ................................................................................................................................................................ 2-14

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): 1995-2011 ......................................... 2-19

Table 2-6 Average LFG Power Production Technology Costs ................................................................... 2-302-29

Table 2-7 Average LFG Direct-use Project Components Costs .................................................................. 2-322-31

Table 2-8 Waste Management of Organics in the United States ................................................................. 2-402-39

Table 3-1 Number of Affected Landfills in 2025 under the Baseline and Alternative Options .............................. 3-8

Table 3-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and Alternative Options .... 3-9

Table 3-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-113-10

Table 3-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (3% Discount 

Rate) .......................................................................................................................................................... 3-133-11

Table 3-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate) ...... 3-

143-12

Table 3-6 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and Alternative Options ...... 3-

163-13

Table 3-7 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-163-13

Table 3-8 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and Alternative Options ...... 3-

173-14

Table 3-9 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-173-14

Table 3-10 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and Alternative Options .... 3-

183-15

Table 3-11 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 3-183-15

Table 4-1 Climate and Human Health Effects of Emission Reductions in this Rule ............................................. 4-2

Table 4-2 Social Cost of CH4, 2012 – 2050a [in 2012$ per metric ton] (Source: Marten et al., 2014b) ................ 4-12

Table 4-3 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) ..................................... 4-14

Table 4-4 Estimated Global Benefits of Net CO2 Reductions in 2025* (in millions, 2012$) .............................. 4-15

Table 4-5 Monetized Benefits-per-Ton Estimates for VOC based on Previous Modeling in 2015 (2012$) ......... 4-22

Table 4-6 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) ..................................... 4-35

Table 4-7 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) ..................................... 4-36

Table 4-8 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) ..................................... 4-36

Table 6-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed Emission Guidelines 

Option 2.5/34 in 2025 (2012$) ............................................................................................................................. 6-2

Table 6-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative Emission Guidelines 

Option 2.5/40 in 2025 (2012$) ............................................................................................................................. 6-3

Table 6-3 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative Emission Guidelines 

Option 2.0/34 in 2025 (2012$) ............................................................................................................................. 6-4

Table 7-1 Number of Affected Landfills in 2025 under the Baseline and Alternative Options .............................. 7-4

Table 7-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and Alternative Options .... 7-5

Table 7-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (7% Discount 

Rate) .............................................................................................................................................................. 7-77-6

Table 7-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative Options (3% Discount 

Rate) .............................................................................................................................................................. 7-97-7
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vii 

Table 7-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate) ...... 7-

107-8

Table 7-6 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) .............................. 7-137-10

Table 7-7 Estimated Global Disbenefits of Net CO2 Increases in 2025* (in millions, 2012$) ...................... 7-137-10

Table 7-8 Small Business Impact Screening Assessment Results (Reporters and Controllers) .................... 7-167-13

Table 7-9 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed NSPS Option 2.5/34 in 

2025 (2012$) .............................................................................................................................................. 7-177-14

Table 7-10 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Option 2.5/40 in 

2025 (2012$) .............................................................................................................................................. 7-207-16

Table 7-11 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Option 2.0/34 in 

2025 (2012$) .............................................................................................................................................. 7-217-17

Table 7-12 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and Alternative Options .... 7-

227-18

Table 7-13 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-227-18

Table 7-14 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and Alternative Options .... 7-

237-19

Table 7-15 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-237-19

Table 7-16 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and Alternative Options .... 7-

247-20

Table 7-17 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative Options (7% Discount 

Rate) .......................................................................................................................................................... 7-247-20

Table 7-18 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) ............................ 7-257-21

Table 7-19 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) ............................ 7-257-21

Table 7-20 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) ............................ 7-257-21

 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

viii 

LIST OF FIGURES 

Figure 2-1 Material Composition of the MSW Discard Stream, 2012 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 Well LFG Collection 2-262-25

Figure 4-1 Path from GHG Emissions to Monetized Damages (Source: Marten et al., 2014) 4-9

Figure 4-2 2005 NATA Model Estimated Census Tract Carcinogenic Risk from HAP Exposure from Emissions of 

All Outdoor Sources (inclusive of Residental Wood Heaters) based on the 2005 National Toxic Inventory. 4-28

Figure 4-3 2005 NATA Model Estimated Census Tract Noncancer Risk from HAP Exposure from Emissions of 

All Outdoor Sources (inclusive of Residental Wood Heaters) based on the 2005 National Toxic Inventory 4-29
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-1 

 EXECUTIVE SUMMARY 

ES.1 Background 

The U.S. Environmental Protection Agency (EPA) is proposing revisions to the Emission 

Guidelines for existing Municipal Solid Waste Landfills. The EPA is not statutorily obligated to 

conduct a review of the Emission Guidelines, but has the discretionary authority to do so when 

circumstances indicate that this is appropriate. Based on changes in the landfills industry and 

changes in size, ownership, and age of landfills since the Emission Guidelines were promulgated 

in 1996, the EPA has concluded that it is appropriate to review the landfills Emission Guidelines 

at this time. Based on our review, we are proposing to lower the annual NMOC emissions 

threshold from 50 Mg/year to 34 Mg/year.

In addition, the EPA is proposing Supplemental New Source Performance Standards for 

new or modified Municipal Solid Waste Landfills. On July 17, 2014, the EPA proposed a new 

NSPS subpart that retained the same design capacity size threshold of 2.5 million m3 or 2.5 

million Mg, but presented several options for revising the NMOC emission rate at which a MSW 

landfill must install controls. Since presenting these options, the EPA has updated its model that 

estimates the emission reduction and cost impacts based on public comments and new data. As a 

result of these data and model improvements, we are now proposing to lower the annual NMOC 

emissions threshold from 50 Mg/year to 34 Mg/year.

ES.2 Results for Proposed Revisions to Emission Guidelines 

For the proposed revisions to the Emission Guidelines for existing MSW landfills, the 

key results of the RIA follow and are summarized in Table ES-1: 

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 

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 compliance cost 

in 2025 to be $46.8 million (2012$) using a 7% discount rate. Using a 3% discount rate, the 

Commented [A1]: OMB RIA Comment 10: Reviewer 

recommends that the ES.1 background should more clearly articulate 

that the document represents the analysis for both emissions 

guidelines for existing landfills and NSPS for new landfills. 

EPA Response: This section now discusses the supplemental NSPS 

proposal. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-2 

nationwide incremental annualized compliance cost in 2025 is estimated to be $35 million 

(2012$). 

Emissions Analysis: In 2025, this proposal would achieve reductions of 2,770 Mg NMOC and 

436,100 Mg methane (10.9 million Mg CO2-equivalents1) compared to the baseline. In addition, 

the proposal is expected to result in the net reduction of 238,000 Mg CO2, due to reduced 

demand for electricity from the grid as landfills generate electricity from landfill gas.2 These 

pollutants are associated with substantial health, welfare and climate effects. 

Benefits: The monetized benefits in this RIA include those from reducing 436,100 Mg methane, 

which are valued using the social cost of methane (SC-CH4), and the reductions in CO2, which 

are valued using the social cost of carbon (SC-CO2). The EPA estimates that, in 2025, the 

proposal will yield monetized climate benefits of $310 million (2012$) to approximately $1.7 

billion (2012$)3; the mean SC-CH4 at the 3% discount rate results in an estimate of about $660 

million (2012$) in 2025. The climate benefits associated with the reduction of 238,000 Mg CO2

are estimated to be $12 million (2012$) in 2025. The benefits from reducing some air pollutants 

have not been monetized in this analysis due to data, resource, and methodological limitations, 

including reducing 2,770 Mg NMOC (including undetermined amounts of HAPs). We assessed 

the benefits of these emission reductions qualitatively in this RIA. 

Small Entity Analysis: The EPA certifies that the proposed Emission Guidelines will not have a 

Significant Impact on a Substantial Number of Small Entities (SISNOSE) because the proposed 

rule will not impose any requirements on small entities. Specifically, Emission Guidelines 

established under CAA section 111(d) do not impose any requirements on regulated entities and, 

thus, will not have a significant economic impact upon a substantial number of small entities. 

Economic Impacts: Because of the relatively low net compliance cost of this proposal 

compared to the overall size of the MSW landfill industry, as well as 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

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

2

 The reduced demand for electricity from the grid more than offsets the additional energy demand required to 

operate the control system and the by-product emissions from the combustion of LFG. 

3

 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

ES-3 

Table ES-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

Emission Guidelines for Existing MSW Landfills in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Total Monetized Benefits1 $670 million 

Total Costs2 $35 million $47 million 

Net Benefits $640 million $620 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 2,770 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 2,770 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 436,100 

Mg/yr methane ($660 million, valued using the social cost of methane) and the net reduction of 238,000 

Mg/yr of CO2 ($12 million, valued using the social cost of carbon). The social cost of methane and 

social cost of carbon estimates are calculated with four different values of a one ton reduction (model 

average at 2.5 percent discount rate, 3 percent, and 5 percent; 95th percentile at 3 percent). For the 

purposes of this table, we show the benefits associated with the model average at 3% discount rate; 

however we emphasize the importance and value of considering the full range of values, which is $310 

million - $1.8 billion for the proposed option. We provide climate benefit estimates based on additional 

discount rates in Section 4.2.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

ES.3 Results for Supplemental Proposed New Source Performance Standards 

For the Supplemental Proposed New Source Performance Standards for new or modified 

MSW landfills, the key results of the RIA follow and are summarized in Table ES-2: 

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 

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 compliance cost 

in 2025 to be $8.5 million (2012$) using a 7% discount rate. Using a 3% discount rate, the 

nationwide incremental annualized compliance cost in 2025 is estimated to be $7.1 million 

(2012$). 
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ES-4 

Emissions Analysis: In 2025, this proposal would achieve reductions of 300 Mg NMOC and 

51,400 Mg methane (1.3 million Mg CO2-equivalents4) compared to the baseline. The proposal is 

also expected to result in minor secondary air impacts, specifically an increase of 670 Mg CO2, 

because more energy is required to operate the GCCS at some landfills than is produced by these 

landfills through the burning of LFG in engines. These pollutants are associated with substantial 

health, welfare and climate effects. 

Benefits: The monetized benefits in this RIA include those from reducing 51,400 Mg methane, 

which are valued using the social cost of methane (SC-CH4), offset by the small increases in 

CO2, which are valued using the social cost of carbon (SC-CO2). The EPA estimates that, in 

2025, the proposal will yield monetized climate benefits of $36 million (2012$) to approximately 

$210 million (2012$)5; the mean SC-CH4 at the 3% discount rate results in an estimate of about 

$78 million (2012$) in 2025. The climate disbenefits associated with the increase of 670 Mg CO2

are estimated to be $0.03 million (2012$) in 2025. The benefits from reducing some air 

pollutants have not been monetized in this analysis due to data, resource, and methodological 

limitations, including reducing 300 Mg NMOC (including undetermined amounts of HAPs). We 

assessed the benefits of these emission reductions qualitatively in this RIA. 

Small Entity Analysis: The EPA performed a small business impacts analysis on the 

Supplemental Proposed New Source Performance Standards for new or modified MSW landfills, 

and as with the July 2014 proposed NSPS subpart certifies that the proposed rule will not have a 

Significant Impact on a Substantial Number of Small Entities (SISNOSE). The proposed revision 

does not impact a substantial number of small entities, and the impact to these entities are not 

significant. This is discussed in greater detail in Section 7.4.

Economic Impacts: Because of the relatively low net compliance cost of this proposal 

compared to the overall size of the MSW landfill industry, as well as 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.

 

4

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

5

 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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ES-5 

Table ES-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Supplemental Proposed New Source Performance Standards for MSW Landfills in 2025 

(2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $78 million 

Monetized CO2 disbenefits1 $0.03 million 

Total Costs2 $7.1 million $8.5 million 

Net Benefits $71 million $70 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 51,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 670 Mg/yr of CO2, valued 

using the social cost of carbon. The social cost of methane and social cost of carbon estimates are 

calculated with four different values of a one ton reduction (model average at 2.5 percent discount rate, 

3 percent, and 5 percent; 95th percentile at 3 percent). For the purposes of this table, we show the 

benefits associated with the model average at 3% discount rate; however we emphasize the importance 

and value of considering the full range of values, which is $36 million - $210 million for the proposed 

option. We provide climate benefit estimates based on additional discount rates in Section 4.2.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

ES.3 Organization of this Report 

The remainder of this report details the methodology and the results of the EIARIA. 

Chapter 1 provides an introduction. Chapter 2 presents the industry profile for the municipal 

solid waste landfill industry. Chapter 3 describes emissions, emissions control options, and 

engineering costs of the Emission Guidelines for existing landfills. Chapter 4 presents estimates 

of the benefits of emissions reductions from the Emission Guidelines for existing landfills. 

Chapter 5 present the economic impacts, employment impacts, and small entity screening 

analysis for the Emission Guidelines for existing landfills. Chapter 6 presents the comparison of 

the benefits and costs of the Emission Guidelines for existing landfills, Chapter 7 presents an 

analysis of the supplemental New Source Performance Standards (NSPS) for new or modified 

MSW landfills proposal, and Chapter 8 concludes with the statutory and executive order reviews. 
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1 INTRODUCTION 

1.1 Background 

The EPA is proposing revisions to the Emission Guidelines for existing Municipal Solid 

Waste Landfills. The EPA is not statutorily obligated to conduct a review of the Emission 

Guidelines, but has the discretionary authority to do so when circumstances indicate that this is 

appropriate. Based on changes in the landfills industry and changes in size, ownership, and age 

of landfills since the Emission Guidelines were promulgated in 1996, the EPA has concluded 

that it is appropriate to review the landfills Emission Guidelines at this time. Based on our 

review, we are proposing to lower the annual NMOC emissions threshold from 50 Mg/year to 34 

Mg/year. 

In addition, the EPA is proposing Supplemental New Source Performance Standards for 

new or modified Municipal Solid Waste Landfills. On July 17, 2014, the EPA proposed a new 

NSPS subpart that retained the same design capacity size threshold of 2.5 million m3 or 2.5 

million Mg, but presented several options for revising the NMOC emission rate at which a MSW 

landfill must install controls. Since presenting these options, the EPA has updated its model that 

estimates the emission reduction and cost impacts based on public comments and new data. As a 

result of these data and model improvements, we are now proposing to lower the annual NMOC 

emissions threshold from 50 Mg/year to 34 Mg/year.

In accordance with Executive Order 12866, Executive Order 13563, OMB Circular A-4, 

and the EPA’s “Guidelines for Preparing Economic Analyses,” the EPA prepared this RIA for 

these “significant regulatory actions.” These actions are economically significant regulatory 

actions because they may have an annual effect on the economy of $100 million or more or 

adversely affect in a material way the economy, a sector of the economy, productivity, 

competition, jobs, the environment, public health or safety, or state, local, or tribal governments 

or communities.6In this RIA, the EPA presents a profile of the municipal solid waste industry in 

 

6 The analysis in this draft RIA constitutes the economic assessment required by CAA section 317. In the EPA’s 

judgment, the assessment is as extensive as practicable taking into account the EPA’s time, resources, and other 

duties and authorities.
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1-2 

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 for this analysis. However, this dataset was missing 

some landfill data for recent years (2010-2014) and included incomplete data for many landfills. 

Thus, model landfills were created to represent the recent landfill data that were not included in 

the dataset. The model landfills were developed by evaluating the most recently opened existing 

landfills and assuming that the sizes and locations of landfills opening during 2010-2014 would 

be similar to the sizes and locations of landfills that opened in the most recent complete 5 years 

of data (2005-2010). The impacts of the proposed Emission Guidelines for existing MSW

landfills shown in this RIA are expressed as the incremental difference between facilities 

complying with the current Emission Guidelines for existing MSW landfills (40 CFR part 60, 

subpart Cc) and facilities that would be required to comply with proposed subpart Cf. Likewise, 

the impacts of the proposed NSPS for new or modified MSW landfills shown in this RIA are 

expressed as the incremental difference between facilities complying with the current NSPS for 

new or modified MSW landfills (40 CFR part 60, subpart WWW) and facilities that would be 

required to comply with proposed subpart XXX. All impacts are shown for the year 2025. The 

EPA is assessing impacts in year 2025 as a representative year for the both the landfills Emission 

Guidelines and NSPS. While the year 2025 differs somewhat from the expected first year of 

implementation for the Emission Guidelines (year 2020), the number of existing landfills 

required to install controls under the proposed 2.5/34 option in year 2025 is comparable (within 2 

percent of those required to control in the estimated first year of implementation. Further, year 

2025 represents a year in which several of the landfills subject to control requirements have had 

to expand their GCCS according the expansion lag times set forth in proposed subpart Cf. While 

the analysis focuses on impacts in 2025, results for alternative years are also presented. 

The EPA certifies that the proposed Emission Guidelines for existing landfills will not 

have a Significant Impact on a Substantial Number of Small Entities (SISNOSE) because the 

proposed rule will not impose any requirements on small entities. Specifically, Emission 

Guidelines established under CAA section 111(d) do not impose any requirements on regulated 

entities and, thus, will not have a significant economic impact upon a substantial number of 

small entities. The EPA also certifies that the supplemental proposed NSPS for new or modified 

MSW landfills also will not have a significant impact on a substantial number of small entities 

Commented [A2]: OMB RIA Comment 9: Reviewer 

recommends clearly articulating the analytic timeline since EPA 

only presents results in the RIA for a snapshot of 2025. 

EPA Response: The discussion has been edited to explain the 

choice of 2025 as a representative year. This discussion also added 

to Sections 3.2 and 7.2. In addition, some results from alternative 

snapshot years are now being included in Chapters 3, 4, and 7. 
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(SISNOSE). The proposed revision does not impact a substantial number of small entities, and 

the impact to these entities are not significant. This is discussed in greater detail in Section 7.4.

1.2 Statement of Need for Policy Action 

1.2.1 Protection of Human Health and the Environment 

The EPA has concluded, after reviewing data on MSW landfills, that a review of the 

Emission Guidelines for existing MSW landfills is appropriate at this time. In addition, the EPA 

is proposing Supplemental New Source Performance Standards for new or modified Municipal 

Solid Waste Landfills. To ensure that public health, safety, and the environment are protected, 

the EPA must ensure that emissions of methane, VOC, and HAP from MSW landfills are 

limited. The pollutant regulated under rules affecting landfills is “MSW landfill emissions”. 

Municipal solid waste landfill emissions, also commonly referred to as landfill gas (LFG), are a 

collection of air pollutants, including methane and NMOC, some of which are toxic.

7 The 1996 

NSPS/EG regulated nonmethane organic compounds (NMOC) as a surrogate for MSW landfill 

emissions but also considered significant methane reductions that could be achieved. In this EG 

and supplemental NSPS proposal, weWe are proposing to lower the annual NMOC emissions 

threshold from 50 Mg/year to 34 Mg/year. The proposed Emission Guidelines are expected to 

result in significant emissions reductions from existing MSW landfills. For the proposed 

Emission Guidelines, there will be climate benefits and HAP, ozone and PM2.5 health “cobenefits”. These co-benefits occur because the control techniques to meet the standards 

simultaneously reduce methane, VOC, and HAP emissions. The NMOC portion of LFG can 

contain a variety of air pollutants, including VOC and various organic HAP. VOC emissions are 

precursors to both fine particulate matter (PM2.5) and ozone formation, while methane is a 

greenhouse gas and a precursor to global ozone formation. As described in Chapter 4, these 

 

7 LFG is composed of approximately 50 percent methane, 50 percent CO2, and less than 1 percent NMOC. (Source: 

EPA. Compilation of Air Pollution Emission Factors, Publication AP-42, Draft Section 2.4 Municipal Solid 

Waste Landfills. October 2008. Available at http://www.epa.gov/ttn/chief/ap42/ch02/draft/d02s04.pdf.) While 

this composition is typical of LFG generated from established waste (waste that has typically been in place for at 

least a year), the quantity and composition of LFG does vary over the lifetime of the landfill. See Section 2.5 for 

more discussion. 

Commented [A3]: OMB RIA Comment 12: Reviewer requests 

providing a citation for 50% of landfill gas being composed of 

methane. 

EPA Response: Reference added in footnote. 

Commented [A4]: OMB RIA Comment 16: Reviewer 

recommends stating in 1.2.1 the requirements relevant to methane. 

Otherwise, it’s not clear why methane isn’t included in the cobenefit category. 

EPA Response: This discussion has been edited to indicate that 

NMOC is a surrogate for MSW landfill emissions, which is the 

regulated pollutant. MSW landfill emissions are composed of 

methane, CO2, and NMOC. In the 1996 NSPS/EG, it was noted that 

“The emissions of concern are non-methane organic compounds 

(NMOC) and methane.” Therefore, while NMOC has always been 

the emission measured to determine if a control system must be in 

place, methane has always been a targeted emission as well. 
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pollutants are associated with substantial health effects, climate effects, and other welfare effects. 

Thus, the proposed rule is expected to reduce human morbidity and premature mortality due to 

exposure to PM2.5, in addition to providing human health and ecosystem benefits due to reduced 

emissions of methane and HAP, and improved visibility due to reduced PM levels.

1.2.2 Need for Regulatory Intervention Because of Market Failure 

The U.S. Office of Management and Budget (OMB) directs regulatory agencies to 

demonstrate the need for a major rule. If the rule is intended to correct a market failure, the 

regulatory impact analysis must show that a market failure exists and that it cannot be resolved 

by measures other than Federal regulation. Market failures are categorized by OMB as 

externalities, market power, or inadequate or asymmetric information. The following paragraphs 

address each of the three categories of market failure as they apply to MSW landfills. The only 

of these three categories that applies to MSW landfills is air pollution as an externality, which is 

discussed in the following section.

1.2.2.1 Air Pollution as an Externality 

Air pollution is an example of a negative externality. This means that, in the absence of 

government regulation, the decisions of generators of air pollution do not fully reflect the costs 

associated with that pollution. For an MSW landfill operator, pollution from landfill gas is a byproduct that can be ignored or disposed of cheaply by venting it to the atmosphere. Left to their 

own devices, many MSW landfill operators may choose to treat air as a free good and not 

internalize the damage cause by emissions. NMOC and Greenhouse Gas (GHG) emissions 

impose costs on society, such as negative health and welfare impacts that are not reflected in the 

market price of the MSW landfill services being provided. This damage is borne by society, and 

the people who are adversely affected by the pollution are not able to collect compensation to 

offset their costs. They cannot collect compensation because the adverse effects, like odor and 

increased risks of morbidity and mortality, are by and large non-market goods. That is, they are 

goods that are not explicitly and routinely traded in organized free markets. 
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1-5 

1.2.2.2 Market Power 

In some respects, local disposal markets are natural monopolies. There are large 

economies of scale in disposal operations, there are barriers to entry through the large up-front 

capital costs necessary to construct a landfill, and in some situations transportation costs are too 

high to ship MSW between regions for disposal (though this is less the case in recent years). 

Unfortunately, the monopolistic (or oligopolistic) local markets that result from these natural 

conditions do not have the competitive market checks and balances that are needed to ensure the 

best utilization of societal resources. While the proposed Emission Guidelines are not designed 

to address the problem of market power, they are intended to ensure that MSW landfills operate 

in a more socially optimal manner. 

1.2.2.3 Inadequate or Asymmetric Information 

The third category of potential market failure that is sometimes used to justify 

government regulation is inadequate or asymmetric information. Some MSW landfills can 

reduce costs by installing gas collection systems, recovering energy from the gas, and selling 

purified gas or electricity. Due to the costs associated with obtaining information about the 

potential costs and benefits of control, some landfills do not install such systems. The Emission 

Guidelines would specify the collection of information that may reduce the cost of obtaining data 

to make an informed decision on whether energy recovery is a good option.

1.3 Organization of this Report 

The remainder of this report details the methodology and the results of the RIA. Chapter 

2 presents the industry profile for the municipal solid waste landfill industry. Chapter 3 describes 

emissions, emissions control options, and engineering costs of the Emission Guidelines for 

existing landfills. Chapter 4 presents estimates of the benefits of emissions reductions from the 

Emission Guidelines for existing landfills. Chapter 5 present the economic impacts, employment

impacts, and small entity screening analysis for the Emission Guidelines for existing landfills. 

Chapter 6 presents the comparison of the benefits and costs of the Emission Guidelines for 

existing landfills, Chapter 7 presents an analysis of the supplemental New Source Performance 

Standards (NSPS) for new and modified MSW landfills proposal, and Chapter 8 concludes with 

the statutory and executive order reviews. 

Commented [A5]: OMB RIA Comment 17: Reviewer 

recommends deleting the discussion in 1.2.2 of market power and 

inadequate/asymmetric information since they are not relevant to 

this rulemaking. 

EPA Response: Sections have been deleted. 
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1.4 References 

U.S. Environmental Protection Agency (EPA). 2008. Compilation of Air Pollution Emission 

Factors, Publication AP-42, Draft Section 2.4 Municipal Solid Waste Landfills. October 

2008. Available at http://www.epa.gov/ttn/chief/ap42/ch02/draft/d02s04.pdf.
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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 (EG) for MSW landfills regulate air 

emissions from landfills that receive household waste as defined in 40 CFR 60.751. 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, 2012b). 

EPA estimates the total amount of MSW generated in the United States in 2012 was 

approximately 251 million tons, a 20 percent increase from 1990. Despite increased waste 

generation, the amount of MSW deposited in landfills decreased from about 145 million tons in 

1990 to 135 million tons in 2012. 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, 2014a). The number of active MSW landfills in the United States has decreased from 

approximately 7,900 in 1988 to approximately 1,800 in 2014 (EPA, 2010; WBJ, 2014). 

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 (NMOC) 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 95 percent of landfill emissions. The remainder of the emissions 

is generated by industrial waste landfills (EPA, 2015h).

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. 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 2014, 58 percent of active MSW landfills were owned by public entities while 

42 percent were privately owned (EPA, 2014c). 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 of dollars 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 MSW 

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; Shin, 2014). 

2.2.1.2 Landfills Covered Under the EG 

The Landfills 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 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 2012, Americans generated about 251 million tons of trash. More than 65 million tons 

of this material was recycled and more than 21 million tons was composted, equivalent to a 34.5 

percent recycling rate (EPA, 2014a). In addition, about 29 million tons of waste was combusted 

for energy recovery (~12 percent) (EPA, 2014a). After recycling, composting, and combustion 

with energy recovery, the net per capita discard rate to landfills was 2.36 pounds per person per 

day in 2012 (EPA, 2014a). This is a 6 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 about 10 million 

tons, from 145 million to 135 million tons in 2012 (EPA, 2014a). While the number of U.S. 

MSW 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, 2014a). 
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Table 2-1 Generation and Discards of MSW, 1960 to 2012 (in pounds per person per day) 8

Activity 1960 1970 1980 1990 2000 2005 2008 2010 2011 2012

Generation 

 2.68 3.25 3.66 4.57 4.74 4.69 4.55 4.44 4.40 4.38 

Discards to landfill a

2.51 3.02 3.24 3.19 2.73 2.63 2.46 2.41 2.36 2.36 

Discards to landfill 

(% of total generation) 94% 93% 89% 70% 58% 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 

In 2012, organic materials continued to be the largest component of discarded MSW. 

Yard trimmings and food scraps account for 29.8 percent and paper and paperboard account for 

another 14.8 percent. Plastics comprise 17.6 percent while metals and wood make up 9.0 percent 

and 8.2 percent, respectively. Rubber, leather, and textiles combined account for 11.2 percent 

and glass accounts for 5.1 percent. Other miscellaneous materials account for the remaining 

4.3 percent of the MSW discarded in 2012 (EPA, 2014a). Figure 2-1 displays material 

composition percentages of the MSW discard stream in 2012, and Table 2-2 shows the amounts 

of different materials discarded in the MSW stream from 1960 to 2012. 

 

8

 Table adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, Recycling, 

and Disposal in the United States: Facts and Figures for 2012.” Table 4. EPA-530-F-14-001. Washington, DC: 

U.S. EPA. <http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_fs.pdf>. Accessed January 6, 2015. 
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Figure 2-1 Material Composition of the MSW Discard Stream, 20129

 

 

9

 Figure adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, 

Recycling, and Disposal in the United States: Facts and Figures for 2012.” Figure 7. EPA-530-F-14-001. 

Washington, DC: U.S. EPA. <http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_fs.pdf>. Accessed 

January 6, 2015.

21.1%

8.2%

17.6%

5.1%

9.0%

8.7%

14.8%

4.3%

11.2%

Food waste

Wood

Plastics

Glass

Metals

Yard trimmings

Paper & paperboard

Other

Rubber, leather & textiles
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Table 2-2 Materials Discardeda In the MSW Stream, 1960 to 2012 (in thousands of tons)10

Wastes 1960 1970 1980 1990 2000 2005 2010 2012 

Paper and Paperboard 24,910 37,540 43,420 52,500 50,180 42,880 26,740 24,260 

Glass 6,620 12,580 14,380 10,470 9,890 9,950 8,400 8,370 

Metals 10,770 13,350 14,290 12,580 12,340 13,410 14,500 14,760 

Plastics 390 2,900 6,810 16,760 24,070 27,600 28,790 28,950 

Rubber and Leather 1,510 2,720 4,070 5,420 5,850 6,240 6,120 6,180 

Textiles 1,710 1,980 2,370 5,150 8,160 9,680 11,100 12,080 

Wood 3,030 3,720 7,010 12,080 12,200 12,960 13,430 13,410 

Other Materialsb

70 470 2,020 2,510 3,020 3,080 3,370 3,300 

Food Waste 12,200 12,800 13,000 23,860 30,020 32,240 34,770 34,690 

Yard Trimmings 20,000 23,200 27,500 30,800 14,760 12,210 14,200 14,370 

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

Total MSW Discarded 82,510 113,040 137,120 175,030 173,990 173,940 165,260 164,270

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 

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 

 

10 Table adapted from U.S. Environmental Protection Agency. 2014. “Municipal Solid Waste Generation, 

Recycling, and Disposal in the United States Tables and Figures for 2012.” Table 3. Washington, DC: U.S. EPA. 

<http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_dat_tbls.pdf>. Accessed January 15, 2015. 
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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, 2012b). 

2.3.1.1 Landfill Siting and Permitting 

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

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, 2012b). 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 

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 
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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 soil and other materials 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 

generally less desirable than the area fill method, mostly due to the expense of lining side slopes 

to protect groundwater from leachate leakage and restrict gas migration (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 (NW&RA, 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 

landfill conditions and maintaining the landfill as a controlled facility. If an active LFG 

collection system is installed, then gas wells are monitored to ensure oxygen is not being pulled 

into the landfill due to excessive vacuum levels. 
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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 (NW&RA, 2008). If an LFG 

collection 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 2.6. 

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, 2012c). 

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) (NW&RA, 2008). Landfill liner systems 

also help prevent offsite 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 

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. 
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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, 2012d). 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 1980s, the number of active MSW landfills in the United States has decreased 

by approximately 75 percent (from ~7,900 in 1988 to ~1,800 in 2014) and the share of sites that 

are publicly owned has also decreased—from 83 percent in 1984 to 58 percent in 2014 (EPA, 

2010; WBJ, 2014; O’Brien, 2006; EPA, 2014c). However, the overall volume of disposal 

capacity has remained fairly constant, indicating a trend of growing individual landfill capacity 

(SWANA, 2007). Based on landfills reporting to the EPA Greenhouse Gas Reporting Program 

(GHGRP) that they were actively accepting waste in 2013, privately owned sites represented 73 

percent of the overall permitted MSW landfill capacity and 73 percent of the MSW landfilled in 

that year, an indication that private landfills are likely to be significantly larger than public ones 

(GHGRP, 2013). Among these reporting sites, the average annual amount of MSW disposed at 

public sites was just under 175,000 short tons, whereas the average private site landfilled about 

427,000 short tons of MSW per year—further evidence that publicly owned landfills are 

generally much smaller than their private counterparts (GHGRP, 2013). 

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 

existing sites and to the idea of regional landfills (EPA, 2002b). The passage of federal 
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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 2012e; 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, often using shipments from rail or truck (BioCycle, 2014a). 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, 2012f). Given the 

dramatic decrease in the number of active landfills in the past 25 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 100 private companies that own and/or operate currently active 

MSW landfills, ranging from large companies with numerous landfills throughout the country to 

local businesses that own a single landfill (EPA, 2014c). The handling of MSW in the United 

States generated $55 billion of revenue in 2011, of which landfilling contributed $13 billion 

(WBJ, 2012a). In terms of their overall 2013 revenue, the top two companies that own and/or 

operate MSW landfills in the United States were Waste Management ($13.98 billion) and 

Republic Services ($8.42 billion), which together accounted for approximately 40 percent of the 

solid waste management revenue share in 2013 (Bloomberg, 2014WM; Bloomberg, 2014RSG). 

The next tier of companies involved in landfill management includes Clean Harbors ($3.51 

billion), Progressive Waste Solutions ($2.03 billion), and Waste Connections ($1.93 billion) 

(Bloomberg, 2014CLH; Bloomberg, 2014BIN; Bloomberg, 2014WCN). Table 2-3 contains a 

summary of the 2013 revenue for the top five companies, as well as information about their 

MSW landfills and transfer stations. 
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Table 2-3 Top 5 Waste Management Companies That Owned or Operated MSW 

Landfills in the United States in 2013a

Company 

2013 

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, 

2014WM)

13.98 267 93.8 300 

Republic Services 

(Bloomberg, 

2014RSG)

8.42 

190 active/ 

124 closed 

N/A 199 

Clean Harbors 

(Bloomberg, 

2014CLH)

3.51 2 N/A N/A 

Progressive Waste 

Solutions 

(Bloomberg, 

2014BIN)

2.03 N/A N/A N/A 

Waste Connections 

(Bloomberg, 

2014WCN)

1.93 42 active 19.5 61 

a Ranking of top five companies adapted from “The 2013 Waste Age 100”. <http://waste360.com/%5Bprimaryterm%5D/2013-waste-age-100-premium>. Accessed January 16, 2015. 

N/A = 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 2012, 1,290 private 

establishments had 15,426 employees in the continental United States under NAICS 562212 

(Solid Waste Landfill) (Census, 2012). In 2013, solid waste management departments of local 

governments reported 95,674 full-time employees and 14,638 part-time employees (Census, 

2013); 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, 2015h). 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, 2012g). 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, LFG migration controls, closure requirements, and postclosure requirements (EPA, 2012g). 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 onsite structures needed to operate the landfill. Cortland County, New York estimated 

that the cost for site development and cell construction (not including onsite 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 on 

site 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 

operating costs dependent on fuel, repairs, and maintenance. Operating costs are relatively small 
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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 2.6 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). 
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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 (NW&RA, 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 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, 2012b), while the national average for only the largest public and 

private landfills was about $49 per ton (KleanIndustries, 2012). This compares to average 

national tip fees of approximately $32 in 1998 (Repa, 2005) and $8 in 1985 (NW&RA, 2011). 
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Average tip fees also 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. 

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): 1995-2011 

U.S. Region 1995a 1998a 2000a 2002a 2004a 2008b 2010c 2011d

Northeast $73 $67 $70 $69 $71 $67 NA $78 

Mid-Atlantic $46 $44 $46 $45 $46 $56 NA $65 

South $29 $31 $31 $30 $31 $32 NA $39 

Midwest $31 $31 $33 $34 $35 $39 NA $43 

South Central $20 $21 $22 $23 $24 $34 NA $33 

West Central $23 $23 $22 $23 $24 $39 NA $35 

West $38 $36 $35 $39 $38 $44 NA $55 

National $32 $32 $32 $34 $34 $42 $44 $50 

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: Shin, 2014 (data reported from Waste & Recycling News).

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 
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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 (300 percent) or an average of $2.40 per year. From 1985 to 2008, tipping fees 

for private landfills increased an average of $1.25 per year but these private fees increased by 

about $1.95 per year between 2004 and 2008 (KleanIndustries, 2012). 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 
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tip fees and total landfill revenues, but can help offset some landfill expenses, for example, the 

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

these potential revenue sources is available in Section 2.6. 

2.5 Air Pollutant Emissions from Landfills 

MSW landfills are a source of 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, 2012h). LFG generated from established waste 

(waste that has been in place for at least a year) is typically composed of roughly 50 percent 

methane and 50 percent carbon dioxide by volume, with trace amounts of NMOC and inorganic 

compounds (e.g., hydrogen sulfide) (EPA, 2015a; EPA, 2012h). 

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, 2012h). 

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., methane or carbon dioxide) and become part of the LFG (EPA, 

2012h). 
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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 

(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, 2012h). 

2.5.2 Methane in LFG 

Methane is 28-3625 times more effective at retaining heat in the earth’s atmosphere than 

carbon dioxide, over a 100 year time horizon, and therefore is considered a potent GHG (IPCC, 

20072013).11 In 2012, landfills were the third-largest anthropogenic source of methane emissions 

in the United States, with MSW landfills accounting for approximately 15 percent of the total 

methane emissions from all sources (EPA, 2015h).The carbon dioxide generated from MSW 

landfills is deemed biogenic because the carbon dioxide 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, 2015a). 

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

availability of oxygen at this stage means that carbon released from the decomposition of organic 

waste materials is in the form of carbon dioxide, and little methane is produced. during which 

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

anaerobic, methane generation increases, and the amount of carbon dioxide produced begins to 

level out (EPA, 2015a). Figure 2-3 presents a sample LFG generation curve over time for a 

typical MSW landfill. Significant methane generation can continue for 10 to 60 years after initial 

waste placement (EPA, 2012h). 

 

11 Note that this proposal uses a GWP value for methane of 25 for CO2 equivalency calculations, consistent with the 

GHG emissions inventories and the IPCC Fourth Assessment Report.

Commented [A6]: OMB RIA comment 28: Reviewer notes 

that the RIA currently does not discuss the climate impacts of the 

oxidization of CH4 into CO2 into the atmosphere. While it is likely 

that these impacts are small when offset by other considerations, a 

discussion that these impacts were considered would be appropriate. 

For example, such a discussion occurs in section 4.7 of the Oil and 

Gas rule RIA. 

EPA response: We don’t account for the CO2 because it is deemed 

biogenic and 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. In other words, the increase in 

atmospheric carbon dioxide concentration associated with the 

decomposition of organic waste materials would have occurred in 

the baseline and is not affected by the proposed rule. The new text in 

the RIA, pgs 2-22 and 2-23, clarifies this point. 
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Figure 2-3 Typical LFG Generation Curve 

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

United States, with MSW landfills accounting for approximately 15 percent of the total methane 

emissions from all sources (EPA, 2015h). Increasing attention is being given to mitigation of

methane, given its global warming potential 25 times greater than carbon dioxide and its 

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

dioxide) (EPA, 2015h). 

As methane oxides in the atmosphere, the carbon in methane is converted to carbon 

dioxide. Both the carbon dioxide generated directly from aerobic decomposition in MSW 

landfills and created as a result of methane oxidation in the atmosphere is deemed biogenic 

because the carbon dioxide 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, 

2015a). In other words, the increase in atmospheric carbon dioxide concentration associated with 

the decomposition of organic waste materials would have occurred in the baseline and is not 

affected by the proposed rule.
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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 

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

information about LFG combustion devices is available in Section 2.6. 

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 NMOC are required by the MSW landfills EG 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) LFG Energy Project Development Handbook 

(EPA, 2015a). 

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 or horizontal wells, and some collection systems 

involve a combination of the two. Vertical wells (Figure 2-4) are the most common method of 
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LFG collection and involve drilling wells vertically in the waste to collect gas. Horizontal wells 

(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. 

Source: EPA, 2015a 

Figure 2-4 Vertical Well LFG Collection 
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Source: EPA, 2015a 

Figure 2-5 Horizontal Well 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 (EPA, 1998). 

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 50 to 95 percent, with an average of 75 percent most 

commonly assumed (EPA, 1998; Sullivan, 2010; EPA, 2015a). In the current GHGRP 

requirements for MSW landfills (40 CFR part 98, subpart HH), LFG collection efficiencies vary 

for active gas collection systems depending upon cover material type, with daily soil cover 

assigned 60 percent, intermediate/final soil cover assigned 75 percent (also the default value), 

and final soil cover of three feet or thicker of clay and/or geomembrane cover system assigned 

95 percent. 

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

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

2012 $’s) required for a 40-acre collection system is $897,000, assuming one well is installed per 

acre. Typical annual operation and maintenance (O&M) costs (in 2012 $’s) for collection 

systems are approximately $2,500 per well, or $100,000 for a 40-acre system (EPA, 2014b). 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 landfills EG (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 

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

used at landfills meeting the criteria in 40 CFR 60.18(b) have been demonstrated to have 

destruction efficiencies similar to enclosed flares. 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, 2001). Enclosed flares are 

more expensive but may be preferable (or required by state regulations) because they provide 
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greater control of combustion conditions and allow for stack testing. They can also reduce noise 

and light nuisances. 

Flare costs vary based on the gas flow of the system. LFGcost-Web 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-Web (in 2012$), a flare for a system designed for 600 cubic 

feet per minute (cfm) of LFG will cost $223,000 (including condensate collection and blowers). 

Typical annual O&M costs (in 2012$) are approximately $5,000 per flare. Electricity costs to 

operate the blower for a 600-cfm active gas collection system would be $53,000 per year, 

assuming an electricity price of $0.085 per kilowatt-hour (kWh) (EPA, 2014b). 

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 640 LFG energy projects are currently operating in 48 states and 

Puerto Rico. 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, 2015b). 

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 

impurities. (While “treatment” has a specific meaning within the MSW landfills EG, 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 
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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, 2015b). 

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. 
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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 as well as interconnection costs. 

Table 2-6 Average LFG Power Production Technology Costs 

Technology 

Typical Size Used 

to Estimate Costs 

Typical Capital 

Costs ($/kW)a

Typical Annual O&M 

Costs ($/kW)a

Internal combustion engine 3,000 kW $1,700 $200 

Small internal combustion engine 500 kW $2,500 $220 

Gas turbine 10,000 kW $1,400 $130 

Microturbine 200 kW $2,900 $220 

Source: EPA, 2014b 

a

 2012$ 

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. 
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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 

(EPA, 2014b). 

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 
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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,b 

Gas compression and treatment $1,200/cfm $130/cfm 

Gas pipeline and condensate 

management system 

$449,000/mile Negligible 

Source: EPA, 2014b 

a

 2012$, based on a 1,000-cfm system with a 5-mile pipeline 

cfm: cubic feet per minute 

b

 Assuming an electricity price of $0.085 per kWh

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. 

Capital costs of high-Btu processing equipment (in 2012$) range from $2,500 per cfm 

LFG for a 10,000-cfm processing system to $5,900 per cfm LFG for a 1,000-cfm processing 
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system. The annual cost to provide electricity to, operate, and maintain these systems (in 2012$) 

is approximately $500 per cfm LFG (EPA, 2014b). Costs will depend on the purity of the highBtu 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. 

For alternative fuel projects, the capital costs of converting LFG into CNG also vary, 

depending primarily on the quantity of fuel being converted and the type of fueling station 

equipment. Similar to high-Btu processing equipment, some economies of scale are realized for 

larger volumes of gas. The capital costs for onsite CNG production with a fueling station (in 

2012$) ranges from $7,200 per cfm LFG for a 600-cfm project to $14,800 per cfm LFG for a 

100-cfm project. The annual cost to operate and maintain a CNG project (in 2012$), including 

media and equipment replacement, is approximately $1 per gallon of gasoline equivalent 

produced by the system, or $0.003 per cfm LFG assuming a conversion efficiency of 65 percent 

and a fuel use rate of 111,200 Btu per gallon of gasoline equivalent (EPA, 2014b). 

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 GHG Credits 

Voluntary GHG 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 GHG 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, Blue Source, and Chicago Climate Exchange (EPA 2012a). 

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

trades are project-specific and are negotiated directly between a buyer and seller of GHG credits. 

In these cases, corporate entities or public institutions, such as universities, may wish to reduce 
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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 GHG emissions from their organization. 

Many state and regional government entities are establishing their own GHG initiatives to 

cap or minimize GHG emissions within their jurisdictions. Examples include the Regional 

Greenhouse Gas Initiative (RGGI), the Washington carbon dioxide offset program, and 

Massachusetts’ carbon dioxide reduction from new plants. Some of these programs establish a 

cap-and-trade program on carbon dioxide emissions, while others require 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 11 cents per 

kWh (EPA, 2014b). 

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 
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“green,” energy resource. These additional revenues can come from premium pricing, tax credits, 

GHG 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-Web 

accommodates four common types of electricity project credits: a direct cash grant, an electricity 

generation tax credit expressed in dollars per kWh, a direct GHG (carbon) reduction credit 

expressed in dollars per metric ton of carbon dioxide equivalent (discussed in Section 2.6.4.2.1), 

and a direct renewable electricity credit expressed in dollars per kWh. This section 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 tax credit, commonly referred to as the renewable electricity Production Tax Credit 

(PTC), for power generated at privately owned LFG electricity projects. To qualify for the credit, 

which was 1.1 cent per kWh for the 2014 calendar year, all electricity produced must be sold to 

an unrelated person during the taxable year. Under legislation passed in December 2014, the 

placed-in-service date deadline for LFG energy projects to be eligible was extended to December 

31, 2014 (DSIRE, 2015). 
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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 

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 $1.50 to $4.00 

per million British thermal units (MMBtu) or 0.14¢ to 0.38¢ per megajoule (EPA, 2013). 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. Specific to vehicle fuel, EPA’s Renewable Fuel 

Standard (RFS) program allows registered renewable fuel producers, including biofuels 

produced from LFG, to generate Renewable Identification Number (RIN) credits for the 

renewable fuel produced which are purchased by parties required to meet specified volumes of 

renewable fuel (EPA, 2014d). In 2014, RIN credits for advanced biofuels (such as LFG-based 

biogas) were between $0.74 and $1.00 per RIN, equivalent to a range of $9 to $13 per million 

Btu (ABC, 2014). GHG emissions trading programs are also potential revenue streams for directuse projects. 

2.7 Integrated Waste Management Strategies 

2.7.1 Introduction 

Landfills are one method of waste disposal, but alternative strategies are available for the 

treatment of MSW, and multiple strategies are often used in combination. EPA has developed a 

non-hazardous waste management hierarchy that ranks the most environmentally sound 

strategies for MSW. Source reduction and reuse (waste prevention) is the most preferred method, 

followed by recycling and composting, energy recovery, and, lastly, treatment and disposal 

(EPA, 2015c). 

Waste prevention is the practice of designing products to reduce the amount of waste that 

will later need to be thrown away, which may result in less toxic waste (EPA, 2015d). Recycling 
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involves the recovery of useful materials, such as paper, glass, plastic, and metals from trash and 

using these materials to make new products. Recycling saves resources, including energy, raw 

materials, and landfill space. 

The diversion of organic materials, such as food scraps and yard waste (e.g., lawn 

trimmings, fallen leaves and branches), from landfills allows these materials to be used to create 

compost or generate energy. The management of organic materials is discussed in Section 2.7.2. 

Alternatively, MSW can be directly combusted in waste-to-energy facilities to generate 

electricity. At the power plant, MSW is unloaded from collection trucks and shredded or 

processed to ease handling. Recyclable materials are separated out, and the remaining waste is 

fed into a combustion chamber to be burned. The heat released from burning the MSW is used to 

produce steam, which turns a steam turbine to generate electricity (EPA, 2015e). 

Landfilling is often used as part of an integrated waste management strategy (e.g., where 

the same community has recycling programs, yard waste composting, and landfilling) and LFG 

can often be used for energy recovery as described in Section 2.6.4. LFG energy projects aim to 

recover and beneficially utilize methane generated from waste that has not been successfully 

diverted from landfills. The promotion of LFG energy is not in conflict with the promotion of 

organic waste diversion, nor does it compete with waste prevention or recycling, but allows LFG 

energy projects to utilize methane generated from millions of tons of organic waste already 

disposed in landfills while supporting future diversion of organic waste from landfills to reduce 

the amount of uncontrolled methane generated. In addition, some studies have shown that 

diverting waste from landfills may not always result in a comparative reduction in GHG 

emissions when efficient LFG collection systems and lifecycle emissions (from transportation 

and processing of organic waste) are taken into account (EPA, 2015f). 

2.7.2 Organics Management 

As detailed in Section 2.2.1.4, food waste, yard debris, and other organic materials 

continue to be the largest component of MSW discarded, with food waste comprising the largest 

portion (EPA, 2014a). Decreasing the amount of organics disposed in landfills would reduce the 

amount of LFG generated. If diverted from disposal in landfills, organic wastes can be 

composted or anaerobically digested. 
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Composting is the controlled biological decomposition of organic material in the 

presence of air to form a humus-like material. Controlled methods of composting include 

mechanical mixing and aerating, ventilating the materials by dropping them through a vertical 

series of aerated chambers, or placing the compost in piles out in the open air and mixing the 

piles periodically (EPA, 2015g). Diverted organic materials can also be used in an anaerobic 

digester, although digesters generally handle relatively small quantities of easily digestible 

waste. BioCycle identified nearly 5,000 composting facilities in the United States, with about 70 

percent composting only yard trimmings and 7 percent composting food scraps (BioCycle, 

2014a). 

Anaerobic digestion involves the conversion of organic matter to energy by 

microbiological organisms in the absence of oxygen. The biogas produced in the digestion 

process is a mixture of methane and carbon dioxide and can be used as a fuel source for heating 

or electricity production. Organic waste can either be digested at facilities specifically designed 

for the organic portion of MSW, or co-digested at wastewater treatment plants and manure 

digesters. The number of anaerobic digesters in the United States that process MSW-based 

wastes is on the rise from the first commercial scale plant coming online by 2010 up to more 

than seven plants operating by 2013, some of them digesting food waste alone and others codigesting food waste with wastewater and other organics (Arsova, 2010; RWI, 2013a; RWI, 

2013b). 

2.7.2.1 Trends 

States and municipalities in the United States are increasingly moving toward the 

diversion of organic wastes from landfills. State initiatives to recycle organic wastes have 

contributed to the growth of curbside organics collection as well as commercial and institutional 

collection and treatment. Table 2-8 lists the 21 states that have mandated organics diversion 

and/or banned disposal of organics from landfills. In particular, five states (California, 

Connecticut, Massachusetts, Rhode Island, and Vermont) have enacted legislation for organics 

disposal specific to food waste (BioCycle, 2014b; MSW Management, 2015). At a local level, 

BioCycle’s Fall 2014 survey identified 198 communities in 19 states with curbside collection of 

food scraps, as shown in Table 2-8. Between 2009 and 2014, the number of municipalities with 

source separated food waste collection more than doubled (from 90 to 198) and the number of 
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households grew by nearly 50 percent (BioCycle, 2015). The assortment of organics 

management initiatives and programs at state and local levels varies across the country by: 

• Type of organic wastes targeted (e.g., food waste, yard waste); 

• Source of organic waste generation (e.g., commercial, residential, institutional); 

• Phase of implementation (from pilot projects to mandatory requirements with fines 

for violations); and 

• Pricing formats (e.g., “pay-as-you-throw,” property tax, fixed fee) (BioCycle, 2015). 
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Table 2-8 Waste Management of Organics in the United States 

State State-wide Organics 

Diversion Mandate and/or 

Disposal Ban1,2,3

Local Residential Food 

Waste Collection 

Program4

Arkansas 

California (FW) 

Colorado 

Connecticut (FW) 

Delaware 

Illinois 

Indiana 

Iowa  

Kentucky 

Maryland  

Massachusetts (FW) 

Michigan 

Minnesota  

Nebraska 

New Hampshire 

New Jersey  

New York 

North Carolina 

Ohio  

Oregon 

Rhode Island2 (FW)

Pennsylvania  

South Carolina 

South Dakota 

Tennessee 

Texas 

Vermont (FW) 

Washington 

Wisconsin  

Number of States 21 19 

FW = Food waste diversion mandate and/or disposal ban

1

 Source: BioCycle, 2014a. Survey results from 39 states that responded. 

2

 Source: BioCycle, 2014b. Rhode Island legislation goes into effect January 2016. 

3

 Source: MSW Management, 2015. 

4

 Source: BioCycle, 2015. Denotes states that have one or more communities with a residential source separated 

food waste collection program. Programs are not state-wide initiatives.
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2.7.2.2 Benefits 

The benefits of diverting organic wastes from landfills include: 

• Reduction of methane, NMOC, and other air pollutants generated by the organic 

fraction of waste disposed in landfills; 

• Production of soil-improving compost material from composting (ILSR, 2014); 

• Generation of biogas from anaerobic digestion used to generate electricity and/or 

heat; and 

• Recovery and recycling of food waste to support food banks for humans or animals 

(MSW Management, 2015). 

2.7.2.3 Barriers 

Some barriers exist that can deter mandating the diversion of organics from landfills, 

especially in the format of a federal mandate, such as: 

• Lack of or variation in regulatory policies, incentives, and drivers to encourage 

organics diversion and make it more affordable (ILSR, 2014). For example, 

Kentucky’s composting permit fees for private entities led to a decline in applicants 

when the fee went from $0 to $3,000 in 2011, with an annual renewal fee of $500 

(BioCycle, 2014b). While New York does not have legislation in place, the state does 

review local materials management plans to provide suggestions on improving 

organics management and offers waste reduction and recycling grants to 

municipalities for education or capital expenditures (BioCycle, 2014b). Lessening 

permit restrictions and fees for organic waste facilities and offering state-level 

assistance to municipalities may spur movement to establish and expand organics 

management programs. 

• Limited capacity for organic material receiving, processing, and treatment facilities 

(e.g., composters, anaerobic digesters) and associated infrastructure (e.g., hauling 

services, transfer stations) (ILSR, 2014). While the United States has no shortage of 

landfill capacity overall, the average amount of organics diverted to composting in 27 

states is 5,155 tons per facility per year, which is far too low to adequately achieve 

higher composting rates (BioCycle, 2014a). Composting of organics can occur at 

several tiers, from home-based and small-scale farm and community sites to onsite 
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institutional systems (primarily schools) to large-scale centralized facilities, thus 

encouraging backyard and locally-based composting and developing adequate 

infrastructure for commercial composting (beyond yard waste) would lead to an 

increased capacity for organic wastes in urban, suburban, and rural areas (BioCycle, 

2014a). 

• Low cost to dispose waste in landfills relative to other waste treatment technologies 

(ILSR, 2014). Traditionally, waste disposal in the United States has been based on 

landfill tipping fees, or the fee a waste collector or hauler pays to discard waste in a 

landfill. Tipping fees at landfills vary across the United States, ranging from $5 to 

$142 per ton in 2011, with a national average just below $50 per ton (Shin, 2014). 

When recycling and organics diversion are introduced, the pricing structure shifts 

from a disposal cost to transportation and processing or treatment costs. Anaerobic 

digesters require significant capital investment and rely on tipping fees to recover 

costs to construct and operate the facility. In addition, due to opposition for siting 

these facilities, it is difficult to obtain permits to build digesters in densely populated 

areas, which results in increased costs to transport feedstock to the digester 

(Waste360, 2014). More recently, local solid waste agencies have offered reduced 

fees for source separated loads of organics at composting facilities. For example, 

Charleston County, South Carolina has a $25 per ton fee to drop off food and organic 

waste for composting, compared to $66 per ton for traditional waste sent to the 

landfill (ILSR, 2014). In addition, variable rate fees, or “pay-as-you-throw” pricing, 

incentivize separate collection of organics and recyclables as trash collection is 

typically priced at a higher fee than source separated organics and recyclables (ILSR, 

2014). 

• Multifaceted and regional nature of the solid waste management industry. Waste 

generators include households, institutions, and commercial entities, and these parties 

vary regionally in both density and demographics. Historically, state and local 

government has controlled all aspects of collection, transportation, disposal, and 

treatment of solid waste including the permitting of facilities and infrastructure and 

assessment of fees through taxes and operation of landfills. Private companies also 

play a significant role that ranges from collecting and hauling waste to owning and 
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operating landfills. While the industry is moving towards more integrated solid waste 

management approaches at a local or regional level, there is not a shift towards a 

national solid waste management system. As a result, the policies, programs, and 

infrastructure to accommodate organics diversion must be tailored to the unique 

situations of each region, state, or municipality to best implement change among 

interlinked entities of generators, collectors, and treatment and disposal facilities. 

• Lack of information and understanding of the environmental and energy benefits of 

separating, recovering, and utilizing organics. Ultimately, effective organics 

diversion from landfills begins at the point of generation. Changing waste disposal 

habits can be challenging for individuals, businesses, and industries in the United 

States, but education and awareness about the benefits of composting and anaerobic 

digestion in a manner that relates directly to individuals and organizations may 

encourage and increase diversion of organics. 

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actor_27909.aspx>. 
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National Waste & Recycling Association (NW&RA) (formerly National Solid Wastes 

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U.S. Environmental Protection Agency (EPA). 2014c. “Landfill-level data only (all landfills) – 

updated August 2014.” LMOP, Climate Change Division, U.S. EPA. 

<http://www.epa.gov/lmop/projects-candidates/index.html>. 

U.S. Environmental Protection Agency (EPA). 2014d. “Webinar: Using Landfill Gas as Vehicle 

Fuel.” LMOP, Climate Change Division, U.S. EPA. November 13, 2014. 

<http://epa.gov/lmop/documents/pdfs/lmop-webinar-13Nov2014.pdf>. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

2-49

U.S. Environmental Protection Agency (EPA). 2015a. LFG Energy Project Development 

Handbook. LMOP, Climate Change Division, U.S. EPA. February 2015. 

<http://epa.gov/lmop/publications-tools/handbook.html>. 

U.S. Environmental Protection Agency (EPA). 2015b. “Landfill and LFG Energy Project 

Database.” LMOP, Climate Change Division, U.S. EPA. January 2015. 

U.S. Environmental Protection Agency (EPA). 2015c. OSWER, ORCR. Web page: NonHazardous Waste Management Hierarchy.” 

<http://www.epa.gov/osw/nonhaz/municipal/hierarchy.htm>. Accessed January 22, 2015. 

U.S. Environmental Protection Agency (EPA). 2015d. OSWER, ORCR. Web page: Municipal 

Solid Waste. <http://www.epa.gov/epawaste/nonhaz/municipal/index.htm>. Accessed 

January 22, 2015. 

U.S. Environmental Protection Agency (EPA). 2015e. OSWER, ORCR. Web page: Electricity 

from Municipal Solid Waste. <http://www.epa.gov/cleanenergy/energy-andyou/affect/municipal-sw.html>. Accessed January 22, 2015. 

U.S. Environmental Protection Agency (EPA). 2015f. LMOP. Web page: Frequent Questions: 

LFG Energy Projects. <http://www.epa.gov/lmop/faq/lfg.html#08>. Accessed January 

22, 2015. 

U.S. Environmental Protection Agency (EPA). 2015g. OSWER, ORCR. Web page: Types of 

Composting. <http://www.epa.gov/epawaste/conserve/composting/types.htm>. Accessed 

January 22, 2015. 

U.S. Environmental Protection Agency (EPA). 2015. Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990-2013. Office of Atmospheric Programs, Washington, DC. 

EPA 430-R-15-004. Annex 3.14, Tables A-265 and Table ES-2. April 2015. 

<http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html>. Accessed 

April 28, 2015.

 Waste 360. 2014. “Navigating the Complexities of Food Waste.” September 25, 2014. 

<http://waste360.com/organics/navigating-complexities-food-waste?NL=WST03&Issue=WST-03_20150128_WST03_312&sfvc4enews=42&cl=article_4&YM_RID=CPEQW000001137125&YM_MID=

2476>. 

Waste Business Journal (WBJ). 2010. “Landfill Tipping Fees Reach New Record, Despite Slow 

Times”. August 17, 2010. 

<http://www.wastebusinessjournal.com/news/wbj20100817A.htm>. 

WBJ. 2012a. “Waste Market Overview & Outlook 2012.” 

<http://www.wastebusinessjournal.com/overview.htm>. Accessed January 16, 2015. 

WBJ. 2012b. “US Landfill Tipping Fees Reach $45 per Ton; Slow Volume Growth.” October 2, 

2012. <http://www.wastebusinessjournal.com/news/wbj20121003A.htm>. 
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2-50

WBJ. 2014. “Directory of Waste Processing and Disposal Sites 2014.” 

<http://www.wastebusinessjournal.com/diratlas.htm>. Accessed January 6, 2015. 

Wright, Shawn. 2012. Waste & Recycling News. “Tipping fees vary across the U.S.” July 20, 

2012. Previously accessed at 

<http://www.wasterecyclingnews.com/article/20120720/NEWS01/120729997/tippingfees-vary-across-the-u-s>. 
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3-1 

3 REGULATORY PROGRAM COSTS AND EMISSIONS REDUCTIONS 

3.1 Introduction 

Currently, the Emission Guidelines for existing MSW landfills 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 chapter of the RIA includes three sets of discussions related to the proposed new Emission 

Guidelines: 

• 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 RIA to 

better understand the regulatory impact analysis. However, we provide references to technical 

memoranda for readers interested in a greater level of detail. 

3.2 General Assumptions and Procedures 

The proposed Emission Guidelines will affect existing MSW landfills. Any changes to 

the emission guidelines that might result from this review will ultimately apply to landfills that 

accepted waste on or after November 8, 198712, and that commenced construction, 

reconstruction, or modification prior to July 17, 2014 (the date of publication of proposed 

revisions to the landfills NSPS, 40 CFR part 60, subpart XXX). However, the EPA recognizes 

that many landfills subject to the proposed Subpart Cf are closed or contain inactive areas that do 

not produce as much landfill gas. Therefore, the EPA is proposing a separate subcategory for 

 

12 This date in 1987 is the date on which permit programs were established under the Hazardous and Solid Waste 

Amendments of RCRA. This date was also selected as the regulatory cutoff in the EG for landfills no longer 

receiving wastes because EPA judged States would be able to identify active facilities as of this date. 
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3-2 

landfills that closed after 1987 but on or before the date of this Emission Guidelines proposal. 

These landfills would be subject to a 50 Mg/yr NMOC emission rate threshold, consistent with 

the NMOC thresholds in Subparts Cc and WWW of Part 60. These landfills will also be exempt 

from initial reporting requirements, provided that the landfill already met these requirements 

under Subparts Cc or WWW of Part 60. 

To assess the impacts of the proposal, the EPA drew upon a comprehensive database of 

existing landfills, derived from a landfill and LFG energy project database maintained by the 

EPA’s Landfill Methane Outreach Program (LMOP) and data from the Greenhouse Gas 

Reporting Program (GHGRP). Unfortunately, this dataset was missing some landfill data for 

recent years (2010-2014) and included incomplete data for many landfills. To better represent 

landfills from recent years, model landfills were created. These model future landfills were 

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

and locations of landfills opening in 2010-2014 would be similar to the sizes and locations of 

landfills that opened in the most recent complete 5 years of data (2005-2010). Based on this 

assessment, the EPA created a total of five model landfills to represent landfills opening during 

2010-2014, which combined with the five landfills for which construction was already planned, 

led to ten projected future landfills that would be subject to the Emission Guidelines. In addition, 

11 model landfills were created that would be subject to the NSPS discussed in Chapter 7. 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.” 

To estimate the cost and emission impacts of each regulatory option, EPA determined 

which landfills in the complete dataset met the design capacity and emission rate thresholds for 

each regulatory option, and then calculated the emission reductions and costs for each landfill 

under each regulatory option in 2025 using the methods described below. The EPA is assessing 

impacts in year 2025 as a representative year for the landfills Emission Guidelines. While the 

year 2025 differs somewhat from the expected first year of implementation for the Emission 

Guidelines (year 2020), the number of existing landfills required to install controls under the 

proposed 2.5/34 option in year 2025 is comparable (within 2 percent of those required to control 

in the estimated first year of implementation. Further, year 2025 represents a year in which 

several of the landfills subject to control requirements have had to expand their GCCS according 

the expansion lag times set forth in proposed subpart Cf. While the analysis focuses on impacts 
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3-3 

in 2025, results for alternative years are also presented in Section 3.6. The resulting costs and 

emission reductions incurred by each landfill were used to assess the overall impacts of the 

current Emission Guidelines 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, “Updated Methodology for Estimating 

Cost and Emission Impacts of Proposed MSW Landfill Regulations. 20142015.” 

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 Cc. 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% interest rate, which is consistent with EPA guidance 

for cost evaluations. Costs are also presented using a 3% interest rate, in accordance with 

OMB guidance. 

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 option13. As the landfill is filled over time, the 

 

13 Note that even though the proposed rule allows a 30-month initial lag time, the model actually assumes the 

collection equipment is installed and operational at 36 months. We modeled as a 36 month (3-year) lag time 

since the first-order decay equation used to model emissions is on an annual, instead of monthly, basis. Further, 

because the current rule requires annual NMOC emission reports to be submitted by 6 months into the following 

calendar year, the landfill would have 30 months after the submittal of its first NMOC emission report showing 

an exceedance to install the GCCS, which is approximately 36 months after the excess emissions occurred. 

Commented [A7]: OMB RIA Comment 9: Reviewer 

recommends clearly articulating the analytic timeline since EPA 

only presents results in the RIA for a snapshot of 2025. 

EPA Response: The discussion has been edited to explain the 

choice of 2025 as a representative year. In addition, some results 

from alternative snapshot years are being included in Chapters 3, 4, 

and 7. 

Commented [A8]: OMB RIA Comment 7: Reviewer 

recommends providing additional details on EPA’s methods for 

estimating costs and emissions reductions, and recommends drawing 

additional language citing to the two summary TSDs referenced. 

EPA Response: We feel that the RIA provides an appropriate level 

of detail about the models, as the memos are essentially the 

description of a series of equations from the models. 
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3-4 

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 maximum gas 

production, gas generation will begin to decline once waste is no longer accepted. At this point, 

the analysis assumes that the GCCS no longer needs to be expanded and the GCCS will continue 

to collect all the gas being produced until the gas production falls back below the emission 

threshold of the proposed standard and the GCCS has been installed for at least 15 years. 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 

percent14. 

In addition to direct emission reductions, the proposed Emission Guidelines are expected 

to have secondary air impacts due to the additional energy demand required to operate the 

control system and the by-product emissions from the combustion of LFG. However, these are 

offset by avoided emissions from the national electrical grid as landfills generate electricity from 

the LFG. The methodology used to estimate secondary impacts of the proposed Emission 

Guidelines are detailed in the docketed memorandum from ERG to EPA, “Estimating Secondary 

Impacts of the Landfills Emission Guidelines Review. 2015” 

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. 

The EPA derived the cost equations used in the evaluation from the EPA’s Landfill Gas 

Energy Cost Model (LFGcost-Web), version 3.0, which was developed by the EPA’s Landfill 

 

14 The regulatory analysis models collectable gas (see ERG. 2015. Updated Methodology for Estimating Cost and 

Emission Impacts of MSW Landfills Regulations). As per 60.34(f)(b)(2)(i), the GCCS should be designed to 

handle the maximum expected gas flow rate from the entire area of the landfill that warrants control over the 

intended use period of the gas control system equipment.

Commented [A9]: OMB RIA Comment 13: Reviewer 

recommends additional information on the basis for the assumed 

efficacy of the collection systems, including citations. 

EPA Response: A clarification and reference is provided in a 

footnote. 
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3-5 

Methane Outreach Program (LMOP). LFGcost-Web 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-Web encompasses the types of costs included in the EPA OAQPS control 

cost manual including capital costs, annual costs, and revenue from LFG electricity sales. 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 compliance costs include direct costs, indirect costs, and revenue from LFG electricity 

sales. 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. 

For this evaluation, the EPA assessed costs in 2012$. The costs included in LFGcostWeb are in 2013$ and were adjusted for inflation to 2012$ using a factor of 2 percent for capital 

costs and 2.5 percent for O&M costs.15 For the primary estimate of costs, 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. Costs were also estimated using an interest rate of 3%. 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. 

 

15 The inflation rate for capital equipment is consistent with the default equipment inflation rate in the LFGcost-Web 

model; the inflation rate for O&M costs is consistent with the default general inflation rate in the LFGcost-Web 

model. See further documentation at: http://epa.gov/lmop/publications-tools/lfgcost/LFGcostWebV3_0manual.pdf 

Commented [A10]: OMB RIA Comment 18: Reviewer 

recommends that EPA use PPI data from BLS instead of the 2% 

inflation rate for capital and 2.5% inflation rate for O&M on 3-5 

EPA Response: As noted in footnote 14, the rates used for this 

analysis are consistent with the default rates in the LFGcost-Web 

model. EPA will edit its analysis of impacts in the final rule to use 

the PPI data from BLS, but this request is not feasible for the 

proposal.
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3-6 

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 

(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% and greater than 

$0.0430 per kWh at 3% interest. 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-Web. 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. 
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3-7 

Several of the compliance requirements require labor to complete the activities in 

addition to capital expenses for purchasing the monitoring and control equipment. This analysis 

assumes that a Civil Engineer or Civil Engineer Technician completes compliance requirements 

of the proposed amendments, depending on the complexity of the task. Some landfill owners or 

operators do all or a portion of this work directly while others contract out control installation or 

monitoring requirements. 

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 2.5/40: design capacity retained at 2.5 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/34: design capacity retained at 2.5 Mg, emission threshold reduced 

to 34 NMOC Mg/yr 

• Alternative Option 2.0/34: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 34 Mg NMOC/year 

The baseline reflects the parameters of the current Emission Guidelines. In the baseline, 

the Emission Guidelines affect 989 landfills, with 574 landfills controlling emissions, 211 

landfills reporting but not controlling emissions, and 233 landfills in the closed subcategory in 

2025. 

Commented [A11]: OMB RIA Comment 19: Reviewer 

recommends clarifying on 3-8 what “baseline” means in Table 3-2. 

EPA Response: Requested clarification appears on 3-7 and is 

relevant for all tables and discussion in this section. 
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3-8 

Table 3-1 Number of Affected Landfills in 2025 under the Baseline and Alternative 

Options 

Affected 

Landfills 

(Open and 

Closed) 

Affected 

Open 

Landfills 

Affected 

Closed 

Subcategory

Closed 

Landfills 

Controlling 

Emissions 

Open 

Landfills 

Controlling 

Emissions 

Open 

Landfills 

Reporting 

but Not 

Controlling 

Emissions 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 989 756 233 29 545 211 

 

Alternative EG Options

Alternative 

option 2.5/40 989 756 233 29 607 149 

Proposed option 

2.5/34 989 756 233 29 651 105 

Alternative 

option 2.0/34 1090 803 287 29 667 136 

Note: Affected landfills include landfills subject to rule based on size and open as of 2015 as well as landfills in the closed 

subcategory. Affected open landfills are comprised of open landfills controlling emissions and open landfills reporting but 

not controlling emissions. Some closed landfills are still controlling emissions in 2025. 

Based on the characteristics of the landfills, the proposed option presented in Table 3-1 

would require 106 additional landfills to install controls by 2025. The less stringent alternative 

option would require 62 additional landfills to install controls by 2025, while the more stringent 

alternative option would affect 101 additional landfills, with some being required only to report, 

others being required to control, and some being in the closed subcategory. In that option, 122 

additional landfills are required to install controls by 2025. 

 Under the proposed option 2.5/34, the emission reductions would be an additional 2,770 Mg 

NMOC and 436,100 Mg methane (10,900,000 Mg CO2 Eq.) compared to the baseline in 2025. 

The less stringent alternative option 2.5/40 would yield emissions reductions of 1,720 Mg 

NMOC and 270,700 Mg methane (6,800,000 Mg CO2 Eq.) compared to the baseline, while the 

more stringent alternative option 2.0/34 would result in emissions reductions of 3,040 Mg 

NMOC and 479,100 Mg methane (12,000,000 Mg CO2 Eq.) compared to the baseline. The wide 

range in magnitude of emission reductions among pollutants is due to the composition of landfill 
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3-9 

gas: NMOC represents less than 1 percent of landfill gas, while methane represents 

approximately 50 percent. The emission reductions are summarized in Table 3-2. 

Table 3-2 Estimated Annual Average Emissions Reductions in 2025 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 57,300 9,035,000 226,000,000 

Incremental values versus the current EG 

Alternative option 2.5/40 1,720 270,700 6,800,000 

Proposed option 2.5/34 2,770 436,100 10,900,000 

Alternative option 2.0/34 3,040 479,100 12,000,000 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Under the proposed option 2.5/34, when using a 7% discount rate the additional cost of control 

over the baseline in 2025 would is estimated to be $101 million, $55.3 million of which is 

estimated to be offset by increased revenue from beneficial-use projects, so the net cost is 

estimated to be $46.8 million (

Commented [A12]: OMB RIA Comment 6: Reviewer 

recommends presenting the baseline emissions of methane and 

NMOC in tabular format. 

EPA Response: Requested information appears in this table. 

Commented [A13]: OMB RIA Comment 5: Reviewer 

recommends clarifying the gross cost in the cost discussion. 

EPA Response: This discussion and the discussion in Section 7.2 

have been edited to discuss the control cost, revenue from 

beneficial-use projects, and the resulting net cost. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-10 

Table 3-3Table 3-3). The additional cost of control for the less stringent alternative 

option 2.5/40 would is estimated to be $60.3 million, $33.6 million of which is estimated to be 

offset by increased revenue from beneficial-use projects, so the net cost is estimated to be $27 

million, while. the The cost of control for the more stringent alternative option 2.0/34 would is 

estimated to be $111 million, $60.7 million of which is estimated to be offset by increased 

revenue from beneficial-use projects, so the net cost is estimated to be $51 million. These 

options represent approximately between 9 to 17 percent in additional net costs beyond the 

baseline, with the proposed option 2.5/34 resulting in a 16 percent increase in net costs beyond 

the baseline for the industry as a whole. 
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3-11 

Table 3-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (7% Discount Rate) 

 Estimated Annualized Net Cost (Millions 2012$) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 7.3 1,700 1,410 299 

Incremental values versus the current EG

Alternative option 2.5/40 0.40 60.3 33.6 27.0 

Proposed option 2.5/34 0.69 101 55.3 46.8 

Alternative option 2.0/34 0.84 111 60.7 51.0 

Note: All total are independently rounded and may not sum. 

When using a 3% discount rate, the model predicts a different timing in the investment behavior 

by the landfills, which affects both the costs and revenue that are predicted in 2025. Under the 

proposed option 2.5/34, the additional cost of control over the baseline in 2025 would is 

estimated to be $117 million, $82.5 million of which is estimated to be offset in increased 

revenue from beneficial-use projects, so the net cost is estimated to be $35 million (
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3-12 

Table 3-4Table 3-4). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $72.1 million, $52.3 million of which is estimated to be offset by 

increased revenue from beneficial use projects, so the net cost is estimated to be $20.1 million, 

while. the The cost of control for the more stringent alternative option 2.0/34 would is estimated 

to be $126 million, of which $89.1 million is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to be $38.1 million. These options represent 

approximately between 24 to 45 percent in additional net costs beyond the baseline, with the 

proposed option 2.5/34 resulting in a 41 percent increase in net costs beyond the baseline for the 

industry as a whole. However, it is important to note that the baseline value when using a 3% 

discount rate is less than 30 percent of the value when using a 7% discount rate, because the 

increased costs of earlier installation of GCCS and engines are offset by increased revenue from 

energy generation. 
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3-13 

Table 3-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (3% Discount Rate) 

 Estimated Annualized Net Cost (Millions 2012$) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 7.1 2,190 2,120 84.5 

Incremental values versus the current EG

Alternative option 2.5/40 0.37 72.1 52.3 20.1 

Proposed option 2.5/34 0.66 117 82.5 35.0 

Alternative option 2.0/34 0.80 126 89.1 38.1 

Note: All total are independently rounded and may not sum. 

In terms of cost effectiveness, when considering the estimated net cost of the options, the 

overall average cost effectiveness for NMOC reductions is $5,0905,200 per Mg NMOC under 

the baseline and roughly $17,000 per Mg NMOC under the proposed option 2.5/34 and 

alternative option 2.0/34, and roughly $16,000 per Mg NMOC under the alternative option 

2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is roughly $32 33 per Mg methane under the baseline and 

approximately $100 - $110 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34. 

When estimating cost effectiveness excluding the estimated revenue from beneficial-use 

projects, the overall average cost effectiveness for NMOC reductions is $29,800 per Mg NMOC 

under the baseline and roughly $37,000 per Mg NMOC under the proposed option 2.5/34 and 

alternative option 2.0/34, and roughly $36,000 per Mg NMOC under the alternative option 

2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is $189 per Mg methane under the baseline and 
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3-14 

approximately $225 - $235 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34.

Table 3-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options 

(7% Discount Rate) 

Cost-effectiveness (2012$ per Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Net 

Costb 

/ton 

Total 

Cost 

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 5,200 29,800 33.1 189 1.3 7.6 

 

Incremental values versus the current EG 

Alternative option 2.5/40 15,800 35,500 100 225 4.0 9.0 

Proposed option 2.5/34 17,000 37,000 108 235 4.3 9.4 

Alternative option 2.0/34 16,800 36,900 107 234 4.3 9.4 

Note: The cost-effectiveness of NMOC and methane are estimated as if all of the control cost were attributed to each 

pollutant separately. 

a A global warming potential of 25 is used to convert methane to CO2-equivalents. The secondary CO2 emission 

reductions are not reflected in these estimates. 

b Net Cost is the total control and testing and monitoring cost minus any project revenue. The control costs for 

landfills with energy projects includes costs to install and operate a reciprocating engine (and associated electrical 

equipment), which is more expensive than a standard flare. Reciprocating engines are not required by the regulation 

but are expected to be used as control devices when it is cost-effective to recovery the LFG energy.

3.6 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

Emission Guidelines for existing MSW landfills, the quantity and composition of landfill gas 

does change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a 

more complete picture of the emission reductions and costs of the Emission Guidelines 

alternatives over time by presenting results from the years 2020, 2030, and 2040. Throughout 

this section, costs are presented only at a 7% interest rate, and do not include testing and 

monitoring costs. However, testing and monitoring costs are typically a very small percentage of 

Commented [A14]: OMB RIA Comment 21: Reviewer 

recommends presenting cost-effectiveness both with and without the 

added revenue on 3-12. 

EPA Response: Table 3-5 has been modified to include costeffectiveness with and without added revenue (change is not tracked 

due to Word issues) and surrounding discussion has been modified. 

Similar change made to Table 7-5 and surrounding text for 

supplemental NSPS proposal. 

Commented [A15]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

3-15 

the overall costs. Tables 3-6 and 3-7 present the emissions reductions and compliance costs, 

respectively, of the alternatives in the 2020 snapshot year. 
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3-16 

Table 3-6 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 56,300 8.9 222 

Incremental values versus the current EG 

Alternative option 2.5/40 1,490 0.24 5.9 

Proposed option 2.5/34 2,270 0.36 9.0 

Alternative option 2.0/34 2,560 0.40 10.1 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-7 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 595 1,660 1,390 262 

Incremental values versus the current EG 

Alternative option 2.5/40 57 53.0 42.9 18.1 

Proposed option 2.5/34 93 88.4 65.8 30.5 

Alternative option 2.0/34 108 96.9 70.0 34.9 

Note: All total are independently rounded and may not sum. 

Tables 3-8 and 3-9 present the emissions reductions and compliance costs, respectively, in the 

2030 snapshot year.
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3-17 

Table 3-8 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 55,600 8.8 219 

Incremental values versus the current EG 

Alternative option 2.5/40 1,960 0.31 7.7 

Proposed option 2.5/34 3,150 0.50 12.4 

Alternative option 2.0/34 3,390 0.53 13.4 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-9 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 554 1,680 1,360 325 

Incremental values versus the current EG 

Alternative option 2.5/40 65 69.4 31.5 32.9 

Proposed option 2.5/34 107 112.9 58.5 49.4 

Alternative option 2.0/34 123 122.4 63.9 53.5 

Note: All total are independently rounded and may not sum. 
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3-18 

Tables 3-10 and 3-11 present the emissions reductions and compliance costs, respectively, in the 

2040 snapshot year. 

Table 3-10 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 49,500 7.8 195 

Incremental values versus the current EG 

Alternative option 2.5/40 1,340 0.21 5.3 

Proposed option 2.5/34 2,130 0.34 8.4 

Alternative option 2.0/34 2,210 0.35 8.7 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 3-11 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$)

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC

Baseline 464 1,500 1,100 398 

Incremental values versus the current EG 

Alternative option 2.5/40 47 51.6 26.7 27.0 

Proposed option 2.5/34 74 89.4 56.4 35.0 

Alternative option 2.0/34 81 93.0 58.2 36.7 

Note: All total are independently rounded and may not sum. 
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4-1 

4 BENEFITS OF EMISSIONS REDUCTIONS 

4.1 Introduction 

The proposed Emission Guidelines are expected to result in significant emissions 

reductions of landfill gas (LFG) from existing MSW landfills. For the proposed Emission 

Guidelines, there will be climate benefits and HAP, ozone and PM2.5 health “co-benefits”. These 

co-benefits occur because the control techniques to meet the standards simultaneously reduce 

methane, VOC, and HAP emissions. By lowering the NMOC emissions threshold to 34 Mg/yr, 

the proposal is anticipated to achieve reductions of 2,770 Mg/yr NMOC and 436,100 Mg/yr 

methane in 2025. The NMOC portion of LFG can contain a variety of air pollutants, including 

VOC and various organic HAP. VOC emissions are precursors to both fine particulate matter 

(PM2.5) and ozone formation, while methane is a GHG and a precursor to global ozone 

formation. As described in the subsequent sections, these pollutants are associated with 

substantial health effects, climate effects, and other welfare effects. The only categories of 

benefits monetized in this RIA are methane-related climate effects and CO2 co-benefits 

associated with reduced electricity demand due to increased generation of electricity by landfills 

through the burning of LFG in engines. The methane-related climate benefits are estimated to 

range from $310 million (2012$) to $1.7 billion (2012$); these benefits are estimated to be $660 

million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are estimated to range 

from $3.6 million (2012$) to $36 million (2012$) in 2025; estimated CO2 benefits are $12 

million (2012$) in 2025 using a 3% discount rate. 

While we expect that these avoided emissions will also result in improvements in air 

quality and reduce health and welfare effects associated with exposure to HAP, ozone, and fine 

particulate matter (PM2.5), we have determined that quantification of those health benefits cannot 

be accomplished for this rule in a defensible way. This is not to imply that these benefits do not 

exist; rather, it is a reflection of the difficulties in modeling the direct and indirect impacts of the 

reductions in emissions for this industrial sector with the data currently available. With the data 

available, we are not able to provide a credible health co-PM2.5 benefits estimates for this rule, 

due to the differences in the locations of MSW landfill emission points relative to existing 

information and the highly localized nature of air quality responses associated with HAP and 

Commented [A16]: OMB RIA Comment 22: Reviewer 

recommends clearly articulating which reductions are primary 

benefits and which are co-benefits on 4.1 

EPA Response: Section has been edited to make this clearer. 

Formatted: Not Superscript/ Subscript
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4-2 

VOC reductions.16 Nearly 30 organic HAPs have been identified in uncontrolled LFG, including 

benzene, ethylbenzene, toluene, and vinyl chloride, and they will be reduced by this rule. In this 

chapter, we provide a qualitative assessment of the health benefits associated with reducing 

exposure to these pollutants, as well as visibility impairment and ecosystem benefits. Table 4-1 

summarizes the quantified and unquantified benefits in this analysis. 

Table 4-1 Climate and Human Health Effects of Emission Reductions in this Rule 

Category Specific Effect 

Effect Has 

Been 

Quantified 

Effect Has 

Been 

Monetized 

More 

Information 

Improved Environment 

Reduced climate 

effects 

Global climate impacts from methane (CH4) 

and carbon dioxide (CO2) —1 

Marten et al. 

(2014), SC-CO2

TSDs 

Other climate impacts (e.g., ozone, black 

carbon, aerosols, other impacts) — — 

IPCC, Ozone ISA, 

PM ISA2

Improved Human Health 

Reduced incidence of 

premature mortality 

from exposure to 

PM2.5

Adult premature mortality based on cohort 

study estimates and expert elicitation estimates 

(age >25 or age >30)

— — PM ISA3

Infant mortality (age <1) — — PM ISA3

Reduced incidence of 

morbidity from 

exposure to PM2.5

Non-fatal heart attacks (age > 18) — — PM ISA3

Hospital admissions—respiratory (all ages) — — PM ISA3

Hospital admissions—cardiovascular (age >20) — — PM ISA3

Emergency room visits for asthma (all ages) — — PM ISA3

Acute bronchitis (age 8-12) — — PM ISA3

Lower respiratory symptoms (age 7-14) — — PM ISA3

Upper respiratory symptoms (asthmatics age 9-

11) — — PM ISA3

Asthma exacerbation (asthmatics age 6-18) — — PM ISA3

Lost work days (age 18-65) — — PM ISA3

Minor restricted-activity days (age 18-65) — — PM ISA3

Chronic Bronchitis (age >26) — — PM ISA3

Emergency room visits for cardiovascular 

effects (all ages) — — PM ISA3

 

16 Previous studies have estimated the monetized benefits-per-ton of reducing VOC emissions associated with the 

effect that those emissions have on ambient PM2.5 levels and the health effects associated with PM2.5 exposure 

(Fann, Fulcher, and Hubbell, 2009). While these ranges of benefit-per-ton estimates provide useful context, the 

geographic distribution of VOC emissions from the MSW landfill sector are not consistent with emissions 

modeled in Fann, Fulcher, and Hubbell (2009). In addition, the benefit-per-ton estimates for VOC emission 

reductions in that study are derived from total VOC emissions across all sectors. Coupled with the larger 

uncertainties about the relationship between VOC emissions and PM2.5 and the highly localized nature of air 

quality responses associated with VOC reductions, these factors lead us to conclude that the available VOC 

benefit-per-ton estimates are not appropriate to calculate monetized benefits of these rules, even as a bounding 

exercise. 
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4-3 

Category Specific Effect 

Effect Has 

Been 

Quantified 

Effect Has 

Been 

Monetized 

More 

Information 

Strokes and cerebrovascular disease (age 50-

79) — — PM ISA3

Other cardiovascular effects (e.g., other ages) — — PM ISA2

Other respiratory effects (e.g., pulmonary 

function, non-asthma ER visits, non-bronchitis 

chronic diseases, other ages and populations) 

— — PM ISA2

Reproductive and developmental effects (e.g., 

low birth weight, pre-term births, etc) — — PM ISA2,4

Cancer, mutagenicity, and genotoxicity effects — — PM ISA2,4

Reduced incidence of 

mortality from 

exposure to ozone 

Premature mortality based on short-term study 

estimates (all ages) — — Ozone ISA3

Premature mortality based on long-term study 

estimates (age 30–99) — — Ozone ISA3

Reduced incidence of 

morbidity from 

exposure to ozone 

Hospital admissions—respiratory causes (age > 

65) — — Ozone ISA3

Hospital admissions—respiratory causes (age 

<2) — — Ozone ISA3

Emergency department visits for asthma (all 

ages) — — Ozone ISA3

Minor restricted-activity days (age 18–65) — — Ozone ISA3

School absence days (age 5–17) — — Ozone ISA3

Decreased outdoor worker productivity (age 

18–65) — — Ozone ISA3

Other respiratory effects (e.g., premature aging 

of lungs) — — Ozone ISA2

Cardiovascular and nervous system effects — — Ozone ISA2

Reproductive and developmental effects — — Ozone ISA2,4

Reduced incidence of 

morbidity from 

exposure to HAP 

Effects associated with exposure to hazardous 

air pollutants such as benzene — — ATSDR, IRIS2,3

Improved Environment 

Reduced visibility 

impairment 

Visibility in Class 1 areas — — PM ISA3

Visibility in residential areas — — PM ISA3

Reduced effects from 

PM deposition 

(organics) 

Effects on Individual organisms and 

ecosystems 

— — PM ISA2

Reduced vegetation 

and ecosystem effects 

from exposure to 

ozone 

Visible foliar injury on vegetation — — Ozone ISA3

Reduced vegetation growth and reproduction — — Ozone ISA3

Yield and quality of commercial forest 

products and crops — — Ozone ISA3

Damage to urban ornamental plants — — Ozone ISA2

Carbon sequestration in terrestrial ecosystems — — Ozone ISA3

Recreational demand associated with forest 

aesthetics — — Ozone ISA2

Other non-use effects Ozone ISA2

Ecosystem functions (e.g., water cycling, 

biogeochemical cycles, net primary 

productivity, leaf-gas exchange, community 

composition) 

— — Ozone ISA2

1

 The global climate and related impacts of CO2 and CH4 emissions changes, such as sea level rise, are estimated within each 

integrated assessment model as part of the calculation of the SC-CO2 and SC-CH4. The resulting monetized damages, which 

are relevant for conducting the benefit-cost analysis, are used in this RIA to estimate the welfare effects of quantified changes 

in CO2 emissions. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-4 

2

 We assess these benefits qualitatively because we do not have sufficient confidence in available data or methods. 

3

 We assess these benefits qualitatively due to data limitations for this analysis, but we have quantified them in other analyses. 

 4 We assess these benefits qualitatively because current evidence is only suggestive of causality or there are other significant 

concerns over the strength of the association. 

4.2 Methane (CH4) 

4.2.1 Methane climate effects and valuation 

Methane is the one of the principal components of landfill gas. Methane is also a potent 

greenhouse gas (GHG) that once emitted into the atmosphere absorbs terrestrial infrared 

radiation that contributes to increased global warming and continuing climate change. Methane 

reacts in the atmosphere to form ozone and ozone also impacts global temperatures. Methane, in 

addition to other GHG emissions, contributes to warming of the atmosphere, which over time 

leads to increased air and ocean temperatures, changes in precipitation patterns, melting and 

thawing of global glaciers and ice, increasingly severe weather events, such as hurricanes of 

greater intensity, and sea level rise, among other impacts. 

According to the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment 

Report (AR5, 2015), changes in methane concentrations since 1750 contributed 0.48 W/m2 of 

forcing, which is about 17% of all global forcing due to increases in anthropogenic GHG 

concentrations, and which makes methane the second leading long-lived climate forcer after 

CO2. However, after accounting for changes in other greenhouse substances such as ozone and 

stratospheric water vapor due to chemical reactions of methane in the atmosphere, historical 

methane emissions were estimated to have contributed to 0.97 W/m2 of forcing today, which is 

about 30% of the contemporaneous forcing due to historical greenhouse gas emissions. 

MSW landfills emit significant amounts of methane. The Inventory of U.S. Greenhouse 

Gas Emissions and Sinks: 1990-2013 (published April 2015) estimates 2013 methane emissions 

from MSW landfills to be 97.5 MMt CO2 Eq. In 2013, total methane emissions from MSW 

landfills represented approximately 15 percent of the total methane emissions from all sources 

and account for about 1.5 percent of all CO2-equivalent (CO2 Eq.) emissions in the U.S., with 

landfills being the third largest contributor to U.S. anthropogenic methane emissions (EPA, 

2015). 
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4-5 

This rulemaking proposes emission control technologies and regulatory alternatives that 

are expected to significantly decrease methane emissions from existing MSW landfills. By 

lowering the NMOC emissions threshold to 34 Mg/yr, the proposal would achieve reductions of 

2,770 Mg/yr NMOC and 436,100 Mg/yr methane in 2025. 

We calculated the global social benefits of methane emissions reductions expected from 

the proposed guidelines for existing MSW landfills using estimates of the social cost of methane 

(SC-CH4), a metric that estimates the monetary value of impacts associated with marginal 

changes in methane emissions in a given year. It includes a wide range of anticipated climate 

impacts, such as net changes in agricultural productivity and human health, property damage 

from increased flood risk, and changes in energy system costs, such as reduced costs for heating 

and increased costs for air conditioning. The SC-CH4 estimates applied in this analysis were 

developed by Marten et al. (2014) and are discussed in greater detail below. 

A similar metric, the social cost of CO2 (SC-CO2), provides important context for 

understanding the Marten et al. SC-CH4 estimates. Estimates of the SC-CO2 have been used by 

EPA and other federal agencies to value the impacts of CO2 emissions changes in benefit cost 

analysis for GHG-related rulemakings since 2008. The SC-CO2 is a metric that estimates the 

monetary value of impacts associated with marginal changes in CO2 emissions in a given year. 

Similar to the SC-CH4, it includes a wide range of anticipated climate impacts, such as net 

changes in agricultural productivity, property damage from increased flood risk, and changes in 

energy system costs, such as reduced costs for heating and increased costs for air conditioning. It 

is used to quantify the benefits of reducing CO2 emissions, or the disbenefit from increasing 

emissions, in regulatory impact analyses. 

The SC-CO2 estimates were developed over many years, using the best science available, 

and with input from the public. Specifically, an interagency working group (IWG) that included 

EPA and other executive branch agencies and offices used three integrated assessment models 

(IAMs) to develop the SC-CO2 estimates and recommended four global values for use in 

regulatory analyses. The SC-CO2 estimates were first released in February 2010 and updated in 

2013 using new versions of each IAM. The 2013 update did not revisit the 2010 modeling 

decisions with regards to the discount rate, reference case socioeconomic and emission scenarios, 
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4-6 

and equilibrium climate sensitivity distribution. Rather, improvements in the way damages are 

modeled are confined to those that have been incorporated into the latest versions of the models 

by the developers themselves and published in the peer-reviewed literature. The 2010 SC-CO2

Technical Support Document (2010 SC-CO2 TSD) provides a complete discussion of the 

methods used to develop these estimates and the current SC-CO2 TSD presents and discusses the 

2013 update (including recent minor technical corrections to the estimates).17 

The 2010 SC-CO2 TSD noted a number of limitations to the SC-CO2 analysis, including 

the incomplete way in which the IAMs capture catastrophic and non-catastrophic impacts, their 

incomplete treatment of adaptation and technological change, uncertainty in the extrapolation of 

damages to high temperatures, and assumptions regarding risk aversion. Currently IAMs do not 

assign value to all of the important physical, ecological, and economic impacts of climate change 

recognized in the climate change literature due to a lack of precise information on the nature of 

damages and because the science incorporated into these models understandably lags behind the 

most recent research. Nonetheless, these estimates and the discussion of their limitations 

represent the best available information about the social benefits of CO2 reductions to inform 

benefit-cost analysis; see RIA of this rule and the SC-CO2 TSDs for additional details. The new 

versions of the models offer some improvements in these areas, although further work is 

warranted. 

Accordingly, EPA and other agencies continue to engage in research on modeling and 

valuation of climate impacts with the goal to improve these estimates. The EPA and other 

agencies also continue to consider feedback on the SC-CO2 estimates from stakeholders through 

a range of channels, including public comments on Agency rulemakings that use the SC-CO2 in 

supporting analyses and through regular interactions with stakeholders and research analysts 

implementing the SC-CO2 methodology used by the interagency working group. In addition, 

OMB’s Office of Information and Regulatory Affairs sought public comment on the approach 

 

17 Both the 2010 SC-CO2 TSD and the current TSD are available at: https://www.whitehouse.gov/omb/oira/socialcost-of-carbonhttps://www.whitehouse.gov/omb/inforeg_regpol_agency_review. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-7 

used to develop the SC-CO2 estimates through a separate comment period that ended on 

February 26, 2014. 

After careful evaluation of the full range of comments, the interagency working group 

continues to recommend the use of the SC-CO2 estimates in regulatory impact analysis. With 

the release of the response to comments, the interagency working group announced plans to 

obtain expert independent advice from the National Academiesy of Sciences, Engineering, and 

Medicine to ensure that the SC-CO2 estimates continue to reflect the best available scientific and 

economic information on climate change. The NRC Academies review will be informed by the 

public comments received and focus on the technical merits and challenges of potential 

approaches to improving the SC-CO2 estimates in future updates. 

Concurrent with OMB’s publication of the response to comments on SC-CO2 and 

announcement of the NRC Academies process, OMB posted a revised TSD that includes two 

minor technical corrections to the current estimates. 18 One technical correction addressed an 

inadvertent omission of climate change damages in the last year of analysis (2300) in one model 

and the second addressed a minor indexing error in another model. On average the revised SCCO2 estimates are one dollar less than the mean SC-CO2 estimates reported in the November 

2013 TSD. The change in the estimates associated with the 95th percentile estimates when using 

a 3% discount rate is slightly larger, as those estimates are heavily influenced by the results from 

the model that was affected by the indexing error. 

The four SC-CO2 estimates are: $15, $50, $73, and $150 per metric ton of CO2 emissions 

in the year 2025 (2012 dollars).19 The first three values are based on the average SC-CO2 from 

the three IAMs, at discount rates of 5, 3, and 2.5 percent, respectively. Estimates of the SC-CO2

for several discount rates are included because the literature shows that the SC-CO2 is sensitive 

 

18 See https://www.whitehouse.gov/omb/oira/social-cost-of-carbon for the response to comments, the blog post 

announcing the Academies’ process, and the current TSD. 

19 The current version of the SCC TSD is available at: 

https://www.whitehouse.gov/omb/inforeg_regpol_agency_review. The TSDs present SC-CO2 in $2007. The 

estimates were adjusted to 2012$ using the GDP Implicit Price Deflator. Also available at: 

http://www.gpo.gov/fdsys/pkg/ECONI-2013-02/pdf/ECONI-2013-02-Pg3.pdf. The SC-CO2 values have been 

rounded to two significant digits. Unrounded numbers from the 2013 SCC TSD were adjusted to 2012$ and used 

to calculate the CO2 benefits. 
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4-8 

to assumptions about the discount rate, and because no consensus exists on the appropriate rate 

to use in an intergenerational context (where costs and benefits are incurred by different 

generations). The fourth value is the 95th percentile of the SC-CO2 across all three models at a 

3% discount rate. It is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SC-CO2 distribution. The SC-CO2 increases over time 

because future emissions are expected to produce larger incremental damages as economies grow 

and physical and economic systems become more stressed in response to greater climate change. 

A challenge particularly relevant to this proposal is that the IWG did not estimate the 

social costs of non-CO2 GHG emissions at the time the SC-CO2 estimates were developed. One 

alternative approach to value methane impacts is to use the global warming potential (GWP) to 

convert the emissions to CO2 equivalents which are then valued using the SC-CO2 estimates. 

The GWP measures the cumulative radiative forcing from a perturbation of a non-CO2

GHG relative to a perturbation of CO2 over a fixed time horizon, often 100 years. The GWP 

mainly reflects differences in the radiative efficiency of gases and differences in their 

atmospheric lifetimes. While the GWP is a simple, transparent, and well-established metric for 

assessing the relative impacts of non-CO2 emissions compared to CO2 on a purely physical basis, 

there are several well-documented limitations in using it to value non-CO2 GHG benefits, as 

discussed in the 2010 SCC TSD and previous rulemakings (e.g., EPA 2012b, 2012d).20 In 

particular, several recent studies found that GWP-weighted benefit estimates for methane are 

likely to be lower than the estimates derived using directly modeled social cost estimates for 

these gases. Gas comparison metrics, such as the GWP, are designed to measure the impact of 

non-CO2 GHG emissions relative to CO2 at a specific point along the pathway from emissions to 

monetized damages (depicted in Figure 4-1), and this point may differ across measures. 

 

20 See also Reilly and Richards 1993; Schmalensee 1993; Fankhauser 1994; Marten and Newbold 2012. 
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4-9 

Figure 4-1 Path from GHG Emissions to Monetized Damages (Source: Marten et al., 

2014) 

The GWP is not ideally suited for use in benefit-cost analyses to approximate the social 

cost of non-CO2 GHGs because it ignores important nonlinear relationships beyond radiative 

forcing in the chain between emissions and damages. These can become relevant because gases 

have different lifetimes and the SC-CO2 takes into account the fact that marginal damages from 

an increase in temperature are a function of existing temperature levels. Another limitation of gas 

comparison metrics for this purpose is that some environmental and socioeconomic impacts are 

not linked to all of the gases under consideration, or radiative forcing for that matter, and will 

therefore be incorrectly allocated. For example, the economic impacts associated with increased 

agricultural productivity due to higher atmospheric CO2 concentrations included in the SC-CO2

would be incorrectly allocated to methane emissions with the GWP-based valuation approach. 

Also of concern, is the fact that the assumptions made in estimating the GWP are not 

consistent with the assumptions underlying SC-CO2 estimates in general, and the SC-CO2

estimates developed by the IWG specifically. For example, the 100 year time horizon usually 

used in estimating the GWP is less than the 300 year horizon the IWG used in developing the 

SC-CO2 estimates. The GWP approach also treats all impacts within the time horizon equally, 

independent of the time at which they occur. This is inconsistent with the role of discounting in 

economic analysis, which accounts for a basic preference for earlier over later gains in utility and 

expectations regarding future levels of economic growth. In the case of methane, which has a 

relatively short lifetime compared to CO2, the temporal independence of the GWP could lead the 
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4-10 

GWP approach to underestimate the SC-CH4 with a larger downward bias under higher discount 

rates (Marten and Newbold 2012).21 

EPA sought public comments on the valuation of non-CO2 GHG impacts in previous 

rulemakings (EPA, 2012b; EPA, 2012d). In general, the commenters strongly encouraged EPA 

to incorporate the monetized value of non-CO2 GHG impacts into the benefit cost analysis, 

however they noted the challenges associated with the GWP-approach, as discussed above, and 

encouraged the use of directly-modeled estimates of the SC-CH4 to overcome those challenges. 

EPA had cited several researchers that had directly estimated the social cost of non-CO2

emissions using IAMs but noted that the number of such estimates was small compared to the 

large number of SC-CO2 estimates available in the literature. EPA found considerable variation 

among these published estimates in terms of the models and input assumptions they employ 

(EPA, 2012b; EPA, 2012d). These studies differed in the emissions perturbation year, employed 

a wide range of constant and variable discount rate specifications, and considered a range of 

baseline socioeconomic and emissions scenarios that have been developed over the last 20 years. 

Furthermore, at the time, none of the other published estimates of the social cost of non-CO2

GHG were consistent with the SC-CO2 estimates developed by the IWG, and most were likely 

underestimates due to changes in the underlying science since their publication. 

Therefore, EPA concluded that the GWP approach would serve as an interim method of 

analysis until directly modeled social cost estimates for non-CO2 GHGs, consistent with the SCCO2 estimates developed by the IWG, were developed. EPA presented GWP-weighted estimates 

in sensitivity analyses rather than the main benefit-cost analyses. 

Since then, a paper by Marten et al. (2014) has provided the first set of published SC-CH4

estimates in the peer-reviewed literature that are consistent with the modeling assumptions 

underlying the SC-CO2 estimates.22 Specifically, the estimation approach of Marten et al. used 

 

21 We note that the truncation of the time period in the GWP calculation could lead to an overestimate of SC-CH4 for 

near term perturbation years in cases where the SC-CO2 is based on a sufficiently low or steeply declining 

discount rate. 

22 Marten et al. (2014) also provided the first set of SC-N2O estimates that are consistent with the assumptions 

underlying the SC-CO2 estimates. 

Commented [A17]: OMB RIA comment 24: Reviewer 

recomends providing a citation for Marten and Newbold 2012, 

which is not in the reference list. See 4-10. 

EPA response: Updated the reference list. 

Commented [A18]: OMB RIA Comment 23: Reviewer 

recommends on 4-9 footnoting that the bias is unknown for other 

GHG. 

EPA Response: Both the text and footnote are written to be specific 

to methane rather than non-GHGs more broadly. Given that this text 

is precise and does not make any suggestions about other non-CO2 

GHGs and that the rulemaking has no implications for other nonCO2 GHGs, we recommend leaving the text unchanged. Other 

GHGs are not relevant to this section. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-11 

the same set of three IAMs, five socioeconomic and emissions scenarios, equilibrium climate 

sensitivity distribution, three constant discount rates, and aggregation approach used by the IWG 

to develop the SC-CO2 estimates. The aggregation method involved distilling the 45 distributions 

of the SC-CH4 produced for each emissions year into four estimates: the mean across all models 

and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95th percentile 

of the pooled estimates from all models and scenarios using a 3 percent discount rate. The 

atmospheric lifetime radiative efficacy of methane used by Marten et al. is based on the estimates 

reported by the IPCC in their Fourth Assessment Report (AR4, 2007), including an adjustment in 

the radiative efficacy of methane to account for its role as a precursor for tropospheric ozone and 

stratospheric water. These values represent the same ones used by in the IPCC in AR4 for 

calculating GWPs. At the time Marten et al. developed their estimates of the SC-CH4, AR4 was 

the latest assessment report by the IPCC. The IPCC updates GWP estimates with each new 

assessment, and in the latest assessment, AR5, the latest estimate of the methane GWP ranged 

from 28-36, compared to a GWP of 25 in AR4. The updated values reflect a number of changes: 

changes in the lifetime and radiative efficiency estimates for CO2, changes in the lifetime 

estimate for methane, and changes in the correction factor applied to methane’s GWP to reflect 

the effect of methane emissions on other climatically important substances such as tropospheric 

ozone and stratospheric water vapor. In addition, the range presented in the latest IPCC report 

reflects different choices regarding whether to account for how biogenic and fossil methane have 

different carbon cycle effects, and for whether to account for climate feedbacks on the carbon 

cycle for both methane and carbon dioxide (rather than just for carbon dioxide as was done in 

AR4).23,24 

 

23 Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment 

Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, 

S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, 

Cambridge, United Kingdom and New York, NY, USA. 

24 Note that this proposal uses a GWP value for methane of 25 for CO2 equivalency calculations, consistent with the 

GHG emissions inventories and the IPCC Fourth Assessment Report. 
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4-12 

Marten et al. (2014) discuss these estimates (SC-CH4 estimates presented below in Table 

4-2), and compare them with other recent estimates in the literature.25 The authors noted that a 

direct comparison of their estimates with all of the other published estimates is difficult, given 

the differences in the models and socioeconomic and emissions scenarios, but results from three 

relatively recent studies offer a better basis for comparison (see Hope (2006), Waldhoff et al. 

(20141), Marten and Newbold (2012)). Marten et al. found that in general the SC-CH4 estimates 

from their 2014 paper are higher than previous estimates. The higher SC-CH4 estimates are 

partially driven by the higher effective radiative forcing due to the inclusion of indirect effects 

from methane emissions in their modeling. Marten et al., similar to other recent studies, also find 

that their directly modeled SC-CH4 estimates are higher than the GWP-weighted estimates. 

More detailed discussion of the SC-CH4 estimation methodology, results and a comparison to 

other published estimates can be found in Marten et al. 

Table 4-2 Social Cost of CH4, 2012 – 2050a [in 2012$ per metric ton] (Source: Marten et 

al., 2014b) 

Year 

SC-CH4

5% 

Average 

3% 

Average 

2.5% 

Average 

3% 

95th percentile 

2012 $430 $1,000 $1,400 $2,800 

2015 $490 $1,100 $1,500 $3,000 

2020 $580 $1,300 $1,700 $3,500 

2025 $700 $1,500 $1,900 $4,000 

2030 $820 $1,700 $2,200 $4,500 

2035 $970 $1,900 $2,500 $5,300 

2040 $1,100 $2,200 $2,800 $5,900 

2045 $1,300 $2,500 $3,000 $6,600 

2050 $1,400 $2,700 $3,300 $7,200 

a

 The values are emissions-year specific and are defined in real terms, i.e., adjusted for inflation using the GDP 

implicit price deflator. 

b

 The estimates in this table have been adjusted to reflect the minor technical corrections to the SC-CO2 estimates 

described above. See erratum Marten et al. (2015) for more details. 

 

25 Marten et al. (2014) estimates are presented in 2007 dollars. These estimates were adjusted for inflation using 

National Income and Product Accounts Tables, Table 1.1.9, Implicit Price Deflators for Gross Domestic Product 

(US Department of Commerce, Bureau of Economic Analysis), http://www.bea.gov/iTable/index_nipa.cfm 

Accessed 3/3/15. 

Commented [A19]: Citation added here and details added to 

references. 
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4-13 

The application of directly modeled estimates from Marten et al. (2014) to benefit-cost 

analysis of a regulatory action is analogous to the use of the SC-CO2 estimates. Specifically, the 

SC-CH4 estimates in Table 4-2 are used to monetize the benefits of reductions in methane 

emissions expected as a result of the proposed rulemaking. Forecast changes in methane 

emissions in a given year, expected as a result of the proposed regulatory action, are multiplied 

by the SC-CH4 estimate for that year. To obtain a present value estimate, the monetized stream 

of future non-CO2 benefits are discounted back to the analysis year using the same discount rate 

used to estimate the social cost of the non-CO2 GHG emission changes. In addition, the 

limitations for the SC-CO2 estimates discussed above likewise apply to the SC-CH4 estimates, 

given the consistency in the methodology. 

EPA recently conducted a peer review of the application of the Marten et al. (2014) nonCO2 social cost estimates in regulatory analysis and received responses that supported this 

application. Three reviewers considered seven charge questions that covered issues such as the 

EPA’s interpretation of the Marten et al. estimates, the consistency of the estimates with the SCCO2 estimates, EPA’s characterization of the limits of the GWP-approach to value non-CO2

GHG impacts, and the appropriateness of using the Marten et al. estimates in regulatory impact 

analyses. The reviewers agreed with EPA’s interpretation of Marten et al.’s estimates; generally 

found the estimates to be consistent with the SC-CO2 estimates; and concurred with the 

limitations of the GWP approach, finding directly modeled estimates to be more appropriate. 

While outside of the scope of the review, the reviewers briefly considered the limitations in the 

SC-CO2 methodology (e.g., those discussed earlier in this section) and noted that because the 

SC-CO2 and SC-CH4 methodologies are similar, the limitations also apply to the resulting SCCH4 estimates. Two of the reviewers concluded that use in RIAs of the SC-CH4 estimates 

developed by Marten et al. and published in the peer-reviewed literature is appropriate, provided 

that the Agency discuss the limitations, similar to the discussion provided for SC-CO2 and other 

economic analyses. All three reviewers encouraged continued improvements in the SC-CO2

estimates and suggested that as those improvements are realized they should also be reflected in 

the SC-CH4 estimates, with one reviewer suggesting the SC-CH4 estimates lag this process. EPA 

supports continued improvement in the SC-CO2 estimates developed by the U.S. government and 
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4-14 

agrees that improvements in the SC-CO2 estimates should also be reflected in the SC-CH4

estimates. The fact that the reviewers agree that the SC-CH4 estimates are generally consistent 

with the SC-CO2 estimates that are recommended by OMB’s guidance on valuing CO2 emissions 

reductions leads EPA to conclude that use of the SC-CH4 estimates is an analytical improvement 

over excluding methane emissions from the monetized portion of the benefit cost analysis. 

In light of the favorable peer review and past comments urging EPA to value non-CO2

GHG impacts in its rulemakings, the Agency has used the Marten et al. (2014) SC-CH4 estimates 

to value methane impacts expected from this proposed rulemaking and has included those 

benefits in the main benefits analysis. EPA seeks comments on the use of these directly modeled 

estimates, from the peer-reviewed literature, for the social cost of non-CO2 GHG. 

The methane benefits calculated using Marten et al. (2014) are presented below in Table 

4-3 for 2025. Applying this approach to the methane reductions estimated for this proposal, the 

2025 methane benefits vary by discount rate and range from about $310 million to approximately 

$1.7 billion; for the proposed option, the mean SC-CH4 at the 3% discount rate results in an 

estimate of about $660 million in 2025. 

Table 4-3 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.27 6.8 $190 $410 $530 $1,100 

Proposed Option 2.5/34 0.44 11 $310 $660 $850 $1,700 

Alternative Option 2.0/34 0.48 12 $340 $720 $930 $1,900 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

While the vast majority of this proposal’s climate-related benefits are associated with 

methane reductions, additional climate-related benefits are expected from the proposal’s 

secondary air impacts, specifically, a net reduction in CO2 emissions due to reduced demand for 
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4-15 

electricity from the grid as landfills generate electricity from landfill gas.26 These benefits are 

presented in Table 4-4 below. Monetizing the net CO2 reductions with the SC-CO2 estimates 

described in this section yields benefits that vary by discount rate and range from about $3.6 

million to approximately $36 million in 2025. For the proposed option, the mean SC-CO2 at the 

3% discount rate results in an estimate of about $12 million in 2025, which is about 2 percent of 

the estimated methane benefits in 2025 (average SC-CH4, 3 percent discount rate). 

Table 4-4 Estimated Global Benefits of Net CO2 Reductions in 2025* (in millions, 2012$) 

Metric tonnes of net 

CO2 reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 102,000 $1.5 $5.0 $7.5 $15 

Proposed Option 2.5/34 238,000 $3.6 $12 $18 $36 

Alternative Option 2.0/34 238,000 $3.6 $12 $18 $36 

*The SC-CO2 values are dollar-year and emissions-year specific. SC-CO2 values represent only a partial 

accounting of climate impacts.

Finally, in addition to the CO2 impacts discussed above, there is a small increase in CO2

emissions resulting from flaring of methane in response to this rule. We are not estimating the 

monetized disbenefits of these secondary emissions of CO2 because much of the methane that 

would have been released in the absence of the flare would have eventually oxidized into CO2 in 

the atmosphere. Note that the CO2 produced from the methane oxidizing in the atmosphere is not 

included in the calculation of the SC-CH4. 

However, EPA does recognize that because the growth rate of the SC-CO2 estimates are 

lower than their associated discount rates, the estimated impact of CO2 produced in the future 

from oxidized methane would be less than the estimated impact of CO2 released immediately 

from flaring, which would imply a small disbenefit associated with flaring. Assuming an average 

methane oxidation period of 8.7 years, consistent with the lifetime used in IPCC AR4, the 

 

26 The reduced demand for electricity from the grid more than offsets the additional energy demand required to 

operate the control system and the by-product emissions from the combustion of LFG. 

Commented [A20]: This discussion added in response to 

question during OMB call. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-16 

disbenefits associated with destroying one metric ton of methane and releasing the CO2

emissions in 2020 instead of being released in the future via the methane oxidation process is 

estimated to be $5 to $25 per metric ton CH4 depending on the SC-CO2 value or 0.7 percent to 

0.9 percent of the SC-CH4 estimates per metric ton for 2020. The analogous estimates for 2025 

are $7 to $34 per metric ton CH4 or 0.8 percent to 1.0 percent of the SC-CH4 estimates per metric 

ton for 2025.27 While EPA is not accounting for the CO2 disbenefits at this time, we request 

comment on the appropriateness of the monetization of such impacts using the SC-CO2 and 

aspects of the calculation.

4.2.2 Methane as an ozone precursor 

This rulemaking would reduce emissions of methane, a GHG and also a precursor to 

ozone. In remote areas, methane is a dominant precursor to tropospheric ozone formation (EPA, 

2013). Approximately 40% of the global annual mean ozone increase since preindustrial times is 

believed to be due to anthropogenic methane (HTAP, 2010). Projections of future emissions also 

indicate that methane is likely to be a key contributor to ozone concentrations in the future 

(HTAP, 2010). Unlike NOX and VOC, which affect ozone concentrations regionally and at 

hourly time scales, methane emissions affect ozone concentrations globally and on decadal time 

scales given methane’s relatively long atmospheric lifetime (HTAP, 2010). Reducing methane 

emissions, therefore, can reduce global background ozone concentrations, human exposure to 

ozone, and the incidence of ozone-related health effects (West et al., 2006, Anenberg et al., 2009, 

Sarofim et al., 2015). These benefits are global and occur in both urban and rural areas. 

Reductions in background ozone concentrations can also have benefits for agriculture and 

ecosystems (UNEP/WMO, 2011). Studies show that controlling methane emissions can reduce 

global ozone concentrations and climate change simultaneously, but controlling other shorterlived ozone precursors such as NOX, carbon monoxide, or non-methane VOC has larger local 

 

27 To calculate the disbenefits associated the complete destruction of a ton of CH4 through flaring, EPA took the 

difference between the SC-CO2 at the time of the flaring and in 8.7 years and discounted that value to the time of 

the flaring using the same discount rate as used to estimate the SC-CO2. This value was then scaled by 44/16 to 

account for the relative mass of carbon contained in a ton of CH4 versus a ton of CO2. The value of the SC-CO2

8.7 years after flaring was estimated by linearly interpolating between the annual SC-CO2 estimates reported in 

the TSD and inflated to 2012 dollars.
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4-17 

health benefits from greater reductions in local ozone concentrations (West and Fiore, 2005; 

West et al., 2006; Fiore et al. 2008; Dentener et al., 2005; Shindell et al., 2005, 2012; 

UNEP/WMO, 2011). The health, welfare, and climate effects associated with ozone are 

described in the preceding sections. Without air quality modeling, we are unable to estimate the 

effect that reducing methane will have on ozone concentrations at particular locations.Examining 

mortality benefits in isolation, However, the global monetized benefit of ozone reduction due to 

methane mitigation have been estimated to be on the order of $1000 per metric ton of methane 

emissions reducedin several studies (Anenberg et al., 2012; Shindell et al., 2012), an estimate 

similar in magnitude to the climate benefits of methane reductions estimated by the Marten et al. 

(2014) or GWP methods.

Recently, a paper was published in the peer-reviewed scientific literature that presented a 

range of estimates of the monetized ozone-related mortality benefits of reducing methane 

emissions (Sarofim et al. 2015). For example, under their base case assumptions using a 3% 

discount rate, Sarofim et al. find global ozone-related mortality benefits of methane emissions 

reductions to be $790 per tonne of methane in 2020, with 10.6%, or $80, of this amount resulting 

from mortality reductions in the United States. The methodology used in this study is consistent 

in some (but not all) aspects with the modeling underlying the SC-CO2 and SC-CH4 estimates 

discussed above, and required a number of additional assumptions such as baseline mortality 

rates and mortality response to ozone concentrations. The Sarofim et al. (2015) study may have 

implications for this benefits analysis as it provides a potential approach to estimating the ozone 

related mortality benefits resulting from the methane reductions expected from this proposed 

rulemaking. The EPA requests comment on Sarofim et al.’s approach to estimating the ozone 

related mortality benefits of methane emissions reductions, including technical considerations in 

applying their methodology to this regulatory impact analysis. 

4.2.3 Combined methane climate and ozone effects of methane

A recent United Nations Environment Programme (UNEP) assessment provided a 

comprehensive analysis of the health, climate, and agricultural benefits of measures to reduce 

methane, as well as black carbon, a component of fine particulate matter that absorbs radiation 

Commented [A21]: Updated based on recently published 

research. 
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4-18 

(UNEP/WMO, 2011; Shindell et al., 2012). The UNEP assessment found that while reducing 

longer-lived GHGs such as CO2 is necessary to protect against long-term climate change, 

reducing global methane and black carbon emissions would have global health benefits by 

reducing exposure to ozone and PM2.5 as well as potentially slowing the rate of climate change 

within the first half of this century. Relative to a business as usual reference scenario, 

implementing methane mitigation measures that achieve approximately 40% reductions in global 

methane emissions were estimated to avoid approximately 0.3°C globally averaged warming in 

2050 (including the impacts of both methane itself and subsequently formed ozone) and 47,000 

ozone-related premature deaths and 27 million metric tons of ozone-related crop yield losses 

globally in 2030 (Shindell et al., 2012). These benefits, including global climate impacts of 

methane and resulting ozone changes, and global ozone-related health and agricultural impacts, 

were valued at $700 to $5,000 per metric ton.28 The methane measures examined include 

extended methane recovery/utilization and reduced fugitive emissions from oil and gas 

production, which contributed the greatest climate benefit of all methane mitigation measures in 

North America and Europe (UNEP, 2011). Examining mortality benefits in isolation, the 

monetized benefit of ozone reduction due to methane mitigation have been estimated to be on the 

order of $1000 per metric ton of methane emissions reduced (Anenberg et al., 2012; Shindell et 

al., 2012), an estimate similar in magnitude to the climate benefits of methane reductions 

estimated by the Marten et al. (2014) or GWP methods. While monetized per-ton benefits of the 

climate, health, and agriculture impacts of methane mitigation have been estimated, there has not 

yet been a similar monetization of the parallel impacts on broader ecosystems. EPA continues to 

monitor developments in this area of research, but is not yet utilizing monetized estimates of the 

benefits of methane mitigation on mortality and agriculture due to ozone reductions. 

 

28 Benefit per ton values derived from Shindell et al. (2012) cannot be directly compared to, nor are they additive 

with, the ozone health benefit-per-ton estimates for the U.S. reported in Section 4.4.1, since they include climate 

and agricultural impacts, are calculated for global rather than U.S. impacts, and use different assumptions for the 

value of a statistical life. Similarly, these values cannot be compared to, nor are they additive with, the methane 

climate valuation estimates in Section 4.2.1 since they include health and agricultural benefits and use different 

assumptions for the Social Cost of Carbon. 
***E.O. 12866 Review – Draft – Do Not Cite, Quote or Release During Review*** 

4-19 

4.3 VOC as a PM2.5 precursor 

This rulemaking would reduce emissions of VOC, which are a precursor to PM2.5. Most 

VOC emitted are oxidized to carbon dioxide (CO2) rather than to PM, but a portion of VOC 

emission contributes to ambient PM2.5 levels as organic carbon aerosols (EPA, 2009a). 

Therefore, reducing these emissions would reduce PM2.5 formation, human exposure to PM2.5, 

and the incidence of PM2.5-related health effects. However, we have not quantified the PM2.5-

related benefits in this analysis. Analysis of organic carbon measurements suggest only a 

fraction of secondarily formed organic carbon aerosols are of anthropogenic origin. The current 

state of the science of secondary organic carbon aerosol formation indicates that anthropogenic 

VOC contribution to secondary organic carbon aerosol is often lower than the biogenic (natural) 

contribution. Given that a fraction of secondarily formed organic carbon aerosols is from 

anthropogenic VOC emissions and the extremely small amount of VOC emissions from this 

sector relative to the entire VOC inventory it is unlikely this sector has a large contribution to 

ambient secondary organic carbon aerosols. Photochemical models typically estimate secondary 

organic carbon from anthropogenic VOC emissions to be less than 0.1 μg/m3. 

Data resources and methodological limitations prevented EPA from monetizing the 

benefits of reducing VOCs. We were unable to perform air quality modeling for this rule to 

quantify the PM2.5 benefits associated with reducing VOC emissions. Due to the high degree of 

variability in the responsiveness of PM2.5 formation to VOC emission reductions, we are unable 

to estimate the effect that reducing VOC will have on ambient PM2.5 levels without air quality 

modeling. However, we provide the discussion below for context regarding findings from 

previous modeling. 

4.3.1 PM2.5 health effects and valuation 

Reducing VOC emissions would reduce PM2.5 formation, human exposure, and the 

incidence of PM2.5-related health effects. Reducing exposure to PM2.5 is associated with 

significant human health benefits, including avoiding mortality and respiratory morbidity. 

Researchers have associated PM2.5 exposure with adverse health effects in numerous 

toxicological, clinical and epidemiological studies (EPA, 2009a). When adequate data and 

resources are available, EPA generally quantifies several health effects associated with exposure 
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4-20 

to PM2.5 (e.g., EPA, 2011d). These health effects include premature mortality for adults and 

infants, cardiovascular morbidity such as heart attacks, hospital admissions, and respiratory 

morbidity such as asthma attacks, acute and chronic bronchitis, hospital and ER visits, work loss 

days, restricted activity days, and respiratory symptoms. Although EPA has not quantified these 

effects in previous benefits analyses, the scientific literature suggests that exposure to PM2.5 is 

also associated with adverse effects on birth weight, pre-term births, pulmonary function, other 

cardiovascular effects, and other respiratory effects (EPA, 2009a). 

When EPA quantifies PM2.5-related benefits, the Agency assumes that all fine particles, 

regardless of their chemical composition, are equally potent in causing premature mortality 

because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by 

particle type (EPA, 2009a). Based on our review of the current body of scientific literature, EPA 

estimates PM-related mortality without applying an assumed concentration threshold. This 

decision is supported by the data, which are quite consistent in showing effects down to the 

lowest measured levels of PM2.5 in the underlying epidemiology studies. 

Previous studies have estimated the monetized benefits-per-ton of reducing VOC 

emissions associated with the effect that those emissions have on ambient PM2.5 levels and the 

health effects associated with PM2.5 exposure (Fann, Fulcher, and Hubbell, 2009), and these 

estimates can provide useful context for this rulemaking. Using the estimates in Fann, Fulcher, 

and Hubbell (2009), the monetized benefit-per-ton of reducing VOC emissions in nine urban 

areas of the U.S. ranges from $560 in Seattle, WA to $5,700 in San Joaquin, CA, with a national 

average of $2,400. These estimates assume a 50 percent reduction in VOC, the Laden et al. 

(2006) mortality function (based on the Harvard Six Cities study, a large cohort epidemiology 

study in the Eastern U.S.), an analysis year of 2015, a 3% discount rate, and 2006$. 

 Additional benefit-per-ton estimates are available from this dataset using alternate 

assumptions regarding the relationship between PM2.5 exposure and premature mortality from 

empirical studies and supplied by experts (e.g., Pope et al., 2002; Laden et al., 2006; Roman et 

al., 2008). EPA generally presents a range of benefits estimates derived from the American 

Cancer Society cohort (e.g., Pope et al., 2002; Krewski et al., 2009) to the Harvard Six Cities 

cohort (e.g., Laden et al., 2006; Lepuele et al., 2012) because the studies are both well-designed 
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4-21 

and extensively peer reviewed, and EPA provides the benefit estimates derived from expert 

opinions in Roman et al. (2008) as a characterization of uncertainty. As shown in Table 4-5Table 

4-5, the range of VOC benefits that reflects the range of epidemiology studies and the range of 

the urban areas is $300 to $7,500 per ton of VOC reduced (2012$).29 Since these estimates were 

presented in the 2012 Oil and Gas NSPS RIA (EPA, 2012b), we updated our methods to apply 

more recent epidemiological studies for these cohorts (i.e., Krewski et al., 2009; Lepeule et al., 

2012) as well as additional updates to the morbidity studies and population data.30 Because these 

updates would not lead to significant changes in the benefit-per-ton estimates for VOC, we have 

not updated them here. 

While these ranges of benefit-per-ton estimates provide useful context, the geographic 

distribution of VOC emissions from the MSW landfill sector are not consistent with emissions 

modeled in Fann, Fulcher, and Hubbell (2009). In addition, the benefit-per-ton estimates for 

VOC emission reductions in that study are derived from total VOC emissions across all sectors. 

Coupled with the larger uncertainties about the relationship between VOC emissions and PM2.5, 

these factors lead the EPA to conclude that the available VOC benefit per ton estimates are not 

appropriate to calculate monetized benefits of this rule, even as a bounding exercise. 

 

29 We also converted the estimates from Fann, Fulcher, and Hubbell (2009) to 2012$ and applied EPA’s current 

value of a statistical life (VSL) estimate. For more information regarding EPA’s current VSL estimate, please see 

Section 5.6.5.1 of the RIA for the PM NAAQS RIA (EPA, 2012c). EPA continues to work to update its 

guidance on valuing mortality risk reductions. 

30 For more information regarding these updates, please see Section 5.3 of the RIA for the final PM NAAQS (EPA, 

2012c). 
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Table 4-5 Monetized Benefits-per-Ton Estimates for VOC based on Previous Modeling in 2015 (2012$) 

Area Pope et al. (2002) Laden et al. (2006) Expert A Expert B Expert C Expert D Expert E Expert F Expert G Expert H Expert I Expert J Expert K Expert L 

Atlanta $660 $1,600 $1,700 $1,300 $1,300 $920 $2,100 $1,200 $780 $980 $1,300 $1,000 $260 $1,000

Chicago $1,600 $4,000 $4,200 $3,300 $3,200 $2,300 $5,300 $3,000 $1,900 $2,400 $3,200 $2,600 $640 $2,500

Dallas $320 $790 $830 $650 $630 $450 $1,000 $580 $380 $480 $630 $510 $130 $490 

Denver $770 $1,900 $2,000 $1,500 $1,500 $1,100 $2,400 $1,400 $910 $1,100 $1,500 $1,200 $300 $910 

NYC/ Philadelphia $2,300 $5,600 $5,900 $4,600 $4,500 $3,200 $7,300 $4,100 $2,700 $3,400 $4,500 $3,600 $890 $3,300

Phoenix $1,100 $2,700 $2,800 $2,200 $2,100 $1,500 $3,500 $2,000 $1,300 $1,600 $2,100 $1,700 $420 $1,600

Salt Lake $1,400 $3,300 $3,500 $2,700 $2,700 $1,900 $4,400 $2,500 $1,600 $2,000 $2,700 $2,200 $570 $2,100

San Joaquin $3,100 $7,500 $7,900 $6,100 $6,000 $4,300 $9,700 $5,500 $3,600 $4,500 $6,000 $4,900 $1,400 $4,600

Seattle $300 $730 $770 $570 $590 $420 $950 $540 $350 $440 $580 $470 $120 $350 

National average $1,300 $3,200 $3,400 $2,600 $2,600 $1,800 $4,200 $2,300 $1,500 $1,900 $2,500 $2,100 $520 $1,900

* These estimates assumed a 50 percent reduction in VOC emissions, an analysis year of 2015, and a 3 percent discount rate. All estimates are rounded to two 

significant digits. These estimates have been adjusted from Fann, Fulcher, and Hubbell (2009) to reflect a more recent currency year and EPA’s current VSL estimate. However, these estimates have not been updated to reflect recent epidemiological studies for mortality studies, morbidity studies, or population data. Using a discount rate of 7 percent, the benefit-per-ton estimates would be approximately 9 percent lower. Assuming a 75 percent reduction in VOC emissions would increase the benefit-per-ton estimates by approximately 4 percent to 52 percent. Assuming a 25 percent reduction in VOC emissions would decrease the benefit-per-ton estimates by 5 percent to 52 percent. EPA generally presents a range of benefits estimates derived from the expert functions from Roman et al. (2008) as a characterization of uncertainty. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-23 

4.3.2 Visibility Effects 

Reducing secondary formation of PM2.5 from VOC emissions would improve visibility 

throughout the U.S. Fine particles with significant light-extinction efficiencies include sulfates, 

nitrates, organic carbon, elemental carbon, and soil (Sisler, 1996). Suspended particles and gases 

degrade visibility by scattering and absorbing light. Higher visibility impairment levels in the 

East are due to generally higher concentrations of fine particles, particularly sulfates, and higher 

average relative humidity levels. Visibility has direct significance to people’s enjoyment of daily 

activities and their overall sense of wellbeing. Good visibility increases the quality of life where 

individuals live and work, and where they engage in recreational activities. Previous analyses 

(EPA, 2006b; EPA, 2011d; EPA, 2011a; EPA, 2012c) show that visibility benefits are a 

significant welfare benefit category. Without air quality modeling, we are unable to estimate 

visibility related benefits, nor are we able to determine whether VOC emission reductions would 

be likely to have a significant impact on visibility in urban areas or Class I areas. 

4.4 VOC as an Ozone Precursor 

This rulemaking would reduce emissions of VOC, which are also precursors to secondary 

formation of ozone. Ozone is not emitted directly into the air, but is created when its two 

primary components, volatile organic compounds (VOC) and oxides of nitrogen (NOX), react in 

the presence of sunlight. In urban areas, compounds representing all classes of VOC and CO are 

important compounds for ozone formation, but biogenic VOC emitted from vegetation tend to be 

more important compounds in non-urban vegetated areas (EPA, 2013). Therefore, reducing 

these emissions would reduce ozone formation, human exposure to ozone, and the incidence of 

ozone-related health effects. However, we have not quantified the ozone-related benefits in this 

analysis for several reasons. First, previous rules have shown that the monetized benefits 

associated with reducing ozone exposure are generally smaller than PM-related benefits, even 

when ozone is the pollutant targeted for control (EPA, 2010a; EPA, 2014a). Second, the 

complex non-linear chemistry of ozone formation introduces uncertainty to the development and 

application of a benefit-per-ton estimate, particularly for sectors with substantial new growth. 

Third, the impact of reducing VOC emissions is spatially heterogeneous depending on local air 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-24 

chemistry. Urban areas with a high population concentration are often VOC-limited, which 

means that ozone is most effectively reduced by lowering VOC. Rural areas and downwind 

suburban areas are often NOX-limited, which means that ozone concentrations are most 

effectively reduced by lowering NOX emissions, rather than lowering emissions of VOC. 

Between these areas, ozone is relatively insensitive to marginal changes in both NOX and VOC. 

Due to data limitations, we did not perform air quality modeling for this rule needed to 

quantify the ozone benefits associated with reducing VOC emissions. Due to the high degree of 

variability in the responsiveness of ozone formation to VOC emission reductions and data 

limitations regarding the location of the emissions reductions, we are unable to estimate the 

effect that reducing VOC will have on ambient ozone concentrations without air quality 

modeling. 

4.4.1 Ozone health effects and valuation 

Reducing ambient ozone concentrations is associated with significant human health 

benefits, including mortality and respiratory morbidity (EPA, 2010a). Researchers have 

associated ozone exposure with adverse health effects in numerous toxicological, clinical and 

epidemiological studies (EPA, 2013). When adequate data and resources are available, EPA 

generally quantifies several health effects associated with exposure to ozone (e.g., EPA, 2010a; 

EPA, 2011a). These health effects include respiratory morbidity such as asthma attacks, hospital 

and emergency department visits, school loss days, as well as premature mortality. The scientific 

literature is also suggestive that exposure to ozone is also associated with chronic respiratory 

damage and premature aging of the lungs. 

In a recent EPA analysis, EPA estimated that reducing 15,000 tons of VOC from 

industrial boilers resulted in $3.6 to $15 million (2008$) of monetized benefits from reduced 

ozone exposure (EPA, 2011b).31 After updating the currency year to 2012$, this implies a 

benefit-per-ton for ozone of $260 to $1,070 per ton of VOC reduced. Since EPA conducted the 

 

31 While EPA has estimated the ozone benefits for many scenarios, most of these scenarios also reduce NOX

emissions, which make it difficult to isolate the benefits attributable to VOC reductions. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-25 

analysis of industrial boilers, EPA published the Integrated Science Assessment for Ozone (EPA, 

2013), the Health Risk and Exposure Assessment for Ozone (EPA, 2014a), and the RIA for the 

proposed Ozone NAAQS (EPA, 2014b). Therefore, the ozone mortality studies applied in the 

boiler analysis, while current at that time, do not reflect the most updated literature available. 

The selection of ozone mortality studies used to estimate benefits in RIAs was revisited in the 

RIA for the proposed Ozone NAAQS. Applying the more recent studies would lead to benefitper-ton estimates for ozone within the range shown here. While these ranges of benefit-per-ton 

estimates provide useful context, the geographic distribution of VOC emissions from the MSW 

landfill sector are not consistent with emissions modeled in the boiler analysis. Therefore, we do 

not believe that those estimates to provide useful estimates of the monetized benefits of this rule, 

even as a bounding exercise. 

4.4.2 Ozone vegetation effects 

Exposure to ozone has been associated with a wide array of vegetation and ecosystem 

effects in the published literature (EPA, 2013a). Sensitivity to ozone is highly variable across 

species, with over 66 vegetation species identified as “ozone-sensitive”, many of which occur in 

state and national parks and forests. These effects include those that damage or impair the 

intended use of the plant or ecosystem. Such effects are considered adverse to the public welfare 

and can include reduced growth and/or biomass production in sensitive trees, reduced yield and 

quality of crops, visible foliar injury, species composition shift, and changes in ecosystems and 

associated ecosystem services. 

4.4.3 Ozone climate effects 

Ozone is a well-known short-lived climate forcing (SLCF) greenhouse gas (GHG) (EPA, 

2006a). Stratospheric ozone (the upper ozone layer) is beneficial because it protects life on Earth 

from the sun’s harmful ultraviolet (UV) radiation. In contrast, tropospheric ozone (ozone in the 

lower atmosphere) is a harmful air pollutant that adversely affects human health and the 

environment and contributes significantly to regional and global climate change. Due to its short 

atmospheric lifetime, tropospheric ozone concentrations exhibit large spatial and temporal 

variability (EPA, 2009b). A recent United Nations Environment Programme (UNEP) study 
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4-26 

reports that the threefold increase in ground level ozone during the past 100 years makes it the 

third most important contributor to human contributed climate change behind CO2 and methane. 

This quantifiable influence of ground level ozone on climate leads to increases in global surface 

temperature and changes in hydrological cycles. 

4.5 Hazardous Air Pollutant (HAP) Benefits 

Even though emissions of air toxics from all sources in the U.S. declined by approximately 

42 percent since 1990, the 2005 National-Scale Air Toxics Assessment (NATA) predicts that 

most Americans are exposed to ambient concentrations of air toxics at levels that have the 

potential to cause adverse health effects (EPA, 2011c).32 The levels of air toxics to which people 

are exposed vary depending on where they live and work and the kinds of activities in which 

they engage. In order to identify and prioritize air toxics, emission source types and locations 

that are of greatest potential concern, the U.S. EPA conducts the NATA. 33 The most recent 

NATA was conducted for calendar year 2005 and was released in March 2011. NATA includes 

four steps: 

1) Compiling a national emissions inventory of air toxics emissions from outdoor sources 

2) Estimating ambient concentrations of air toxics across the United States utilizing 

dispersion models 

3) Estimating population exposures across the United States utilizing exposure models 

4) Characterizing potential public health risk due to inhalation of air toxics including both 

cancer and noncancer effects 

 

32 The 2005 NATA is available on the Internet at http://www.epa.gov/ttn/atw/nata2005/.

33 The NATA modeling framework has a number of limitations that prevent its use as the sole basis for setting 

regulatory standards. These limitations and uncertainties are discussed on the 2005 NATA website. Even so, 

this modeling framework is very useful in identifying air toxic pollutants and sources of greatest concern, setting 

regulatory priorities, and informing the decision making process. U.S. EPA. (2011) 2005 National-Scale Air 

Toxics Assessment. http://www.epa.gov/ttn/atw/nata2005/

Commented [A22]: OMB RIA Comment 25: Reviewer 

recommends more specificity in the HAP benefits discussion on 4.5. 

If there are known HAP emissions please focus the discussion to 

those emissions. The current discussion doesn’t seem very relevant 

to these rulemakings. 

EPA Response: Section 4.5 only includes a qualitative discussion of 

four HAP that are known to be part of landfill gas: benzene, toluene, 

ethylbenzene, and vinyl chloride. Even though we cannot quantify 

the emission reductions of these HAP, we anticipate reduced 

exposure to them as a result of this rulemaking. The NATA 

discussion provides context for evaluating these qualitative HAP 

benefits. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-27 

Based on the 2005 NATA, EPA estimates that about 5 percent of census tracts 

nationwide have increased cancer risks greater than 100 in a million. The average national 

cancer risk is about 50 in a million. Nationwide, the key pollutants that contribute most to the 

overall cancer risks are formaldehyde and benzene. 34,35 Secondary formation (e.g., formaldehyde 

forming from other emitted pollutants) was the largest contributor to cancer risks, while 

stationary, mobile and background sources contribute almost equal portions of the remaining 

cancer risk. 

Noncancer health effects can result from chronic,36 subchronic,37 or acute38 inhalation 

exposures to air toxics, and include neurological, cardiovascular, liver, kidney, and respiratory 

effects as well as effects on the immune and reproductive systems. According to the 2005 

NATA, about three-fourths of the U.S. population was exposed to an average chronic 

concentration of air toxics that has the potential for adverse noncancer respiratory health effects.

Results from the 2005 NATA indicate that acrolein is the primary driver for noncancer 

respiratory risk. 

Figure 4-2 and Figure 4-3 depict the estimated census tract-level carcinogenic risk and 

noncancer respiratory hazard from the assessment. It is important to note that large reductions in 

HAP emissions may not necessarily translate into significant reductions in health risk because 

toxicity varies by pollutant, and exposures may or may not exceed levels of concern. For 

 

34 Details on EPA’s approach to characterization of cancer risks and uncertainties associated with the 2005 NATA 

risk estimates can be found at http://www.epa.gov/ttn/atw/nata1999/riskbg.html#Z2. 

35 Details about the overall confidence of certainty ranking of the individual pieces of NATA assessments including 

both quantitative (e.g., model-to-monitor ratios) and qualitative (e.g., quality of data, review of emission 

inventories) judgments can be found at http://www.epa.gov/ttn/atw/nata/roy/page16.html. 

36 Chronic exposure is defined in the glossary of the Integrated Risk Information System (IRIS) database 

(http://www.epa.gov/iris) as repeated exposure by the oral, dermal, or inhalation route for more than 

approximately 10% of the life span in humans (more than approximately 90 days to 2 years in typically used 

laboratory animal species).

37 Defined in the IRIS database as repeated exposure by the oral, dermal, or inhalation route for more than 30 days, 

up to approximately 10% of the life span in humans (more than 30 days up to approximately 90 days in typically 

used laboratory animal species).

38 Defined in the IRIS database as exposure by the oral, dermal, or inhalation route for 24 hours or less. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-28 

example, acetaldehyde mass emissions were more than double acrolein emissions on a national 

basis in EPA’s 2005 National Emissions Inventory (NEI). However, the Integrated Risk 

Information System (IRIS) reference concentration (RfC) for acrolein is considerably lower than 

that for acetaldehyde, suggesting that acrolein could be potentially more toxic than 

acetaldehyde.39 Thus, it is important to account for the toxicity and exposure, as well as the mass 

of the targeted emissions. 

Figure 4-2 2005 NATA Model Estimated Census Tract Carcinogenic Risk from HAP 

Exposure from Emissions of All Outdoor Sources (inclusive of Residental Wood Heaters) 

based on the 2005 National Toxic Inventory. 

 

39 Details on the derivation of IRIS values and available supporting documentation for individual chemicals (as well 

as chemical values comparisons) can be found at http://cfpub.epa.gov/ncea/iris/compare.cfm. 

Commented [A23]: OMB RIA Comment 1: Reviewer 

recommends deleting the discussion in the RIA (starting on page 4-

25) because acrolein and acetaldehyde are HAPS but not key 

landfills gases. Further, the discussion of acrolein being “more 

toxic” is uncertain because there is no information about doseresponse. Without dose response, all that can be said is that adverse 

health effects can start to manifest at lower concentrations for 

acrolein than acetaldehyde. 

EPA Response: Text has been deleted. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-29 

Figure 4-3 2005 NATA Model Estimated Census Tract Noncancer Risk from HAP 

Exposure from Emissions of All Outdoor Sources (inclusive of Residental Wood Heaters) 

based on the 2005 National Toxic Inventory 

Due to methodology and data limitations, we were unable to estimate the benefits 

associated with the hazardous air pollutants that would be reduced as a result of this rule. In a 

few previous analyses of the benefits of reductions in HAP, EPA has quantified the benefits of 

potential reductions in the incidences of cancer and noncancer risk (e.g., EPA, 1995). In those 

analyses, EPA relied on unit risk factors (URF) and reference concentrations (RfC) developed 

through risk assessment procedures. The URF is a quantitative estimate of the carcinogenic 

potency of a pollutant, often expressed as the probability of contracting cancer from a 70-year 

lifetime continuous exposure to a concentration of one μg/m3 of a pollutant. These URFs are 

designed to be conservative, and as such, are more likely to represent the high end of the 

distribution of risk rather than a best or most likely estimate of risk. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-30 

An RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a 

continuous inhalation exposure to the human population (including sensitive subgroups) that is 

likely to be without an appreciable risk of deleterious noncancer health effects during a lifetime. 

As part of the second prospective analysis of the benefits and costs of the Clean Air Act (EPA, 

2011a), EPA conducted a case study analysis of the health effects associated with reducing 

exposure to benzene in Houston from implementation of the Clean Air Act (IEc, 2009). While 

reviewing the draft report, EPA’s Advisory Council on Clean Air Compliance Analysis 

concluded that “the challenges for assessing progress in health improvement as a result of 

reductions in emissions of hazardous air pollutants (HAP) are daunting...due to a lack of 

exposure-response functions, uncertainties in emissions inventories and background levels, the 

difficulty of extrapolating risk estimates to low doses and the challenges of tracking health 

progress for diseases, such as cancer, that have long latency periods” (EPA-SAB, 2008). 

In 2009, EPA convened a workshop to address the inherent complexities, limitations, and 

uncertainties in current methods to quantify the benefits of reducing HAP. Recommendations 

from this workshop included identifying research priorities, focusing on susceptible and 

vulnerable populations, and improving dose-response relationships (Gwinn et al., 2011). 

In summary, monetization of the benefits of reductions in cancer incidences requires 

several important inputs, including central estimates of cancer risks, estimates of exposure to 

carcinogenic HAP, and estimates of the value of an avoided case of cancer (fatal and non-fatal). 

Due to methodology and data limitations, we did not attempt to monetize the health benefits of 

reductions in HAP in this analysis. Instead, we provide a qualitative analysis of the health effects 

associated with the HAP anticipated to be reduced by this rule. EPA remains committed to 

improving methods for estimating HAP benefits by continuing to explore additional concepts of 

benefits, including changes in the distribution of risk. 

In the subsequent sections, we describe the health effects associated with the main HAP 

of concern from the MSW landfill sector: benzene, ethylbenzene, toluene, and vinyl chloride. 

This rule is anticipated to avoid or reduce 2,770 tons of NMOC per year. With the data 

available, it was not possible to estimate the tons of each individual HAP that would be reduced. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-31 

Therefore, in addition to the reasons identified above, we cannot estimate the monetized benefits 

associated with reducing HAP emissions for this rule.

4.5.1 Benzene 

The EPA’s IRIS database lists benzene as a known human carcinogen (causing leukemia) 

by all routes of exposure, and concludes that exposure is associated with additional health effects, 

including genetic changes in both humans and animals and increased proliferation of bone marrow 

cells in mice.40,41,42 EPA states in its IRIS database that data indicate a causal relationship between 

benzene exposure and acute lymphocytic leukemia and suggest a relationship between benzene 

exposure and chronic non-lymphocytic leukemia and chronic lymphocytic leukemia. The IARC 

has determined that benzene is a human carcinogen and the U.S. Department of Health and Human 

Services has characterized benzene as a known human carcinogen.43,44

A number of adverse noncancer health effects including blood disorders, such as 

preleukemia and aplastic anemia, have also been associated with long-term exposure to 

benzene.45,46

 

40 U.S. Environmental Protection Agency (EPA). 2000. Integrated Risk Information System File for Benzene. 

Research and Development, National Center for Environmental Assessment, Washington, DC. This material is 

available electronically at: http://www.epa.gov/iris/subst/0276.htm. 

41 International Agency for Research on Cancer, IARC monographs on the evaluation of carcinogenic risk of 

chemicals to humans, Volume 29, Some industrial chemicals and dyestuffs, International Agency for Research 

on Cancer, World Health Organization, Lyon, France, p. 345-389, 1982. 

42 Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry, V.A. (1992) Synergistic action of the benzene metabolite 

hydroquinone on myelopoietic stimulating activity of granulocyte/macrophage colony-stimulating factor in vitro, 

Proc. Natl. Acad. Sci. 89:3691-3695. 

43 International Agency for Research on Cancer (IARC). 1987. Monographs on the evaluation of carcinogenic risk 

of chemicals to humans, Volume 29, Supplement 7, Some industrial chemicals and dyestuffs, World Health 

Organization, Lyon, France. 

44 U.S. Department of Health and Human Services National Toxicology Program 11th Report on Carcinogens 

available at: http://ntp.niehs.nih.gov/go/16183 . 

45 Aksoy, M. (1989). Hematotoxicity and carcinogenicity of benzene. Environ. Health Perspect. 82: 193-197. 

46 Goldstein, B.D. (1988). Benzene toxicity. Occupational medicine. State of the Art Reviews. 3: 541-554. 

Commented [A24]: OMB RIA Comment 2: Reviewer 

recommends clarifying in the RIA that EPA cannot estimate how 

much HAPs would be reduced because of this rule, and therefore 

cannot estimate benefits. 

EPA Response: This has been clarified in this section. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-32 

4.5.2 Ethylbenzene 

Ethylbenzene is a major industrial chemical produced by alkylation of benzene. The pure 

chemical is used almost exclusively for styrene production. It is also a constituent of crude 

petroleum and is found in gasoline and diesel fuels. Acute (short-term) exposure to ethylbenzene 

in humans results in respiratory effects such as throat irritation and chest constriction, and 

irritation of the eyes, and neurological effects such as dizziness. Chronic (long-term) exposure 

of humans to ethylbenzene may cause eye and lung irritation, with possible adverse effects on 

the blood. Animal studies have reported effects on the blood, liver, and kidneys and endocrine 

system from chronic inhalation exposure to ethylbenzene. No information is available on the 

developmental or reproductive effects of ethylbenzene in humans, but animal studies have 

reported developmental effects, including birth defects in animals exposed via inhalation. 

Studies in rodents reported increases in the percentage of animals with tumors of the nasal and 

oral cavities in male and female rats exposed to ethylbenzene via the oral route.47,48 The reports of 

these studies lacked detailed information on the incidence of specific tumors, statistical analysis, 

survival data, and information on historical controls, thus the results of these studies were 

considered inconclusive by the International Agency for Research on Cancer (IARC, 2000) and 

the National Toxicology Program (NTP).49,50 The NTP (1999) carried out a chronic inhalation 

bioassay in mice and rats and found clear evidence of carcinogenic activity in male rats and some 

evidence in female rats, based on increased incidences of renal tubule adenoma or carcinoma in 

male rats and renal tubule adenoma in females. NTP (1999) also noted increases in the incidence 

 

47 Maltoni C, Conti B, Giuliano C and Belpoggi F, 1985. Experimental studies on benzene carcinogenicity at the 

Bologna Institute of Oncology: Current results and ongoing research. Am J Ind Med 7:415-446.

48 Maltoni C, Ciliberti A, Pinto C, Soffritti M, Belpoggi F and Menarini L, 1997. Results of long-term experimental 

carcinogenicity studies of the effects of gasoline, correlated fuels, and major gasoline aromatics on rats. Annals 

NY Acad Sci 837:15-52.

49International Agency for Research on Cancer (IARC), 2000. Monographs on the Evaluation of Carcinogenic Risks 

to Humans. Some Industrial Chemicals. Vol. 77, p. 227-266. IARC, Lyon, France.

50 National Toxicology Program (NTP), 1999. Toxicology and Carcinogenesis Studies of Ethylbenzene (CAS No. 

100-41-4) in F344/N Rats and in B6C3F1 Mice (Inhalation Studies). Technical Report Series No. 466. NIH 

Publication No. 99-3956. U.S. Department of Health and Human Services, Public Health Service, National 

Institutes of Health. NTP, Research Triangle Park, NC.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-33 

of testicular adenoma in male rats. Increased incidences of lung alveolar/bronchiolar adenoma or 

carcinoma were observed in male mice and liver hepatocellular adenoma or carcinoma in female 

mice, which provided some evidence of carcinogenic activity in male and female mice (NTP, 

1999). IARC (2000) classified ethylbenzene as Group 2B, possibly carcinogenic to humans, 

based on the NTP studies. 

4.5.3 Toluene51

Under the 2005 Guidelines for Carcinogen Risk Assessment, there is inadequate 

information to assess the carcinogenic potential of toluene because studies of humans chronically 

exposed to toluene are inconclusive, and toluene was not carcinogenic in adequate inhalation 

cancer bioassays of rats and mice exposed for life.

52,53,54, and increased Increased incidences of 

mammary cancer and leukemia were reported in a lifetime rat oral bioassay;

55

 however, this 

evidence was considered equivocal since cancers were observed at the low dose tested 

(500mg/kg/day) but not at the higher dose tested (800 mg/kg/day). In support of EPA’s cancer 

classification, IARC has classified toluene as Group 3 (not classifiable as to its carcinogenicity 

in humans) with a supporting statement that there is inadequate evidence in humans and evidence 

suggesting a lack of carcinogenicity of toluene in experimental animals.

56

 

51 All health effects language for this section came from: U.S. EPA. 2005. “Full IRIS Summary for Toluene 

(CASRN 108-88-3)” Environmental Protection Agency, Integrated Risk Information System (IRIS), Office of 

Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH. 

Available on the Internet at <http://www.epa.gov/iris/subst/0118.htm>.

52 CIIT (Chemical Industry Institute of Toxicology). (1980) A twenty-four month inhalation toxicology study in 

Fischer-344 rats exposed to atmospheric toluene. Conducted by Industrial Bio-Test Laboratories, Inc., Decatur, 

IL, and Experimental Pathology Laboratories, Inc., Raleigh, NC, for CIIT, Research Triangle Park, NC..

53 NTP (National Toxicology Program), 1990. Toxicology and carcinogenesis studies of toluene (CAS No. 108-88-

3) in F344/N rats and B5C3F1 mice (inhalation studies). Public Health Service, U.S. Department of Health and 

Human Services; NTP TR 371. Available from: National Institute of Environmental Health Sciences, Research 

Triangle Park, NC.

54 Huff, J., 2003. Absence of carcinogenic activity in Fischer rats and B6C3F1 mice following 103-week inhalation 

exposures to toluene. Int J Occup Environ Health 9:138-146.

55 Maltoni, C; Ciliberti, A; Pinto, C; et al., 1997. Results of long-term experimental carcinogenicity studies of the 

effects of gasoline, correlated fuels, and major gasoline aromatics on rats. Ann NY Acad Sci 837:15-52. 

56 IARC. (International Agency for Research on Cancer), 1999. IARC monographs on the evaluation of carcinogenic 

risks of chemicals to humans. Vol. 71, Part 2. Re-evaluation of some organic chemicals, hydrazine and hydrogen 

peroxide. Lyon, France: International Agency for Research on Cancer, pp. 829-864.

Commented [A25]: OMB RIA Comment 3: Reviewer 

recommends clarifying the first paragraph of the RIA on toluene. It 

currently says “toluene was not carcinogenic in adequate inhalation 

cancer bioassays of rats and mice exposed for life, and increased 

evidence of mammary cancer and leukemia were reported in a 

lifetime rat oral bioassay.” Were the increased incidences of 

mammary cancer and leukemia observed in inadequate oral cancel 

bioassays? 

The cancer classification is just hazard identification, so there should 

be discussion on why the evidence is inadequate despite a positive 

oral cancer bioassay. 

EPA Response: This discussion has been clarified. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-34 

The central nervous system (CNS) is the primary target for toluene toxicity in both 

humans and animals for acute and chronic exposures. CNS dysfunction (which is often 

reversible) and narcosis have been frequently observed in humans acutely exposed to low or 

moderate levels of toluene by inhalation: symptoms include fatigue, sleepiness, headaches, and 

nausea. Central nervous system depression has been reported to occur in chronic abusers 

exposed to high levels of toluene. Symptoms include ataxia, tremors, cerebral atrophy, 

nystagmus (involuntary eye movements), and impaired speech, hearing, and vision. Chronic 

inhalation exposure of humans to toluene also causes irritation of the upper respiratory tract, eye 

irritation, dizziness, headaches, and difficulty with sleep. 

Human studies have also reported developmental effects, such as CNS dysfunction, 

attention deficits, and minor craniofacial and limb anomalies, in the children of women who 

abused toluene during pregnancy. A substantial database examining the effects of toluene in 

subchronic and chronic occupationally exposed humans exists. The weight of evidence from 

these studies indicates neurological effects (i.e., impaired color vision, impaired hearing, 

decreased performance in neurobehavioral analysis, changes in motor and sensory nerve 

conduction velocity, headache, and dizziness) as the most sensitive endpoint. 

4.5.4 Vinyl Chloride57

Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products. 

Acute (short-term) exposure to high levels of vinyl chloride in air has resulted in central nervous 

system effects (CNS), such as dizziness, drowsiness, and headaches in humans. Chronic (longterm) exposure to vinyl chloride through inhalation and oral exposure in humans has resulted in 

liver damage. Cancer is a major concern from exposure to vinyl chloride via inhalation, as vinyl 

chloride exposure has been shown to increase the risk of a rare form of liver cancer in humans. 

 

57 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Vinyl Chloride. 2000. 

Available online at http://www.epa.gov/iris/subst/1001.htm. 
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4-35 

EPA has classified vinyl chloride as a Group A, “human carcinogen”. IARC has classified vinyl 

chloride as carcinogenic to humans (Group 1).58

4.5.5 Other Air Toxics 

In addition to the compounds described above, other air toxic compounds might be 

affected by this rule. Information regarding the health effects of those compounds can be found 

in EPA’s IRIS database.59

4.6 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

Emission Guidelines for existing MSW landfills, the quantity and composition of landfill gas 

does change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a 

more complete picture of the climate benefits of the Emission Guidelines alternatives over time 

by presenting results from the years 2020, 2030, and 2040. 

Table 4-6 presents the climate benefits of the alternatives in the 2020 snapshot year. 

Table 4-6 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.24 5.9 $140 $310 $410 $810 

Proposed Option 2.5/34 0.36 9.0 $210 $460 $620 $1,200 

Alternative Option 2.0/34 0.40 10.1 $240 $520 $700 $1,400 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

 

58 International Agency for Research on Cancer (IARC). 2008. Monographs on the Evaluation of the Carcinogenic 

Risk of Chemicals for Humans. Vol. 97, pp311. Lyon, France: International Agency for Research on Cancer. 

Available online at http://monographs.iarc.fr/ENG/Monographs/vol97/index.php. 

59 U.S. EPA Integrated Risk Information System (IRIS) database is available at: www.epa.gov/iris 

Commented [A26]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

4-36 

Table 4-7 presents the climate benefits of the alternatives in the 2030 snapshot year.

Table 4-7 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.31 7.7 $250 $530 $670 $1,400 

Proposed Option 2.5/34 0.50 12 $410 $860 $1,100 $2,300 

Alternative Option 2.0/34 0.53 13 $440 $920 $1,200 $2,400 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 4-8 presents the climate benefits of the alternatives in the 2040 snapshot year.

Table 4-8 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.21 5.3 $230 $450 $590 $1,300 

Proposed Option 2.5/34 0.34 8.4 $360 $720 $940 $2,000 

Alternative Option 2.0/34 0.35 8.7 $380 $750 $980 $2,100 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

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Commented [A27]: Updated citation 

Commented [A28]: Relevant, peer-reviewed paper just 

published online 
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*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

5-1 

5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS 

5.1 Introduction 

This chapter of the RIA includes three sets of discussions related to the proposed 

Emission Guidelines for MSW landfills: 

• Economic Impact Analysis 

• Employment Analysis 

• Small Business Analysis 

These discussions are intended to assist the reader of the RIA to better understand the potential 

economic impacts of the proposal, though data and methodological limitations prevented a 

complete assessment of the economic impacts of the proposed Emission Guidelines. 

5.2 Economic Impact Analysis 

The impacts shown for the proposal reflect the incremental difference between facilities 

in the baseline and for an option that reduces the NMOC emission rate threshold to 34 Mg/yr 

from the current emissions guideline level of 50 Mg/yr (proposed option 2.5/34). The proposal 

retains the design capacity threshold of 2.5 million Mg or 2.5 million cubic feet. Because the 

proposed option 2.5/34 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 Chapter 3 of this 

RIA to be about $46.8 million in 2025 for the proposed option. 

Assessing the economic impacts of these costs is difficult due to the nature of the MSW 

industry. As previously discussed in Chapter 2, landfills are owned by private companies, 

government (local, state, or federal), or individuals. In 2014, 58 percent of landfills were owned 

by public entities. Households served by public landfills may not respond to price increases in 

the same way as they would if served by private firms, since these households typically pay their 

collection fees through property taxes or other mandatory payments. In these cases, affected 

landfills may be more readily able to pass through increased costs to customers. Households 

served by private landfills may choose to alter their behavior in response to increased collection 

fees, but research into the price elasticity of demand for waste services has typically found the 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

5-2 

demand for waste services to be price inelastic (Bel and Gradus, 2014; Kinnaman, 2006). As was 

shown in Table 2-5, tipping fees have for the most part increased over time, and industry reports 

indicate that “firms have generally managed to hold the line on pricing and win 2-3 percent 

increases to maintain positive revenue amid slow volume growth” (WBJ, 2012a). This suggests 

that firms will, for the most part, be able to pass along increased costs to their consumers. While 

households faced with higher costs will have less income to spend on other goods and services, 

the large number of households served by any particular landfill suggests that any individual 

household will be only modestly impacted. 

As previously discussed in Chapter 2, the handling of MSW in the United States 

generated $55 billion of revenue in 2011, of which landfilling contributed $13 billion (WBJ, 

2012a). Of the $46.8 million of costs in 2025 for the proposed option, 15 percent are borne by 

the five largest firms in the industry, who together accounted for nearly $30 billion in revenue in 

2013 (see Table 2-3). An additional 79 percent of the costs are expected to be incurred by entities 

that are large by SBA standards. Small public entities are predicted to incur approximately six 

percent of the costs, while small private entities are predicted to incur less than one percent of the 

total cost. 

Because of the relatively low net cost of proposed option 2.5/34 compared to the overall 

size of the MSW industry, as well as 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. However, because of the relatively low incremental costs of the proposed option 2.5/34, 

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. 

5.3 Employment Impacts 

In addition to addressing the costs and benefits of the final rule, EPA has analyzed the 

impacts of this rulemaking on employment, which are presented in this section. While a 

standalone analysis of employment impacts is not included in a standard cost-benefit analysis, 

such an analysis is of particular concern in the current economic climate given continued interest 

Commented [A29]: OMB RIA Comment 26: Reviewer 

recommends that given the current unemployment rate of 5.3%, the 

compelling need for an extensive discussion on employment on 5.3 

isn’t clear. For the final rule, reviewer recommends abbreviating this 

discussion. 

EPA Response: Discussion will be revised for final rule. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

5-3 

in the employment impact of regulations such as this final rule. Executive Order 13563, states, 

“Our regulatory system must protect public health, welfare, safety, and our environment while 

promoting economic growth, innovation, competitiveness, and job creation.” 60 While 

disaggregated compliance costs are not available for the analyzed options, a brief discussion of 

the labor requirements associated with the installation, operation, and maintenance of control 

requirements, as well as reporting and recordkeeping requirements is included in Section 3.4, on 

engineering and administrative costs, of this RIA. However, due to data and methodology 

limitations, we have not quantified the rule’s effects on employment. What follows is an 

overview of the various ways that environmental regulation can affect employment. EPA 

continues to explore the relevant theoretical and empirical literature and to seek public comments 

in order to ensure that the way EPA characterizes the employment effects of its regulations is 

valid and informative.61

5.3.1 Background on the Regulated Industry 

This regulation is expected to affect domestic employment in the regulated sector – 

municipal solid waste landfills. Municipal solid waste (MSW) is the stream of garbage collected 

by sanitation services from homes, businesses, and institutions. 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. 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 (NMOC) 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 landfill. LFG can be collected and combusted in 

flares or energy recovery devices to reduce emissions. In this rulemaking EPA is proposing to 

lower the annual NMOC emissions threshold from 50 Mg/year to 34 Mg/year. Because of the 

 

60Executive Order 13563 (January 21, 2011). Improving Regulation and Regulatory Review. Section 1. General 

Principles of Regulation, Federal Register, Vol. 76, Nr. 14, p. 3821. 

61 The employment analysis in this RIA is part of EPA’s ongoing effort to “conduct continuing evaluations of 

potential loss or shifts of employment which may result from the administration or enforcement of [the Act]” 

pursuant to CAA section 321(a).
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5-4 

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

rule options on the supply and demand for MSW landfill services. However, because of the 

relatively low incremental costs of the proposed option, 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. 

As described in Chapter 2 of this RIA, EPA estimates the total amount of MSW 

generated in the United States in 2012 was approximately 251 million tons, a 20 percent increase 

from 1990. The number of active MSW landfills in the United States has decreased from 

approximately 7,900 in 1988 to approximately 1,800 in 2014 (EPA, 2010; WBJ, 2014). 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). 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, 2012a). 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). See Chapter 2, Table 2-3, for a 

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

MSW landfills and transfer stations. 

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

individuals. In 2014, 58 percent of active MSW landfills were owned by public entities while 

42 percent were privately owned (EPA, 2014). As older local public landfills approach their 

capacities, many communities are finding that the most economically viable solution to their 

waste disposal needs is shipping their waste to large 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, 2002). Waste transfer stations are facilities where MSW is unloaded from 

collection vehicles and reloaded into long-distance transport vehicles for delivery to regional 

landfills or other treatment/disposal facilities. By combining the loads of several waste collection 
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trucks into a single shipment, communities and waste management companies can reduce labor 

used and operating costs for 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, 2012b). 

The industry that collects, transfers, deposits and manages 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. For employment estimates related to publicly-owned landfills, solid waste 

management departments of local governments reported, in 2013, 95,674 full-time employees 

and 14,638 part-time employees (U.S. Census Bureau, 2013); however, statistics from the U.S. 

Census Bureau are not readily available solely for landfill-related aspects of these departments. 

An additional government source of employment data by detailed industry is the Bureau of 

Labor Statistics (BLS). The BLS Quarterly Census of Employment and Wages, which gathers 

employment data from state unemployment insurance programs, reports employment data for 

publicly-owned solid waste landfills (NAICS 562212) owned by local governments: in March 

2013, they report 22,586 employees (U.S. Bureau of Labor Statistics, 2013). For employment 

estimates related to private landfills, both the U.S. Census Bureau and the Bureau of Labor 

Statistics provide employment data. However, because these agencies use different methods to 

gather and classify employment data, their estimates indicate a range of employment within 

NAICS 562212, “solid waste landfills”.62 For March 2012, the most recent estimate from the 

U.S. Census Bureau’s County Business Patterns, the Census estimate is 18,208 employees at 

privately-owned solid waste landfills (U.S. Census Bureau, 2012). However, for privately-owned 

solid waste landfills, the BLS estimate for March 2012 is 37,628 employees (U.S. Bureau of 

Labor Statistics, 2012). When data series differ, it can be instructive to look at more aggregated 

industry categories, and in this case, more aggregated employment estimates are very similar 

 

62 BLS QCEW methodology for “industrial classification”: http://www.bls.gov/opub/hom/homch5_b.htm. Census 

methodology for “industry classification of establishments”: 

https://www.census.gov/econ/cbp/methodology.htm. 
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between Census and BLS at the 3-digit level NAICS, 562 Waste Management and Remediation 

Services. Based on observed within NAICS 562, the range in estimates at the 6-digit NAICS 

562212 may be driven by methodological differences in categorizing establishments by their 

“main economic activity”, which for this detailed industry, is likely a combination of waste 

treatment, waste disposal, and waste remediation and recovery services, and therefore difficult to 

classify by a single economic activity.63 

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 

due to recycling and other diversion activities (EPA, 2012c). 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 as the trend towards increased use of 

regional landfills and waste transfer stations continues. In addition, employment may be affected 

as landfills add technologies in response to the proposed regulation. Whether the technology 

added will capture and flare landfill gas, or capture and combust it for energy recovery, 

employment will be associated with these activities. 

5.3.2 Employment Impacts of Environmental Regulation 

From an economic perspective labor is an input into producing goods and services; if a 

regulation requires that more labor be used to produce a given amount of output, that additional 

labor is reflected in an increase in the cost of production. Moreover, when the economy is at full 

employment, we would not expect an environmental regulation to have an impact on overall 

employment because labor is being shifted from one sector to another. On the other hand, in 

periods of high unemployment, employment effects (both positive and negative) are possible. 

For example, an increase in labor demand due to regulation may result in a short-term net 

increase in overall employment as workers are hired by the regulated sector to help meet new 

requirements (e.g., to install new equipment) or by the environmental protection sector to 

 

63 2-, 3-, 4-, 5-, and 6-digit NAICS listings for NAICS 56 “Administrative and Support and Waste Management and 

Remediation Services” < http://www.census.gov/cgibin/sssd/naics/naicsrch?chart_code=56&search=2012%20NAICS%20Search>.
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5-7 

produce new abatement capital resulting in hiring previously unemployed workers . When 

significant numbers of workers are unemployed, the opportunity costs associated with displacing 

jobs in other sectors are likely to be smaller. And, in general, if a regulation imposes high costs 

and does not increase the demand for labor, it may lead to a decrease in employment. The 

responsiveness of industry labor demand depends on how these forces all interact. Economic 

theory indicates that the responsiveness of industry labor demand depends on a number of 

factors: price elasticity of demand for the product, substitutability of other factors of production, 

elasticity of supply of other factors of production, and labor’s share of total production costs. 

Berman and Bui (2001) put this theory in the context of environmental regulation, and suggest 

that, for example, if all firms in the industry are faced with the same compliance costs of 

regulation and product demand is inelastic, then industry output may not change much at all. 

Regulations set in motion new orders for pollution control equipment and services. New 

categories of employment have been created in the process of implementing environmental 

regulations. When a regulation is promulgated, one typical response of industry is to order 

pollution control equipment and services in order to comply with the regulation when it becomes 

effective. On the other hand, the closure of plants that choose not to comply – and any changes in 

production levels at plants choosing to comply and remain in operation - occur after the 

compliance date, or earlier in anticipation of the compliance obligation. Environmental 

regulation may increase revenue and employment in the environmental technology industry. 

While these increases represent gains for that industry, they translate into costs to the regulated 

industries required to install the equipment. 

Environmental regulations support employment in many basic industries. Regulated firms 

either hire workers to design and build pollution controls directly or purchase pollution control 

devices from a third party for installation. Once the equipment is installed, regulated firms hire 

workers to operate and maintain the pollution control equipment—much like they hire workers 

to produce more output. In addition to the increase in employment in the environmental 

protection industry (via increased orders for pollution control equipment), environmental 

regulations also support employment in industries that provide intermediate goods to the 

environmental protection industry. The equipment manufacturers, in turn, order steel, tanks, 

vessels, blowers, pumps, and chemicals to manufacture and install the equipment. Currently in 
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most cases there is no scientifically defensible way to generate sufficiently reliable estimates of 

the employment impacts in these intermediate goods sectors. 

It is sometimes claimed that new or more stringent environmental regulations raise 

production costs thereby reducing production which in turn must lead to lower employment. 

However, the peer-reviewed literature indicates that determining the direction of net employment 

effects in a regulated industry is challenging due to competing effects. Environmental regulations 

are assumed to raise production costs and thereby the cost of output, so we expect the “output” 

effect of environmental regulation to be negative (higher prices lead to lower sales). On the other 

hand, complying with the new or more stringent regulation requires additional inputs, including 

labor, and may alter the relative proportions of labor and capital used by regulated firms in their 

production processes. Two sets of researchers discussed here, Berman and Bui (2001) and 

Morgenstern, Pizer, and Shih (2002),64 demonstrate using standard neoclassical microeconomics 

that environmental regulations have an ambiguous effect on employment in the regulated sector. 

These theoretical results imply that the effect of environmental regulation on employment in the 

regulated sector is an empirical question and both sets of authors tested their models empirically 

using different methodologies. Both Berman and Bui and Morgenstern et al. examine the effect 

of environmental regulations on employment and both find that overall they had no significant 

net impact on employment in the sectors they examined. 

Berman and Bui (2001) developed an innovative approach to examine how an increase in 

local air quality regulation that reduces nitrogen oxides (NOX) emissions affects manufacturing 

employment in the South Coast Air Quality Management District (SCAQMD), which 

incorporates Los Angeles and its suburbs. During the time frame of their study, 1979 to 1992, the 

SCAQMD enacted some of the country’s most stringent air quality regulations. Using 

 

64 Berman, E. and L. T. M. Bui (2001). “Environmental Regulation and Labor Demand: Evidence from the South 

Coast Air Basin.” Journal of Public Economics 79(2): 265-295. Morgenstern, R. D., W. A. Pizer, and J. S. Shih. 

2002. Jobs versus the Environment: An Industry-Level Perspective. Journal of Environmental Economics and 

Management 43(3):412-436. 
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SCAQMD’s local air quality regulations, Berman and Bui identify the effect of environmental 

regulations on net employment in the regulated industries.65,66 The authors find that “while 

regulations do impose large costs, they have a limited effect on employment” (Berman and Bui, 

2001, p. 269). Their conclusion is that local air quality regulation “probably increased labor 

demand slightly” but that “the employment effects of both compliance and increased stringency 

are fairly precisely estimated zeros, even when exit and dissuaded entry effects are included” 

(Berman and Bui, 2001, p. 269).67

Morgenstern et al. (2002) estimated the effects of pollution abatement expenditures from 

1979 to 1991 at the plant level on net employment in four highly regulated sectors (pulp and 

paper, plastics, steel, and petroleum refining). Thus, in contrast to Berman and Bui (2001), this 

study identifies employment effects by examining differences in abatement expenditures rather 

than geographical differences in stringency. They conclude that increased abatement 

expenditures generally have not caused a significant change in net employment in those sectors. 

While the specific sectors Morgenstern et al. examined are different than the sectors considered 

here, the methodology that Morgenstern et al. developed is still an informative way to 

qualitatively, if not quantitatively, assess the effects of this rulemaking on employment at MSW 

landfills. For example, as firms add new technologies to capture landfill gases for flaring or for 

conversion to energy, there will be a demand for labor to install, monitor, and operate these new 

approaches to waste management and energy production. 

While there is an extensive empirical, peer-reviewed literature analyzing the effect of 

environmental regulations on various economic outcomes including productivity, investment, 

competitiveness as well as environmental performance, there are only a few papers that examine 

the impact of environmental regulation on employment, but this area of the literature has been 

growing. As stated previously in this RIA section, empirical results from Berman and Bui (2001) 

and Morgenstern et al (2002) suggest that new or more stringent environmental regulations do 

 

65 Note, like Morgenstern, Pizer, and Shih (2002), this study does not estimate the number of jobs created in the 

environmental protection sector. 

66 Berman and Bui include over 40 4-digit SIC industries in their sample. 

67 Including the employment effect of exiting plants and plants dissuaded from opening will increase the estimated 

impact of regulation on employment. 
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not have a substantial impact on net employment (either negative or positive) in the regulated 

sector. Similarly, Ferris, Shadbegian, and Wolverton (2014) also find that regulation-induced net 

employment impacts are close to zero in the regulated sector. Furthermore, Gray et al. (2014) 

find that pulp mills that had to comply with both the air and water regulations in EPA’s 1998 

“Cluster Rule” experienced relatively small and not always statistically significant, decreases in 

employment. Nevertheless, other empirical research suggests that more highly regulated 

counties may generate fewer jobs than less regulated ones (Greenstone 2002, Walker 2011). 

However, the methodology used in these two studies cannot estimate whether aggregate 

employment is lower or higher due to more stringent environmental regulation, it can only imply 

that relative employment growth in some sectors differs between more and less regulated areas. 

List et al. (2003) find some evidence that this type of geographic relocation, from more regulated 

areas to less regulated areas may be occurring. Overall, the peer-reviewed literature does not 

contain evidence that environmental regulation has a large impact on net employment (either 

negative or positive) in the long run across the whole economy. 

While the theoretical framework laid out by Berman and Bui (2001) and Morgenstern et 

al. (2002) still holds for the industries affected under these emission guidelines, important 

differences in the markets and regulatory settings analyzed in their study and the setting 

presented here lead us to conclude that it is inappropriate to utilize their quantitative estimates to 

estimate the employment impacts from this proposed regulation. In particular, the industries used 

in these two studies as well as the timeframe (late 1970’s to early 1990’s) are quite different than 

those in the proposed Emission Guidelines. Furthermore, the control strategies analyzed for this 

RIA include gas collection systems, destruction, and utilization, which are very different than the 

control strategies examined by Berman and Bui and Morgenstern et al.68 For these reasons we 

conclude there are too many uncertainties as to the transferability of the quantitative estimates in 

these two studies to apply their estimates to quantify the employment impacts within the 

regulated sectors for this regulation, though these studies have usefulness for qualitative 

assessment of employment impacts. 

 

68 More detail on how emission reductions expected from compliance with this rule can be obtained can be found in 

Chapter 3 of this RIA. 
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The preceding sections have outlined the challenges associated with estimating net 

employment effects in the regulated sector and in the environmental protection sector. These 

challenges make it very difficult to accurately produce net employment estimates for the whole 

economy that would appropriately capture the way in which costs, compliance spending, and 

environmental benefits propagate through the macro-economy. Quantitative estimates are further 

complicated by the fact that macroeconomic models often have very little sectoral detail and 

usually assume that the economy is at full employment. EPA’s Science Advisory Board (SAB) is 

currently in the process of seeking input from an independent expert panel on modeling 

economy-wide impacts, including employment effects. 

5.3.3 Conclusion 

Economic theory predicts that the total effect of an environmental regulation on labor 

demand in regulated sectors is not necessarily positive or negative. Peer-reviewed econometric 

studies that use a structural approach, applicable to in the regulated sectors, converge on the 

finding that such effects, whether positive or negative, have been small. 

Because of the lack of appropriate economic parameters or model, the EPA is unable to 

estimate the impacts of the regulatory options on the supply and demand for MSW landfill 

services. However, because of the relatively low incremental costs of the proposed option, 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. 

MSW landfill activities 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. 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 due to recycling or other waste diversion (EPA, 

2012c). 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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5-12 

Employment to design, construct and operate new technologies for managing landfill gases 

either through flaring or conversion to energy may also increase. 

5.4 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. 

For the purposes of assessing the impact of the proposed Emission Guidelines on small 

entities, a small entity is defined as: (1) A small business that is primarily engaged in the 

collections and disposal of refuse in a landfill operation as defined by NAICS code 562212 with 

annual receipts less than $38.5 million; (2) a small governmental jurisdiction that is a 

government of a city, county, town, school district, or school 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. 

After considering the economic impact of the proposed Emission Guidelines on small 

entities, the EPA certifies that the proposed regulation will not have a Significant Impact on a 

Substantial Number of Small Entities (SISNOSE). 

The proposed rule will not impose any requirements on small entities. Specifically, 

Emission Guidelines established under CAA section 111(d) do not impose any requirements on 

regulated entities and, thus, will not have a significant economic impact upon a substantial 

number of small entities. After Emission Guidelines are promulgated, states establish standards 

on existing sources and it is those state requirements that could potentially impact small entities. 

Our analysis here is consistent with the analysis of the analogous situation arising when the EPA 

establishes NAAQS, which do not impose any requirements on regulated entities. As here, any 

impact of a NAAQS on small entities would only arise when states take subsequent action to 

maintain and/or achieve the NAAQS through their state implementation plans. See American 
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Trucking Associations v. EPA, 175 F.3d 1029, 1043-45 (D.C. Cir. 1999) (NAAQS do not have 

significant impacts upon small entities because NAAQS themselves impose no regulations upon 

small entities). 

5.5 References 

Bel, Germà and Raymond Gradus. 2014. “Effects of Unit-based Pricing on the Waste Collection 

Demand: a Meta-regression Analysis.” Working Paper 2014/20. Research Institute of 

Applied Economics. <http://www.ub.edu/irea/working_papers/2014/201420.pdf>. 

Berman, E. and L. T. M. Bui. 2001. “Environmental Regulation and Labor Demand: Evidence 

from the South Coast Air Basin.” Journal of Public Economics 79(2): 265-295, docket nr. 

EPA-HQ-OAR-2011-0135 at http://www.regulations.gov. 

Bloomberg Businessweek. 2014RSG. 2013 SEC Filings - Republic Services Inc (RSG). 10-K, 

Annual Financials, February 13, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=RSG

>. 

Bloomberg Businessweek. 2014WM. 2013 SEC Filings - Waste Management Inc (WM). 10-K, 

Annual Financials, February 18, 2014. 

<http://investing.businessweek.com/research/stocks/financials/secfilings.asp?ticker=WM

>. 

Ferris, Ann, Ronald J. Shadbegian, and Ann Wolverton. 2014. “The Effect of Environmental 

Regulation on Power Sector Employment: Phase I of the Title IV SO2 Trading Program.” 

Journal of the Association of Environmental and Resource Economists 5, 173-193. 

Gray, Wayne B., Ronald J. Shadbegian, Chunbei Wang, and Merve Meral. 2014. “Do EPA 

Regulations Affect Labor Demand? Evidence from the Pulp and Paper Industry.” Journal 

of Environmental Economics and Management: 68, 188-202. 

Greenstone, M. 2002. “The Impacts of Environmental Regulations on Industrial Activity: 

Evidence from the 1970 and 1977 Clean Air Act Amendments and the Census of 

Manufactures.” Journal of Political Economy 110(6): 1175-1219. 

Kinnaman, Thomas C. 2006. “Examining the Justification for Residential Recycling.” Journal of 

Economic Perspectives 20(4): 219-232. 

List, J. A., D. L. Millimet, P. G. Fredriksson, and W. W. McHone. 2003. “Effects of 

Environmental Regulations on Manufacturing Plant Births: Evidence from a Propensity 

Score Matching Estimator.” The Review of Economics and Statistics 85(4): 944-952. 
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5-14 

Morgenstern, Richard D., William A. Pizer, and Jhih-Shyang Shih. 2002. “Jobs Versus the 

Environment: An Industry-Level Perspective.” Journal of Environmental Economics and 

Management 43: 412-436, docket nr. EPA-HQOAR-2011-0135-0057 at 

http://www.regulations.gov. 

U.S. Bureau of Labor Statistics. 2012. Quarterly Census of Employment and Wages. Private, 

NAICS 562212 Solid waste landfill, All States and U.S. 2012 First Quarter, All 

establishment sizes < 

http://www.bls.gov/cew/apps/table_maker/v3/table_maker.htm#type=0&year=2012&qtr

=1&own=5&ind=562&supp=1>. 

U.S. Bureau of Labor Statistics. 2013. Quarterly Census of Employment and Wages. Local 

Government, NAICS 562212 Solid waste landfill, All States and U.S. 2013 First Quarter, 

All establishment sizes < 

http://www.bls.gov/cew/apps/table_maker/v3/table_maker.htm#type=0&year=2013&qtr

=1&own=3&ind=562212&supp=1>. 

U.S. Census Bureau (Census). 2012. County Business Patterns. Solid Waste Landfill (NAICS 

562212). < 

http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=BP_201

2_00A1&prodType=table>. 

U.S. Census Bureau (Census). 2013. Annual Survey of Public Employment & Payroll. Local 

Government Employment and Payroll Data. March 2013. 

<http://www.census.gov/govs/apes/>. 

U.S. Environmental Protection Agency (EPA). 2002. Solid Waste and Emergency Response. 

“Waste Transfer Stations: A Manual for Decision-Making.” June 2002. EPA-530-R-02-

002. <http://www.epa.gov/waste/nonhaz/municipal/pubs/r02002.pdf>. 

U.S. Environmental Protection Agency (EPA). 2010. “Municipal Solid Waste in the United 

States: 2009 Facts and Figures.” December 2010. EPA-530-R-10-012. Washington, DC: 

U.S EPA. <http://www.epa.gov/waste/nonhaz/municipal/pubs/msw2009rpt.pdf>. 

Accessed January 6, 2015. 

U.S. Environmental Protection Agency (EPA). 2012a. Office of Solid Waste and Emergency 

Response (OSWER), Office of Resource Conservation and Recovery (ORCR). Web 

page: Municipal Solid Waste Landfills. 

<http://www.epa.gov/osw/nonhaz/municipal/landfill.htm>. Accessed December 4, 2012. 

U.S. Environmental Protection Agency (EPA). 2012b. OSWER, ORCR. Web page: MSW 

Landfill Criteria Technical Manual. 

<http://www.epa.gov/osw/nonhaz/municipal/landfill/techman/>. Accessed December 4, 

2012. 

U.S. Environmental Protection Agency (EPA). 2012c. Landfill Methane Outreach Program 

(LMOP), Climate Change Division, U.S. EPA. Web page: Frequent Questions: Landfill 

Gas. <http://www.epa.gov/lmop/faq/landfill-gas.html>. Accessed December 3, 2012. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

5-15 

U.S. Environmental Protection Agency (EPA). 2014. “Landfill-level data only (all landfills) – 

updated August 2014.” LMOP, Climate Change Division, U.S. EPA. 

<http://www.epa.gov/lmop/projects-candidates/index.html>. 

Walker, Reed. 2011. “Environmental Regulation and Labor Reallocation.” American Economic 

Review: Papers and Proceedings, 101(2). 

Waste Business Journal (WBJ). 2012a. “Waste Market Overview & Outlook 2012.” 

<http://www.wastebusinessjournal.com/overview.htm>. Accessed January 16, 2015. 

WBJ. 2014. “Directory of Waste Processing and Disposal Sites 2014.” 

<http://www.wastebusinessjournal.com/diratlas.htm>. Accessed January 6, 2015. 
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6-1 

6 COMPARISON OF BENEFITS AND COST 

6.1 Introduction 

The EPA compared the monetized methane-related climate benefits and CO2 co-benefits of 

the proposed Emission Guidelines for existing landfills against the estimated annualized compliance 

costs and found that the benefits of the proposed rule outweigh the costs. The net benefits are likely 

larger since the EPA was not able to monetize the benefits from reducing exposure to 2,770 Mg/yr 

of NMOC. The NMOC portion of LFG can contain a variety of air pollutants, including VOC 

and various organic HAP, and these pollutants are associated with health and welfare effects 

described in Chapter 4.

6.2 Net Benefits of the Proposed Standards 

For the proposed 2.5/34 option, the monetized methane-related climate benefits are 

estimated to range from $310 million to $1.7 billion (2012$)69 in 2025; these benefits are 

estimated to be $660 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $3.6 million to $36 million (2012$)70 in 2025; estimated CO2 benefits 

are $12 million (2012$) in 2025 using a 3% discount rate. Under the proposed option 2.5/34, 

when using a 7% discount rate the additional cost in 2025 would be $47 million. Using a 3% 

discount rate, the additional cost over the baseline in 2025 would be $35 million. Thus, the net 

benefits, using a 7% discount rate, are expected to be $260 million to $1.7 billion, with a central 

estimate of $620 million. These results are summarized in Table 6-1. 

 

 

69 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

70 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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6-2 

Table 6-1 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

Emission Guidelines Option 2.5/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $310 million - $1.7 billion 

Monetized CO2 co-benefits1 $3.6 million - $36 million 

Total Costs2 $35 million $47 million 

Net Benefits $270 million - $1.7 billion $260 million - $1.7 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 2,770 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 2,770 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 436,100 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 238,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

6.3 Net Benefits of the Alternate Standards 

For the less stringent 2.5/40 option, the monetized methane-related climate benefits are 

estimated to range from $190 million to $1.1 billion (2012$)71 in 2025; these benefits are 

estimated to be $410 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $1.5 million to $15 million (2012$)72 in 2025; estimated CO2 benefits 

are $5.0 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% 

 

71 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

72 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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6-3 

discount rate the additional cost in 2025 would be $27 million. Using a 3% discount rate, the 

additional cost over the baseline in 2025 would be $20 million. Thus, the net benefits, when 

using a 7% discount rate, would be expected to be $160 million to $1.1 billion, with a central 

estimate of $390 million. These results are summarized in Table 6-2. 

Table 6-2 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative 

Emission Guidelines Option 2.5/40 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $190 million - $1.1 billion 

Monetized CO2 co-benefits1 $1.5 million - $15 million 

Total Costs2 $20 million $27 million 

Net Benefits $170 million - $1.1 billion $160 million - $1.1 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 1,720 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 1,720 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 270,700 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 102,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

For the more stringent 2.0/34 option, the monetized methane-related climate benefits are 

estimated to range from $340 million to $1.9 billion (2012$)73 in 2025; these benefits are 

 

73 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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6-4 

estimated to be $720 million (2012$) in 2025 using a 3% discount rate. The CO2 co-benefits are 

estimated to range from $3.6 million to $36 million (2012$)74 in 2025; estimated CO2 benefits 

are $12 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% 

discount rate the additional cost in 2025 would be $51 million. Using a 3% discount rate, the 

additional cost over the baseline in 2025 would be $38 million. Thus, the net benefits, when 

using a 7% discount rate, would be expected to be $290 million to $1.9 billion, with a central 

estimate of $690 million. These results are summarized in Table 6-3.

Table 6-3 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative 

Emission Guidelines Option 2.0/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $340 million - $1.9 billion 

Monetized CO2 co-benefits1 $3.6 million - $36 million 

Total Costs2 $38 million $51 million 

Net Benefits $300 million - $1.9 billion $290 million - $1.9 billion 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 3,040 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 3,040 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 479,100 

Mg/yr methane, valued using the social cost of methane, and the net reduction of 238,000 Mg/yr of 

CO2, valued using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SCCO2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

 

74 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7-1 

7 SUPPLEMENTAL NSPS PROPOSAL 

7.1 Introduction 

On July 17, 2014, the EPA proposed a new NSPS subpart resulting from its ongoing 

review of the landfills NSPS (79 FR 41796). The proposed new subpart retained the same design 

capacity size threshold of 2.5 million m3 or 2.5 million Mg, but presented several options for 

revising the NMOC emission rate at which a MSW landfill must install controls. Since 

presenting these options, the EPA has updated its model that estimates the emission reduction 

and cost impacts based on public comments and new data. 

At proposal, the EPA estimated the emission reductions and costs associated with 17 new 

“greenfield” landfills that the EPA projected to commence construction, reconstruction, or 

modification between 2014 and 2018 and have a design capacity of 2.5 million m3 and 2.5 

million Mg. The basis of the projected number of new landfills and associated emission 

reductions is presented in the landfills NSPS docket EPA-HQ-OAR-2003-0215. Multiple 

commenters on the landfills NSPS proposal stated that the EPA underestimated the cost impacts 

of the landfills NSPS because the EPA failed to consider the number of landfills that are 

expected to undergo a modification, and thus become subject to the proposed NSPS. In response 

to these comments, the EPA consulted with its Regional Offices, as well as state and local 

authorities, to identify landfills expected to undergo a modification within the next 5 years. 

Based on this information, the EPA estimated the number of existing landfills likely to modify 

after July 17, 2014 and become subject to subpart XXX. In addition, the EPA has made several 

changes to its underlying dataset and methodology used to analyze the impacts of potential 

control options, as discussed in Chapter 3 of this RIA. Using the revised dataset, the EPA re-ran 

the model and control options similar to the options presented in the proposed NSPS. As a result 

of these changes, the number and characteristics of the model new landfills and modified 

landfills that are expected to become subject to proposed subpart XXX have changed. The 

revised number of affected landfills, as well as revised estimates of the costs and benefits of the 

previously proposed and newly proposed option, are discussed below. 
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7-2 

7.2 Regulatory Baseline and Options 

The July 2014 proposed new subpart to the NSPS for MSW landfills analyzed options 

slightly different from those analyzed for the current proposed revisions to the emissions 

guidelines. The options analyzed in that Economic Impact Analysis were: 

• Baseline: design capacity retained at 2.5 Mg, emission threshold retained at 50 Mg 

NMOC/year

• Alternative Option 3.0/40: design capacity increased to 3.0 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/40: design capacity retained at 2.5 Mg, emission threshold reduced 

to 40 NMOC Mg/yr 

• Alternative Option 2.0/40: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 40 Mg NMOC/year. 

Consistent with the Methane Strategy that was developed as part of the President’s Climate 

Action Plan, when preparing this supplemental NSPS proposal the EPA considered more 

stringent control options that may achieve additional reductions of methane and NMOC for new 

landfills. As a result of the revised analysis, the EPA is proposing no changes to the design 

capacity threshold for new sources, but is proposing to lower the NMOC emission rate threshold 

to 34 Mg/yr for new and modified sources subject to subpart XXX. In addition to responding to 

feedback received during the NSPS proposal comment period, the EPA believes consistency 

between the thresholds in the emission guidelines and the NSPS is important, given that an 

existing landfill can modify and become subject to the proposed subpart XXX by commencing 

construction on an increase in design capacity. Commenters on the July 17, 2014 notices 

weighed in on consistency between the NSPS and emission guidelines. An environmental 

organization recommended adopting consistent applicability standards, such as design capacity 

and NMOC emission thresholds, between subpart XXX for new landfills and subpart Cf for 

existing landfills to maximize beneficial environmental impacts for existing landfills, which are 

more numerous than anticipated new landfills, and to prevent creating incentives for existing 

landfills subject to modification by allowing them to comply with less rigorous requirements. In 
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7-3 

addition, two regulatory agencies requested harmonizing requirements for existing and new 

landfills between the current regulations in subpart WWW and the new proposed subpart XXX. 

As a result, the options analyzed for this supplemental NSPS proposal for new or 

modified MSW landfills match the options analyzed for the proposed revisions to the emissions 

guidelines for existing MSW landfills, and are: 

• Baseline: design capacity retained at 2.5 Mg, emission threshold retained at 50 Mg 

NMOC/year

• Alternative Option 2.5/40: design capacity retained at 2.5 Mg, emission threshold 

reduced to 40 NMOC Mg/yr

• Proposed Option 2.5/34: design capacity retained at 2.5 Mg, emission threshold reduced 

to 34 NMOC Mg/yr 

• Alternative Option 2.0/34: design capacity reduced to 2.0 Mg, emission threshold 

reduced to 34 Mg NMOC/year 

The baseline and alternative option 2.5/40 correspond to options analyzed in the previous 

NSPS proposal, and can be directly compared to the results in that economic impact analysis to 

better understand the effects of the change in the number of landfills predicted to be affected by 

the NSPS.75 The baseline reflects the parameters of the current NSPS. Specifically, all reported 

results are incremental to the current NSPS (2.5/50) and not the proposed option (2.5/40) from 

the July 2014 proposed new subpart to the NSPS for MSW landfills. In the baseline, the NSPS 

affects 140 landfills, with 28 landfills reporting but not controlling emissions and 112 landfills 

reporting and controlling emissions in 2025. The EPA is assessing impacts in year 2025 as a 

representative year for the both the landfills Emission Guidelines and NSPS. While the analysis 

focuses on impacts in 2025, results for alternative years are also presented in Section 7.8.

 

75 U.S. Environmental Protection Agency (EPA). 2014. “Economic Impact Analysis for the Proposed New 

Subpart to the New Source Performance Standards.” June 2014. Available at < 

http://www.epa.gov/ttn/ecas/regdata/EIAs/LandfillsNSPSProposalEIA.pdf>. 
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Table 7-1 Number of Affected Landfills in 2025 under the Baseline and Alternative 

Options 

 Affected Landfills (no.) 

Landfills 

Affected 

Landfills 

Reporting but 

Not Controlling 

Emissions 

Landfills 

Reporting and 

 Controlling 

Emissions 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 140 28 112 

Incremental values versus the current NSPS

Alternative option 2.5/40 0 -11 11 

Proposed option 2.5/34 0 -15 15 

Alternative option 2.0/34 7 -12 19 

Based on the characteristics of the projected landfills, the proposed option presented in 

Table 7-1Table 7-1 would require 15 additional landfills to install controls by 2025. The less 

stringent alternative option 2.5/40 (which corresponds to the proposed option in the July 2014 

NSPS proposal) would require 11 additional landfills to install controls by 2025, while the more 

stringent alternative option 2.0/34 would affect 22 additional landfills, with some being required 

only to report and others being required to control. In that option, 19 additional landfills are 

required to install controls by 2025. 

Under the proposed option 2.5/34, the emission reductions would be an additional 300 Mg 

NMOC and 51,400 Mg methane (1,300,000 Mg CO2 Eq.) compared to the baseline in 2025. The 

less stringent alternative option 2.5/40 would yield emissions reductions of 300 Mg NMOC and 

44,400 Mg methane (1,100,000 Mg CO2 Eq.) compared to the baseline, while the more stringent 

alternative option 2.0/34 would result in emissions reductions of 400 Mg NMOC and 62,500 Mg 

methane (1,600,000 Mg CO2 Eq.) compared to the baseline. The emission reductions are 

summarized in Table 7-2Table 7-2. 
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7-5 

Table 7-2 Estimated Annual Average Emissions Reductions in 2025 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 11,600 1,834,000 45,900,000 

Incremental values versus the current NSPS 

Alternative option 2.5/40 300 44,400 1,100,000 

Proposed option 2.5/34 300 51,400 1,300,000 

Alternative option 2.0/34 400 62,500 1,600,000 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Minor secondary air impacts 

are not included in this table. See Section 7.3 for details. 

Costs for the NSPS were estimated in the same manner as the costs for the emissions guidelines. 

This methodology is discussed in Chapter 3. Under the proposed option 2.5/34, when using a 7% 

discount rate the additional cost of control in 2025 would is estimated to be $9.0 million, of 

which approximately $0.6 million is estimated to be offset by increased revenue from beneficialuse projects, so the net cost is estimated to be approximately $8.5 million (
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7-6 

Table 7-3Table 7-3). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $6.6 million, which is estimated to be supplemented by approximately 

$0.65 million in reduced revenue from beneficial-use projects, so the net cost is estimated to be 

approximately $7.4 million., while the The cost of control for the more stringent alternative 

option 2.0/34 would is estimated to be $10.7 million, of which approximately $0.6 million is 

estimated to be offset by increased revenue from beneficial-use projects, so the net cost is 

estimated to be approximately $10.2 million. These options represent approximately between 12 

to 16 percent in additional net costs beyond the baseline, with the proposed option 2.5/34 

resulting in a 14 percent increase in net costs beyond the baseline for the industry as a whole. 
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Table 7-3 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (7% Discount Rate) 

 Estimated Annualized Net Cost (Millions $2012) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 1.3 322 262 61 

Incremental values versus the current NSPS 

Alternative option 2.5/40 0.06 6.6 -0.65 7.4 

Proposed option 2.5/34 0.08 9.0 0.60 8.5 

Alternative option 2.0/34 0.11 10.7 0.60 10.2 

Note: All total are independently rounded and may not sum. 

When using a 3% discount rate, the model predicts a different timing in the investment behavior 

by the landfills, which affects both the costs and revenue that are predicted in 2025. Under the 

proposed option 2.5/34, the additional cost of control over the baseline in 2025 would is 

estimated to be $12.6 million, of which $5.5 is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to be $7.1 million (
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Table 7-4Table 7-4). The cost of control for the less stringent alternative option 2.5/40 

would is estimated to be $8.0 million, of which $1.6 million is estimated to be offset by 

increased revenue from beneficial-use projects, so the net cost is estimated to be $6.4 million., 

while the The cost of control for the more stringent alternative option 2.0/34 is estimated to be 

$14.9 million, of which $6.3 million is estimated to be offset by increased revenue from 

beneficial-use projects, so the net cost is estimated to would be $8.6 million. These options 

represent approximately between 28 to 38 percent in additional net costs beyond the baseline, 

with the proposed option 2.5/34 resulting in a 31 percent increase in net costs beyond the 

baseline for the industry as a whole. However, it is important to note that the baseline value 

when using a 3% discount rate is less than 40 percent of the cost when using a 7% discount rate, 

because the increased costs of earlier installation of GCCS and engines are offset by increased 

revenue from energy generation. 
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Table 7-4 Estimated Engineering Compliance Costs in 2025 for Baseline and Alternative 

Options (3% Discount Rate) 

 Estimated Annualized Net Cost (Millions $2012) 

Testing and 

Monitoring 

Costs Control Costs 

Revenue from 

Beneficial-use

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 1.2 404 382 22 

Incremental values versus the current NSPS 

Alternative option 2.5/40 0.06 8 1.6 6.4 

Proposed option 2.5/34 0.07 12.6 5.5 7.1 

Alternative option 2.0/34 0.10 14.9 6.3 8.6 

Note: All total are independently rounded and may not sum. 

In terms of cost effectiveness, when considering the estimated net cost of the options, the 

overall average cost effectiveness for NMOC reductions is $5,271 per Mg NMOC under the 

baseline and roughly $26,000 per Mg NMOC under the proposed option 2.5/34 and the 

alternative options 2.5/40 and 2.0/34 (Table 7-5Table 7-5). 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 overall average cost effectiveness for methane reductions is roughly $33 per Mg 

methane under the baseline and approximately $160 per Mg methane under the proposed option 

2.5/34 and the alternative options 2.5/40 and 2.0/34.

When estimating cost effectiveness excluding the estimated revenue from beneficial-use 

projects, the overall average cost effectiveness for NMOC reductions is $27,800 per Mg NMOC 

under the baseline and roughly $27,000 to $28,000 per Mg NMOC under the proposed option 

2.5/34 and alternative option 2.0/34, and roughly $24,000 per Mg NMOC under the alternative 

option 2.5/40 (Table 3-5Table 3-5). 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 overall average cost 

effectiveness for methane reductions is $176 per Mg methane under the baseline and 
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7-10 

approximately $150 - $175 per Mg methane under the proposed option 2.5/34 and the alternative 

options 2.5/40 and 2.0/34.

Table 7-5 Estimated Cost-effectiveness in 2025 for the Baseline and Alternative Options 

(7% Discount Rate) 

Cost-effectiveness (2012$ per Mg)

NMOC Methane 

Methane 

(in CO2-

equivalents)* 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

Net 

Costb 

/ton

Total 

Cost

/ton 

 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 5,271 27,800 33.5 176 1.3 7.10

 

Incremental values versus the current EG 

Alternative option 2.5/40 26,100 23,800 166 151 6.6 6.0 

Proposed option 2.5/34 26,100 27,900 165 177 6.6 7.1 

Alternative option 2.0/34 25,600 27,100 163 172 6.5 6.9 

Note: The cost-effectiveness of NMOC and methane are estimated as if all of the control cost were attributed to each 

pollutant separately. 

a A global warming potential of 25 is used to convert methane to CO2-equivalents. The secondary CO2 emission 

reductions are not reflected in these estimates. 

b Net Cost is the total control and testing and monitoring cost minus any project revenue. The control costs for 

landfills with energy projects includes costs to install and operate a reciprocating engine (and associated electrical 

equipment), which is more expensive than a standard flare. Reciprocating engines are not required by the regulation 

but are expected to be used as control devices when it is cost-effective to recovery the LFG energy.

 

7.3 Benefits 

The proposed subpart to the NSPS is expected to result in significant emissions 

reductions of landfill gas (LFG) from existing new or modified MSW landfills. As in the case of 

the proposed emissions guidelines, there will be climate benefits and HAP, ozone and PM2.5 

health “co-benefits”. These co-benefits occur because the control techniques to meet the 

standards simultaneously reduce methane, VOC, and HAP emissions. By lowering the current 

NMOC emissions threshold of 50 Mg/yr to 34 Mg/yr, the proposal is anticipated to achieve 

reductions of 300 Mg/yr NMOC and 51,400 Mg/yr methane in 2025. The NMOC portion of 

LFG can contain a variety of air pollutants, including VOC and various organic HAP. VOC 
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emissions are precursors to both fine particulate matter (PM2.5) and ozone formation, while 

methane is a GHG and a precursor to global ozone formation. As described in detail in Chapter 

4, these pollutants are associated with substantial health effects, climate effects, and other 

welfare effects. As with the proposed emissions guidelines, the only categories of benefits 

monetized for the proposed NSPS are methane-related and CO2-related climate effects. While 

the methane-related climate effects are positive as with the proposed emissions guidelines, for 

the proposed NSPS there are small CO2 disbenefits associated with increased electricity demand 

due to the energy demands of the GCCS exceeding the increased generation of electricity by 

landfills through the burning of LFG in engines. 

While we expect that these avoided emissions will also result in improvements in air 

quality and reduce health and welfare effects associated with exposure to HAP, ozone, and fine 

particulate matter (PM2.5), we have determined that quantification of those health benefits cannot 

be accomplished for this rule in a defensible way. This is not to imply that these benefits do not 

exist; rather, it is a reflection of the difficulties in modeling the direct and indirect impacts of the 

reductions in emissions for this industrial sector with the data currently available. 

The methodology used to calculate methane climate benefits is discussed in detail in Section 4.2 

of this RIA. Applying the approach discussed in that section to the CH4 reductions estimated for 

this proposal, the 2025 methane benefits vary by discount rate and range from about $36 million 

to approximately $210 million; for the proposed option, the mean SC-CH4 at the 3% discount 

rate results in an estimate of about $78 million in 2025. These benefits are presented below in 
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Table 7-6Table 7-6. 
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Table 7-6 Estimated Global Benefits of CH4 Reductions in 2025* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.044 1.1 $32 $67 $86 $180 

Proposed Option 2.5/34 0.051 1.3 $36 $78 $100 $210 

Alternative Option 2.0/34 0.063 1.6 $44 $95 $120 $250 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

However, there are climate-related disbenefits that are expected from the proposal’s 

secondary air impacts, specifically, a net increase in CO2 emissions. These disbenefits arise 

because more energy is required to operate the GCCS at some landfills than is produced by these 

landfills through the burning of LFG in engines.76 These disbenefits are presented in Table 7-7 

below. Monetizing the net CO2 increases with the SC-CO2 estimates also described in Section 

4.2 yields disbenefits that vary by discount rate and range from about $0.01 million to 

approximately $0.10 million in 2025. For the proposed option, the mean SC-CO2 at the 3% 

discount rate results in an estimate of about $0.03 million in 2025. 

Table 7-7 Estimated Global Disbenefits of Net CO2 Increases in 2025* (in millions, 2012$) 

Metric tonnes of net 

CO2 increased 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 11,000 $0.17 $0.55 $0.81 $1.6 

Proposed Option 2.5/34 670 $0.010 $0.033 $0.049 $0.10 

Alternative Option 2.0/34 2,000 $0.030 $0.10 $0.14 $0.29 

*The SC-CO2 values are dollar-year and emissions-year specific. SC-CO2 values represent only a partial 

accounting of climate impacts. 

 

76 As in the case of the proposed Emissions Guidelines, there is an additional CO2 impact, specifically a small 

increase in CO2 emissions resulting from flaring of methane in response to this rule. We are not estimating the 

monetized disbenefits of these secondary emissions of CO2 because much of the methane that would have been 

released in the absence of the flare would have eventually oxidized into CO2 in the atmosphere. See Section 4.2.1 

for more discussion.
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7.4 Economic Impacts 

7.4.1 Economic Impact Analysis 

As was discussed in Section 5.2, assessing the economic impacts of the costs of the 

proposed option is difficult due to the nature of the MSW industry. The cost of the current 

proposal is estimated to be $8.5 million in 2025. Because of the relatively low net cost of 

proposed option 2.5/34 compared to the overall size of the MSW industry as was discussed in 

Chapter 2 and Section 5.2, as well as 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. However, because of the relatively low incremental costs of the proposed option 2.5/34, 

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. 

7.4.2 Employment Impacts 

As is the case with the proposed emissions guidelines, the EPA is unable to quantify the 

effect of the proposed NSPS on employment. However, a discussion of the potential impacts on 

employment appears in Section 5.3, and is relevant for the proposed NSPS as well as the 

proposed emissions guidelines. 

7.4.3 Small Business Impacts Analysis 

As discussed in Section 5.4, 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. 
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It was determined that the July 2014 proposed NSPS subpart would not have a significant 

economic impact on a substantial number of small entities. Given the changes in the number of 

landfills anticipated to become subject to the new proposed NSPS, the potential impact on small 

entities has been reanalyzed. 

For the purposes of assessing the impact of the proposed NSPS on small entities, a small 

entity is defined as: (1) A small business that is primarily engaged in the collections and disposal 

of refuse in a landfill operation as defined by NAICS code 562212 with annual receipts less than 

$38.5 million; (2) a small governmental jurisdiction that is a government of a city, county, town, 

school district, or school 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 EPA typically assessed how the regulatory program may potentially impact owners 

(ultimate parent companies, governmental jurisdictions, or not-for-profit enterprises) by 

comparing pollution control costs to total sales or revenue. This is referred to as a “sales” test or 

cost-to-sales ratio. To perform this test, the total annualized control cost for a small entity (i) is 

divided by its reported revenue: 

		 =

	

	
		

	
	

The “sales test” is the impact metric 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 

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 SBREFA77 and is 

consistent with guidance published by the U.S. SBA’s Office of Advocacy that suggests that cost 

 

77 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> 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-16 

as a percentage of total revenues is a metric for evaluating cost increases on small entities in 

relation to increases on large entities.78 The results of the screening analysis appear below in 

Table 7-8. 

Table 7-8 Small Business Impact Screening Assessment Results (Reporters and 

Controllers) 

2.5 million Mg; 

Reduce to 40 Mg/yr 

NMOC 

2.5 million Mg; 

Reduce to 34 Mg/yr 

NMOC 

2.0 million Mg; 

Reduce to 34 Mg/yr 

NMOC 

 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

Count from 

Screen 

Based on 

Total Cost 

Count from 

Screen 

Based on 

Net Cost 

No. Affected 13 13 13 13 14 14 

No. Affected with Sales Data 11 11 11 11 12 12 

No. Affected > 1% (n) 0 0 2 2 2 2 

No. Affected > 3% (n) 0 0 1 1 1 1 

No. Affected > 1% (%) 0.0% 0.0% 18.2% 18.2% 16.7% 16.7% 

No. Affected > 3% (%) 0.0% 0.0% 9.1% 9.1% 8.3% 8.3% 

After considering the economic impact of the proposed NSPS on small entities, the 

analysis indicates that this rule will not have a significant impact on a substantial number of 

small entities (SISNOSE). First, the proposed revision does not impact a substantial number of 

small entities, since only 13 small entities are projected to be impacted by the proposed option. 

Additionally, the impact to these entities are not significant, because only 2 entities have impacts 

greater than 1 percent of sales, and only 1 of these 2 entities has impacts greater than 3 percent of 

sales.

7.5 Comparison of Benefits and Costs 

The EPA compared the monetized methane-related climate benefits and CO2 co-benefits 

of the proposed NSPS for new or modified MSW landfills against the estimated annualized costs

 

78U.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. 

Commented [A30]: OMB RIA Comment 15: Reviewer notes 

that the basis for no SISNOSE finding isn’t stated and requests the 

analysis to support this conclusion. 

EPA Response: Justification has now been added to this section and 

section 8.3. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-17 

and found that the benefits of the proposed rule outweigh the costs. The net benefits are likely 

larger since the EPA was not able to monetize the benefits from reducing exposure to 300 Mg/yr 

of NMOC. The NMOC portion of LFG can contain a variety of air pollutants, including VOC 

and various organic HAP, and these pollutants are associated with health and welfare effects 

described in Chapter 4. 

7.6 Net Benefits of the Proposed Standards 

For the proposed 2.5/34 option, the monetized methane-related climate benefits are 

estimated to range from $36 million to $210 million (2012$)79 in 2025; these benefits are 

estimated to be $78 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are 

estimated to range from $0.01 million to $0.10 million (2012$)80 in 2025; estimated CO2

disbenefits are $0.033 million (2012$) in 2025 using a 3% discount rate. Under the proposed 

option 2.5/34, when using a 7% discount rate the additional cost in 2025 would be $8.5 million. 

Using a 3% discount rate, the additional cost over the baseline in 2025 would be $7.1 million. 

Thus, the net benefits in 2025, when using a 7% discount rate, are expected to be $28 million to 

$200 million, with a central estimate of $69 million. These results are summarized in Table 7-9. 

Table 7-9 Summary of the Monetized Benefits, Costs, and Net Benefits for the Proposed 

NSPS Option 2.5/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $36 million - $210 million 

Monetized CO2 disbenefits1 $0.010 million - $0.10 million 

Total Costs2 $7.1 million $8.5 million 

Net Benefits $29 million - $200 million $28 million - $200 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 

79 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

80 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-18 

Visibility impairment 

Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 51,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 665 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

7.7 Net Benefits of the Alternate Standards 

For the less stringent 2.5/40 option, the monetized methane-related climate benefits are estimated 

to range from $31 million to $180 million (2012$)81 in 2025; these benefits are estimated to be 

$67 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are estimated to 

range from $0.17 million to $1.6 million (2012$)82 in 2025; estimated CO2 disbenefits are $0.55 

million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% discount 

rate the additional cost in 2025 would be $7.4 million. Using a 3% discount rate, the additional 

cost over the baseline in 2025 would be $6.4 million. Thus, the net benefits, when using a 7% 

discount rate, would be expected to be $23 million to $170 million in 2025, with a primary 

estimate of $59 million. These results are summarized in 

 

81 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

82 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
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7-19 

Table 7-10Table 7-10. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-20 

Table 7-10 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Alternative NSPS Option 2.5/40 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $31 million - $180 million 

Monetized CO2 disbenefits1 $0.17 million - $1.60 million 

Total Costs2 $6.4 million $7.4 million 

Net Benefits $24 million - $170 million $23 million - $170 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 300 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 300 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 44,400 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 11,000 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

For the more stringent 2.0/34 option, the monetized methane-related climate benefits are 

estimated to range from $44 million to $250 million (2012$)83 in 2025; these benefits are 

estimated to be $95 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are 

estimated to range from $0.03 million to $0.29 million (2012$)84 in 2025; estimated CO2

disbenefits are $0.10 million (2012$) in 2025 using a 3% discount rate. Under this option, when 

using a 7% discount rate the additional cost in 2025 would be $10 million. Using a 3% discount 

rate, the additional cost over the baseline in 2025 would be $8.6 million. Thus, the net benefits, 

 

83 The range of estimates reflects four SC-CH4 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 

84 The range of estimates reflects four SC-CO2 estimates: the mean across all models and scenarios using a 2.5 

percent, 3 percent, and 5 percent discount rate, and the 95th percentile of the pooled estimates from all models 

and scenarios using a 3% discount rate. See Section 4.2 for a complete discussion. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-21 

when using a 7% discount rate, would be expected to be $34 million to $240 million in 2025, 

with a primary estimate of $85 million. These results are summarized in Table 7-11. 

Table 7-11 Summary of the Monetized Benefits, Costs, and Net Benefits for the 

Alternative NSPS Option 2.0/34 in 2025 (2012$) 

3% Discount Rate 7% Discount Rate 

Monetized Methane-related Benefits1 $44 million - $250 million 

Monetized CO2 disbenefits1 $0.03 million - $0.29 million 

Total Costs2 $8.6 million $10.0 million 

Net Benefits $35 million - $240 million $34 million - $240 million 

Non-monetized Benefits3 Health effects of PM2.5 and ozone exposure from 400 Mg 

NMOC/yr reduced 

Health effects of HAP exposure from 400 Mg NMOC/yr 

reduced 

 Visibility impairment 

 Vegetation effects 

1 Monetized benefits include the climate-related benefits associated with the reduction of 62,500 Mg/yr 

methane, valued using the social cost of methane, and the net increase of 1,970 Mg/yr of CO2, valued 

using the social cost of carbon. The range of estimates reflects four SC-CH4 and four SC-CO2

estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent 

discount rate, and the 95th percentile of the pooled estimates from all models and scenarios using a 3% 

discount rate. See Section 4.2 for a complete discussion.

2 The engineering compliance costs are annualized and include estimated revenue from electricity sales 

for landfills that are expected to generate revenue by using landfill gas for energy. 

3 While we expect that these avoided emissions will result in improvements in air quality and reductions 

in health effects associated with HAP, ozone, and particulate matter (PM), we have determined that 

quantification of those benefits cannot be accomplished for this rule in a defensible way. This is not to 

imply that there are no benefits or co-benefits of the rulesthese benefits do not exist; rather, it is a 

reflection of the difficulties in modeling the direct and indirect impacts of the reductions in emissions 

for this industrial sector with the data currently available. 

7.8 Alternative Years of Analysis 

While the EPA is assessing impacts in year 2025 as a representative year for the landfills 

NSPS for new or modified MSW landfills, the quantity and composition of landfill gas does 

change over the lifetime of a landfill, as discussed in Chapter 2. This section presents a more 

complete picture of the emission reductions, costs, and benefits of the NSPS alternatives over 

time by presenting results from the years 2020, 2030, and 2040. Throughout this section, costs 

are presented only at a 7% interest rate, and do not include testing and monitoring costs. 

However, testing and monitoring costs are typically a very small percentage of the overall costs. 

Commented [A31]: This section added in response to OMB 

General Comment 1. Table additions not tracked as changes for 

clarity. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-22 

Tables 7-12 and 7-13 present the emissions reductions and compliance costs, respectively, of the 

alternatives in the 2020 snapshot year. 

Table 7-12 Estimated Annual Average Emissions Reductions in 2020 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 10,100 1.6 39.9 

Incremental values versus the current NSPS 

Alternative option 2.5/40 400 0.06 1.6 

Proposed option 2.5/34 470 0.07 1.9 

Alternative option 2.0/34 550 0.09 2.2 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-13 Estimated Engineering Compliance Costs in 2020 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 106 294 251 42.0 

Incremental values versus the current NSPS 

Alternative option 2.5/40 13 13.2 6.5 6.7 

Proposed option 2.5/34 16 15.9 8.3 7.6 

Alternative option 2.0/34 20 17.5 8.3 9.3 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 

Tables 7-14 and 7-15 present the emissions reductions and compliance costs, respectively, in the 

2030 snapshot year.
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7-23 

Table 7-14 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current NSPS = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 12,200 1.9 48.1 

Incremental values versus the current NSPS

Alternative option 2.5/40 190 0.03 0.7 

Proposed option 2.5/34 270 0.04 1.1 

Alternative option 2.0/34 330 0.05 1.3 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-15 Estimated Engineering Compliance Costs in 2030 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 115 331 258 74.0 

Incremental values versus the current EG 

Alternative option 2.5/40 7 3.8 -0.5 4.3 

Proposed option 2.5/34 12 5.9 -1.0 7.0 

Alternative option 2.0/34 16 7.6 -1.0 8.6 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

7-24 

Tables 7-16 and 7-17 present the emissions reductions and compliance costs, respectively, in the 

2040 snapshot year. 

Table 7-16 Estimated Annual Average Emissions Reductions in 2040 for the Baseline and 

Alternative Options 

 Annual Average Reduction (Mg) 

NMOC 

Million 

Methane 

Million 

Methane 

(in CO2-

equivalents)* 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 11,600 1.8 45.7 

Incremental values versus the current EG

Alternative option 2.5/40 220 0.03 0.9 

Proposed option 2.5/34 350 0.05 1.4 

Alternative option 2.0/34 360 0.06 1.4 

*A global warming potential of 25 is used to convert methane to CO2-equivalents. Secondary CO2 emission 

reductions are not included in this table. 

Table 7-17 Estimated Engineering Compliance Costs in 2040 for Baseline and Alternative 

Options (7% Discount Rate) 

 

Landfills 

Controlling 

Emissions

Estimated Annualized Net Cost (Millions 

2012$) 

Control Costs 

Revenue from 

Beneficial-use 

Projects Net Cost 

Current EG = 2.5 million Mg and m3 design capacity and 50 Mg/yr NMOC 

Baseline 107 321 228 93.0 

Incremental values versus the current EG 

Alternative option 2.5/40 7 5.0 -0.4 5.3 

Proposed option 2.5/34 12 11.6 3.2 8.4 

Alternative option 2.0/34 13 12.0 3.2 8.7 

Note: All total are independently rounded and may not sum. Costs do not include testing and monitoring costs. 

Table 7-18 presents the climate benefits of the alternatives in the 2020 snapshot year.
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7-25 

Table 7-18 Estimated Global Benefits of CH4 Reductions in 2020* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.063 1.6 $37 $82 $110 $220 

Proposed Option 2.5/34 0.074 1.9 $43 $96 $130 $260 

Alternative Option 2.0/34 0.087 2.2 $51 $110 $150 $300 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 7-19 presents the climate benefits of the alternatives in the 2030 snapshot year.

Table 7-19 Estimated Global Benefits of CH4 Reductions in 2030* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.029 0.73 $24 $50 $63 $130 

Proposed Option 2.5/34 0.042 1.1 $35 $73 $92 $190 

Alternative Option 2.0/34 0.052 1.3 $42 $89 $110 $230 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 

Table 7-20 presents the climate benefits of the alternatives in the 2040 snapshot year. 

Table 7-20 Estimated Global Benefits of CH4 Reductions in 2040* (in millions, 2012$) 

Million 

metric 

tonnes of 

CH4

reduced 

Million 

metric 

tonnes of 

CO2-

equivalent 

reduced 

Discount rate and statistic 

5% 

(average) 

3% 

(average) 

2.5% 

(average) 

3% (95th

percentile) 

Alternative Option 2.5/40 0.035 0.87 $38 $75 $98 $210 

Proposed Option 2.5/34 0.055 1.4 $59 $120 $150 $330 

Alternative Option 2.0/34 0.056 1.4 $61 $120 $160 $330 

*The SC-CH4 values are dollar-year and emissions-year specific. SC-CH4 values represent only a partial 

accounting of climate impacts. 
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8-1 

8 STATUTORY AND EXECUTIVE ORDER REVIEWS 

8.1 Executive Order 12866, Regulatory Planning and Review and Executive Order 

13563, Improving Regulation and Regulatory Review 

Under section 3(f)(1) of Executive Order (EO) 12866 (58 FR 51735, October 4, 1993), 

this action is an “economically significant regulatory action” because it is likely to have an 

annual effect on the economy of $100 million or more. Accordingly, the EPA submitted this 

action to the Office of Management and Budget (OMB) for review under EO 12866 and 13563 

(76 FR 3821, January 21, 2011) and any changes made in response to OMB recommendations 

have been documented in the docket for this action. In addition, the EPA prepared this RIA of 

the potential costs and benefits associated with this action. For the proposed Emission 

Guidelines, the monetized methane-related climate benefits are estimated to range from $310 

million to $1.7 billion (2012$); these benefits are estimated to be $660 million (2012$) in 2025 

using a 3% discount rate. The CO2 co-benefits are estimated to range from $3.6 million to $36 

million (2012$) in 2025; estimated CO2 benefits are $12 million (2012$) in 2025 using a 3% 

discount rate. Under the proposed option 2.5/34, when using a 3% discount rate, the additional 

cost over the baseline in 2025 would be $47 million. When using a 7% discount rate, the 

additional cost in 2025 would be $35 million. Thus, the net benefits are expected to be $260 

million to $1.7 billion, with a primary estimate of $620 million. Table 6-1 shows the results of 

the cost and benefits analysis for this proposed rule. 

The EPA also considered the impacts associated with the proposed revision to the NSPS 

and has concluded that the proposed NSPS is also economically significant. For the proposed 

rule, the monetized methane-related climate benefits are estimated to range from $36 million to 

$210 million (2012$) in 2025, depending on the discount rate; these benefits are estimated to be 

$78 million (2012$) in 2025 using a 3% discount rate. The CO2 disbenefits are estimated to 

range from $0.01 million to $0.10 million (2012$) in 2025, depending on the discount rate; 

estimated CO2 disbenefits are $0.033 million (2012$) in 2025 using a 3% discount rate. Under 

the proposed option 2.5/34, when using a 7% discount rate the additional cost in 2025 would be 

$8.5 million. Using a 3% discount rate, the additional cost over the baseline in 2025 would be 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

8-2 

$7.1 million. Thus, the net benefits in 2025 are expected to be $28 million to $200 million, with 

a central estimate of $69 million. These results are summarized in Table 7-9. 

8.2 Paperwork Reduction Act 

The information collection requirements in the proposed Emission Guidelines have been 

submitted for approval to OMB under the PRA. The Information Collection Request (ICR) 

document that the EPA prepared for the proposed Emission Guidelines has been assigned EPA 

ICR number [2522.01]. You can find a copy of the ICR in the docket for this rule, and it is 

briefly summarized here. 

The information required to be collected is necessary to identify the regulated entities 

subject to the proposed rule and to ensure their compliance with the proposed Emission 

Guidelines. The recordkeeping and reporting requirements are mandatory and are being 

established under authority of CAA section 114 (42 U.S.C. 7414). All information other than 

emissions data submitted as part of a report to the agency for which a claim of confidentiality is 

made will be safeguarded according to CAA section 114(c) and the EPA’s implementing 

regulations at 40 CFR part 2, subpart B. 

Respondents/affected entities: Municipal solid waste landfills that accepted waste on or 

after November 8, 1987 and commenced construction, reconstruction, or modification on 

or before July 17, 2014. 

Respondent’s obligation to respond: Mandatory (40 CFR part 60, subpart Cf). 

Estimated number of respondents: 988 municipal solid waste landfills. 

Frequency of response: Initially, occasionally and annually. 

Total estimated burden: 621,947 hours (per year) for the responding facilities and 16,054 

hours (per year) for the agency. These are estimates for the average annual burden for the 

first 3 years after the rule is final. Burden is defined at 5 CFR 1320.3(b). 
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8-3 

Total estimated cost: $41,755,793 (per year), which includes annualized capital or 

operation and maintenance costs, for the responding facilities and $1,029,658 (per year) 

for the agency. These are estimates for the average annual cost for the first 3 years after 

the rule is final. 

The information collection requirements in the supplemental NSPS proposal have been 

submitted for approval to OMB under the PRA. The Information Collection Request (ICR) 

document that the EPA prepared for this supplemental proposal has been assigned EPA ICR 

number 2498.02. You can find a copy of the ICR in the docket for this rule, and it is briefly 

summarized here. 

The information required to be collected is necessary to identify the regulated entities 

subject to the proposed NSPS and to ensure their compliance with the proposed NSPS and this 

supplemental proposal. The recordkeeping and reporting requirements are mandatory and are 

being established under authority of CAA section 114 (42 U.S.C. 7414). All information other 

than emissions data submitted as part of a report to the agency for which a claim of 

confidentiality is made will be safeguarded according to CAA section 114(c) and the EPA’s 

implementing regulations at 40 CFR part 2, subpart B. 

The information collection requirements in the proposed NSPS (79 FR 41828, July 17, 

2014) were submitted for approval to OMB under the PRA. The ICR document that the EPA 

prepared was assigned EPA ICR number 2498.01. Since the NSPS review was proposed on July 

17, 2014, the EPA updated the number of existing landfills likely to modify after July 17, 2014, 

and, thus, become subject to proposed 40 CFR part 60, subpart XXX, as discussed in this 

preamble. The supplemental proposal to lower the emission threshold for new and modified 

sources affects the burden estimates the EPA presented in EPA ICR number 2498.01. As a result, 

the EPA updated the EPA ICR number 2498.01 and re-submitted it to OMB for approval as EPA 

ICR 2498.02 to reflect the estimated number of respondents and a lower NMOC emission rate. A 

copy of the ICR is in Docket ID No. EPA-HQ-OAR-2003-0215, and it is briefly summarized 

here. 
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8-4 

Respondents/affected entities: Municipal solid waste landfills that commence 

construction, reconstruction, or modification after July 17, 2014. 

Respondent’s obligation to respond: Mandatory (40 CFR part 60, subpart XXX). 

Estimated number of respondents: 144 Municipal solid waste landfills that commence 

construction, reconstruction, or modification after July 17, 2014. 

Frequency of response: Initially, occasionally, and annually. 

Total estimated burden: 101,031 Hours (per year) for the responding facilities and 2,790 

hours (per year) for the agency. These are estimates for the average annual burden for the 

first 3 years after the rule is final. Burden is defined at 5 CFR 1320.3(b). 

Total estimated cost: $6,701,401 (per year), which includes annualized capital or 

operation and maintenance costs, for the responding facilities and $177,680 (per year) for 

the agency. These are estimates for the average annual cost for the first 3 years after the 

rule is final. 

8.3 Regulatory Flexibility Act 

The Regulatory Flexibility Act (RFA) 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 (SISNOSE). Small entities include small businesses, small organizations, and small 

governmental jurisdictions. 

For purposes of assessing the impacts of this proposed rule on small entities, small entity 

is defined as: (1) a small business that is a small industrial entity as defined by the Small 

Business Administration’s (SBA) regulations at 13 CFR 121.201; (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 

which is independently owned and operated and is not dominant in its field. 
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After considering the economic impact of the proposed Emission Guidelines on small 

entities, the EPA certifies that the proposed regulation will not have a Significant Impact on a 

Substantial Number of Small Entities (SISNOSE). 

The proposed rule will not impose any requirements on small entities. Specifically, 

Emission Guidelines established under CAA section 111(d) do not impose any requirements on 

regulated entities and, thus, will not have a significant economic impact upon a substantial 

number of small entities. After emission guidelines are promulgated, states and U.S. territories 

establish standards on existing sources, and it is those requirements that could potentially impact 

small entities. 

Our analysis here is consistent with the analysis of the analogous situation arising when 

the EPA establishes NAAQS, which do not impose any requirements on regulated entities. As 

here, any impact of a NAAQS on small entities would only arise when states take subsequent 

action to maintain and/or achieve the NAAQS through their state implementation plans. See 

American Trucking Associations v. EPA, 175 F.3d 1029, 1043-45 (D.C. Cir. 1999) (NAAQS do 

not have significant impacts upon small entities because NAAQS themselves impose no 

regulations upon small entities). 

After considering the economic impact of the supplemental proposed NSPS on small 

entities, the analysis indicates that this rule will not have a significant impact on a substantial 

number of small entities (SISNOSE). First, the proposed revision does not impact a substantial 

number of small entities, since only 13 small entities are projected to be impacted by the 

proposed option. Additionally, the impact to these entities are not significant, because only 2 

entities have impacts greater than 1 percent of sales, and only 1 of these 2 entities has impacts 

greater than 3 percent of sales. These results are summarized in Table 7-8.

8.4 Unfunded Mandates Reform Act 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Public Law 104-4, 

establishes requirements for federal agencies to assess the effects of their regulatory actions on 

state, local, and tribal governments and the private sector. Under section 202 of the UMRA, the 
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EPA generally must prepare a written statement, including a cost-benefit analysis, for proposed 

and final rules with “federal mandates” that may result in expenditures to state, local, and tribal 

governments, in the aggregate, or to the private sector, of $100 million or more in any 1 year. 

Before promulgating an EPA rule for which a written statement is needed, section 205 of the 

UMRA generally requires the EPA to identify and consider a reasonable number of regulatory 

alternatives and to adopt the least costly, most cost-effective or least burdensome alternative that 

achieves the objectives of the rule. The provisions of section 205 do not apply when they are 

inconsistent with applicable law. Moreover, section 205 allows the EPA to adopt an alternative 

other than the least costly, most cost-effective or least burdensome alternative if the 

Administrator publishes with the final rule an explanation for why that alternative was not 

adopted. Before the EPA establishes any regulatory requirements that may significantly or 

uniquely affect small governments, including tribal governments, it must have developed under 

section 203 of the UMRA a small government agency plan. The plan must provide for notifying 

potentially affected small governments, enabling officials of affected small governments to have 

meaningful and timely input in the development of the EPA regulatory proposals with significant 

federal intergovernmental mandates, and informing, educating, and advising small governments 

on compliance with the regulatory requirements. 

This action does not contain any unfunded mandate of $100 million or more as described 

in UMRA, 2 U.S.C. 1531–1538. The proposed Emission Guidelines apply to landfills that were 

constructed, modified, or reconstructed on or after November 8, 1987, and that commenced 

construction, reconstruction, or modification on or before July 17, 2014. Impacts resulting from 

the proposed Emission Guidelines are below the applicable threshold. 

However, the proposed Emission Guidelines may significantly or uniquely affect small 

governments because small governments operate landfills. The EPA consulted with small 

governments concerning the regulatory requirements that might significantly or uniquely affect 

them. In developing this rule, the EPA consulted with small governments pursuant to a plan 

established under section 203 of the UMRA to address impacts of regulatory requirements in the 

rule that might significantly or uniquely affect small governments. The EPA held meetings as 

discussed in Section 7.5 under Federalism consultations. 
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The supplemental proposal for the NSPS does not contain a federal mandate that may 

result in expenditures of $100 million or more for state, local, and tribal governments, in the 

aggregate, or the private sector in any one year. This action applies to landfills that were 

constructed, modified, or reconstructed on or after July 17, 2014. Impacts resulting from the 

proposed NSPS are far below the applicable threshold. Thus, the proposed NSPS is not subject to 

the requirements of sections 202 or 205 of the UMRA. 

8.5 Executive Order 13132: Federalism 

Executive Order 13132, entitled “Federalism” (64 FR 43255, August 10, 1999), requires 

the EPA to develop an accountable process to ensure “meaningful and timely input by state and 

local officials in the development of regulatory policies that have federalism implications.” 

“Policies that have federalism implications” are defined in the Executive Order to include 

regulations that have “substantial direct effects on the states, on the relationship between the 

national government and the states, or on the distribution of power and responsibilities among 

the various levels of government.” The EPA has concluded that the proposed Emission 

Guidelines have federalism implications, because the rule imposes substantial direct compliance 

costs on state or local governments, and the federal government will not provide the funds 

necessary to pay those costs. 

The EPA has concluded that the supplemental proposal for the NSPS does not have 

Federalism implications. The proposed NSPS will not have substantial direct effects on the 

states, on the relationship between the national government and the states, or on the distribution 

of power and responsibilities among the various levels of government, as specified in Executive 

Order 13132. The supplemental proposal will not have impacts of $25 million or more in any 

one year. Thus, Executive Order 13132 does not apply to the supplemental. Although section 6 

of Executive Order 13132 does not apply to the supplemental proposal NSPS, the EPA consulted 

with state and local officials and representatives of state and local governments early in the 

process of developing the proposed rules for MSW landfills (both the NSPS and Emission 

Guidelines) to permit them to have meaningful and timely input into the rules’ development. The 

EPA conducted a Federalism Consultation Outreach Meeting on September 10, 2013. Due to 

interest in that meeting, additional outreach meetings were held on November 7, 2013 and 
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November 14, 2013. With the pending proposal of these Emission Guidelines, an additional 

Federalism outreach meeting was conducted on April 15, 2015. Participants included the 

National Governors’ Association, the National Conference of State Legislatures, the Council of 

State Governments, the National League of Cities, the U.S. Conference of Mayors, the National 

Association of Counties, the International City/County Management Association, the National 

Association of Towns and Townships, the County Executives of America, the Environmental 

Council of States, National Association of Clean Air Agencies, Association of State and 

Territorial Solid Waste Management Officials, environmental agency representatives from 43 

states, and approximately 60 representatives from city and county governments. The comment 

period was extended to allow sufficient time for interested parties to review briefing materials 

and provide comments. Concerns raised during the consultations include: implementation 

concerns associated with shortening of gas collection system installation and/or expansion 

timeframes, concerns regarding significant lowering of the design capacity or emission 

thresholds, the need for clarifications associated with wellhead operating parameters and the 

need for consistent, clear and rigorous surface monitoring requirements. 

8.6 Executive Order 13175: Consultation and Coordination with Indian Tribal 

Governments 

Executive Order 13175, entitled “Consultation and Coordination with Indian Tribal 

Governments” (65 FR 67249, November 9, 2000), requires the EPA to develop an accountable 

process to ensure “meaningful and timely input by tribal officials in the development of 

regulatory policies that have tribal implications.” This action has tribal implications. However, it 

will neither impose substantial direct compliance costs on federally recognized tribal 

governments, nor preempt tribal law. The database used to estimate impacts of the proposed 40 

CFR part 60, subpart Cf identified one tribe, the Salt River Pima-Maricopa Indian Community, 

which owns three landfills potentially subject to the proposed Emission Guidelines. One of these 

landfills is open, the Salt River Landfill, and is already controlling emissions under the current 

NSPS/EG framework, so while subject to this subpart, the costs of this proposal are not 

substantial. The two other landfills are closed and anticipated to meet the definition of the closed 

landfill subcategory. One of the landfills, the Tri Cities Landfill is already controlling emissions 
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under the current NSPS/EG framework and will not incur substantial additional compliance costs 

under Cf. The other landfill, North Center Street Landfill, is not estimated to install controls 

under the current NSPS/EG framework. 

The supplemental NSPS proposal does not have tribal implications, as specified in 

Executive Order 13175. Based on the EPA’s review of existing landfills as outlined in the 

docketed memorandum, “Summary of Landfill Dataset Used in the Cost and Emission Reduction 

Analysis of Landfills Regulations. 2014,” tribal landfills are not anticipated to be large enough to 

become subject to the rulemaking. Thus, Executive Order 13175 does not apply to the 

supplemental NSPS proposal. Nevertheless, the EPA specifically solicits comment on this action 

from tribal officials. 

8.7 Executive Order 13045: Protection of Children from Environmental Health Risks 

and Safety Risks 

Executive Order 13045, “Protection of Children from Environmental Health Risks and 

Safety Risks” (62 FR 19885, April 23, 1997) applies to any rule that: (1) is determined to be 

“economically significant” as defined under Executive Order 12866, and (2) concerns an 

environmental health or safety risk that the EPA has reason to believe may have a 

disproportionate effect on children. If the regulatory action meets both criteria, the Agency must 

evaluate the environmental health or safety effects of the planned rule on children, and explain 

why the planned regulation is preferable to other potentially effective and reasonably feasible 

alternatives considered by the Agency. 

The EPA interprets Executive Order 13045 as applying only to those regulatory actions 

that concern environmental health or safety risks that the EPA has reason to believe may 

disproportionately affect children, per the definition of “covered regulatory action” in section 2-

202 of the Executive Order. The proposed Emission Guidelines and the supplemental NSPS 

proposal are not subject to Executive Order 13045 because they do not concern an environmental 

health risk or safety risk. We also note that the methane and NMOC reductions expected from 

the proposed Emission Guidelines and NSPS will have positive health effects including for 

children as previously discussed in Chapter 4. 
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8.8 Executive Order 13211: Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use 

This proposed action is not a “significant energy action” as defined in Executive Order 

13211, “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, 

or Use” (66 FR 28355 (May 22, 2001)) because in the Agency’s judgment it is not likely to have 

a significant adverse effect on the supply, distribution, or use of energy. The EPA has concluded 

that this rule is not likely to have any adverse energy effects because there are a small number of 

landfills subject to control requirements under subpart Cf. Further, the EPA has concluded that 

the proposed Emission Guidelines and supplemental NSPS proposal are not likely to have any 

adverse energy effects because the energy demanded to operate these control systems will be 

offset by additional energy supply from landfill gas energy projects. 

8.9 National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, §12(d) (15 U.S.C. 272 note) directs the EPA to use 

voluntary consensus standards in its regulatory activities unless to do so would be inconsistent 

with applicable law or otherwise impractical. Voluntary consensus standards are technical 

standards (e.g., materials specifications, test methods, sampling procedures, and business 

practices) that are developed or adopted by voluntary consensus standards bodies. The NTTAA 

directs the EPA to provide Congress, through OMB, explanations when the Agency decides not 

to use available and applicable voluntary consensus standards. 

This action involves technical standards. The EPA has decided to use EPA Methods 2, 

2E, 3, 3A, 3C, 21, 25, 25A, and 25C of 40 CFR part 60, appendix A. While the EPA identified 

10 VCS as being potentially applicable (ANSI/ASME PTC 19-10-1981 Part 10, ASME B133.9-

1994 (2001), ISO 10396:1993 (2007), ISO 12039:2001, ASTM D5835-95 (2013), ASTM 

D6522-11, CAN/CSA Z223.2-M86 (1999), ASTM D6060-96 (2009), ISO 14965:2000(E), EN 

12619(1999)), the agency decided not to use these methods. The EPA determined that the 10 

candidate VCS identified for measuring emissions of pollutants or their surrogates subject to 

emission standards in the rule would not be practical due to lack of equivalency, documentation, 
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validation data, and other important technical and policy considerations. The agency identified 

no such standards for Methods 2E, 21, and 25C. The EPA’s review, including review comments 

for these 10 methods, is documented in the memorandum, “Voluntary Consensus Standard 

Results for Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills” in 

the docket for this rulemaking. 

8.10 Executive Order 12898: Environmental Justice 

Executive Order 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive policy 

on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and low 

income populations in the United States. 

To gain a better understanding of the Municipal Solid Waste Landfills source category 

and near‐source populations, the EPA conducted a proximity analysis at a study area of 3 miles 

of the source category for this rulemaking. This analysis identifies, on a limited basis, the 

subpopulations that may be exposed to air pollution from the regulated sources and thus are 

expected to benefit most from this regulation. This analysis does not identify the demographic 

characteristics of the most highly affected individuals or communities, nor does it quantify the 

level of risk faced by those individuals or communities. To the extent that any minority, low‐

income or indigenous subpopulation is disproportionately impacted by hazardous air emissions 

due to the proximity of their homes to sources of these emissions, that subpopulation also stands 

to see increased environmental and health benefit from the emission reductions called for by this 

rule. 

The EPA believes the human health or environmental risk addressed by this action will 

not have potential disproportionately high and adverse human health or environmental effects on 

minority, low-income or indigenous populations because the proposed subpart would reduce 

emissions of landfill gas, which contains both nonmethane organic compounds and methane. 

These avoided emissions will improve air quality and reduce public health and welfare effects 
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associated with exposure to landfill gas emissions. The results of the proximity analysis 

conducted for the proposed Emission Guidelines are presented in the April 22, 2015 document 

entitled, “2015 Environmental Justice Screening Report for Municipal Solid Waste Landfills,” a 

copy of which is available in the docket (Docket ID No. EPA–HQ–OAR–2003–0215). 

In regards to the supplemental landfills NSPS proposal, the EPA has concluded that it is 

not practicable to determine whether there would be disproportionately high and adverse human 

health or environmental effects on minority, low income, or indigenous populations from this 

proposed rule because it is unknown where new or modified facilities will be located. However, 

the previously mentioned proximity analysis conducted for the proposed Emission Guidelines 

provides information about the populations likely to be impacted. 
From: Thundiyil, Karen 

Sent: Wednesday, August 12, 2015 4:26 PM 

To: Grossman, Andrea 

Cc: Szabo, Aaron; Ward, Hillary; Marsh, Karen; Cozzie, David; Vetter, Rick 

Subject: Landfills - Malfunctions 

Importance: High 

Hi Andrea, 

Attached you will find the response to the 3 issues we discussed yesterday. 

Please note that we do not believe it is appropriate to address SSM in the NSPS supplemental package. 

The NSPS supplemental is a streamlined notice which address the emission threshold and modifications. 

Additionally, you asked about specific text related to the RIA. 

Text excerpt: 

Additionally, a couple of sentences and a footnote have just been added to section 1.1 per our Office of General 

Counsel. Those sentences say “In accordance with Executive Order 12866, Executive Order 13563, OMB Circular 

A-4, and the EPA’s “Guidelines for Preparing Economic Analyses,” the EPA prepared this RIA for these 

“significant regulatory actions.” These actions are economically significant regulatory actions because they 

may have an annual effect on the economy of $100 million or more or adversely affect in a material way the 

economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or 

state, local, or tribal governments or communities.6” And the footnote says “6 The analysis in this draft RIA 

constitutes the economic assessment required by CAA section 317. In the EPA’s judgment, the assessment is as 

extensive as practicable taking into account the EPA’s time, resources, and other duties and authorities.” 

We have confirmed that the highlighted text is standard language for any regulation that is reflected in 

Section 317 of the CAA. 

Please let us know if you have any questions, 

Karen.