# R EGULATORY 

# I MPACT 

# A NALYSIS FOR THE 

# P RO POSED 

# R EVISIONS TO THE 

# E MISSION 

# G UIDELINES FOR 

# E XISTING 

# S OURCES AND 

# S UPPLEMENTAL 

# P ROPOSED 

# N EW 

# S OURCE 

# P ERFORMANCE 

# S TANDARDS IN THE 

# M UNICIPAL 

# S OLID 

# W ASTE 

# L ANDFILLS 

# S ECTORThis page intentionally left blank.

### EPA

- 452/R

- 15

- 00 8 August 2015

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 Health and Environmental Impacts Division Research Triangle Park, NC 27711ii 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 Par k, 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.iii TABLE OF CONTENTS

T ABLE OF C ONTENTS ................................ ................................ ................................ .................... III L IST OF T ABLES ................................ ................................ ................................ ............................. VI L IST OF F IGURES ................................ ................................ ................................ ........................ VIII E XECUTIVE SUMMARY ................................ ................................ ................................ ............. ES

- 1
ES.1 B AC KGROUND

................................ ................................ ................................ ................................ ............ ES

- 1 ES.2 R ESULTS FOR P ROPOSED R EVISIONS TO E MISSION G UIDELINES

................................ ................................ ES

- 1 ES.3 R ESULTS FOR S UPPLEMENTAL P ROPOSED N EW S OURCE P ERFORMANCE S TANDARDS

............................... ES

- 3 ES.3 O RGANIZATION OF THIS R EPORT

................................ ................................ ................................ ................ ES

- 5 1 I NTRODUCTION ................................ ................................ ................................ .................... 1

- 1
1.1 B ACKGROUND

................................ ................................ ................................ ................................ .............. 1

- 1 1.2 S TATEMENT OF N EED FOR P OLICY A CTION

................................ ................................ ................................ .. 1

- 3 1.2.1 Protection of Human Health and the Environment

................................ ................................ ............ 1

- 3 1.2.2 Need for Regulatory Intervention Because of Market Failure

................................ ........................... 1

- 4 1.2.2.1 Air Pollution as an Externality

................................ ................................ ................................ . 1

- 4 1.3 O RGANIZATION OF THIS R EPORT

................................ ................................ ................................ .................. 1

- 4 1.4 R EFERENCES

................................ ................................ ................................ ................................ ................ 1

- 5 2 I NDUSTRY P ROFILE ................................ ................................ ................................ ............. 2

- 1
2.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 2

- 1 2.2 W ASTE S TREAM B ACKGROUND

................................ ................................ ................................ ................... 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 D ISPOSAL F ACILITY B ACKGROUND

................................ ................................ ................................ .............. 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 C OSTS AND R EVENUE S TREAMS FOR L ANDFILLS

................................ ................................ ....................... 2

- 15 2.4.1 Major Cost Components for Landfills

................................ ................................ ............................. 2

- 15 2.4.2 Landfill Revenue Sources

................................ ................................ ................................ ................ 2

- 18 2.5 A IR P OLLUTANT E MISSIONS FROM L ANDFILLS

................................ ................................ .......................... 2

- 21 2.5.1 NMOC in LFG

................................ ................................ ................................ ................................ . 2

- 21 2.5.2 Methane in LFG

................................ ................................ ................................ ............................... 2

- 22 2.5.3 Criteria Pollutants from Combustion of LFG

................................ ................................ .................. 2

- 23 2.6 T ECHNIQUES FOR C ONTROLLING E MISSIONS FROM L ANDFILLS

................................ ................................ . 2

- 24 2.6.1 Introduction

................................ ................................ ................................ ................................ ...... 2

- 24 2.6.2 Gas Collection Systems

................................ ................................ ................................ ................... 2

- 24 2.6.3 Destruction

................................ ................................ ................................ ................................ ....... 2

- 26 2.6.4 Utilization

................................ ................................ ................................ ................................ ........ 2

- 28 2.6.4.1 Technologies

................................ ................................ ................................ .......................... 2

- 28 2.6.4.2 Revenues and Incentives

................................ ................................ ................................ ........ 2

- 33 2.7 I NTEGRATED W ASTE M ANAGEMENT S TRATEGIES

................................ ................................ ..................... 2

- 36 2.7.1 Introduction

................................ ................................ ................................ ................................ ...... 2

- 36iv 2.7.2 Organics Management

................................ ................................ ................................ ..................... 2

- 37 2.7.2.1 Trends

................................ ................................ ................................ ................................ ..... 2

- 38 2.7.2.2 Bene fits

................................ ................................ ................................ ................................ .. 2

- 40 2.7.2.3 Barriers

................................ ................................ ................................ ................................ ... 2

- 40 2.8 R EFERENCES

................................ ................................ ................................ ................................ .............. 2

- 42 3 R EGULATORY P ROGRAM C OSTS AND E MISSIONS R EDUCTIONS ................................ ....... 3

- 1
3.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 3

- 1 3.2 G ENERAL A SSUMPTIONS AND P ROCEDURES

................................ ................................ ................................ 3

- 1 3.3 E MISSIONS A NALYSIS

................................ ................................ ................................ ................................ .. 3

- 3 3.4 E NGINEERING AND A DMINISTRATIVE C OST A NALYSIS

................................ ................................ ................ 3

- 4 3.5 R EGULATORY B ASELINE AND O PTIONS

................................ ................................ ................................ ....... 3

- 7 3.6 A LTERNATIVE Y EARS OF A NALYSIS

................................ ................................ ................................ .......... 3

- 12 4 B ENEFITS OF E MISSIONS R EDUCTIONS ................................ ................................ ............... 4

- 1
4.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 4

- 1 4.2 M ETHAN E (CH 4 )

................................ ................................ ................................ ................................ .......... 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 PM 2.5 PRECURSOR

................................ ................................ ................................ ...................... 4

- 18 4.3.1 PM 2.5 health effects and valuation

................................ ................................ ................................ .... 4

- 19 4.3.2 Visibility Effects

................................ ................................ ................................ .............................. 4

- 23 4.4 VOC AS AN O ZONE P RECURSOR

................................ ................................ ................................ ................ 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 H AZARDOUS A IR P OLLUTANT (HAP) B ENEFITS

................................ ................................ ........................ 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 A LTERNATIVE Y EARS OF A NALYSIS

................................ ................................ ................................ .......... 4

- 35 4.7 R EFERENCES

................................ ................................ ................................ ................................ .............. 4

- 36 5 E CONOMIC I MPACT A NALYSIS AND D ISTRIBUTIONAL A SSESSMENTS ............................... 5

- 1
5.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 5

- 1 5.2 E CONOM IC I MPACT A NALYSIS

................................ ................................ ................................ ..................... 5

- 1 5.3 E MPLOYMENT I MPACTS

................................ ................................ ................................ ............................... 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 S MALL B USINESS I MPACTS A NALYSIS

................................ ................................ ................................ ....... 5

- 12 5.5 R EFERENCES

................................ ................................ ................................ ................................ .............. 5

- 1 3 6 C OMPARISON OF B ENEFITS AND C OST ................................ ................................ ............... 6

- 1
6.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 6

- 1 6.2 N ET B ENEFITS OF THE P ROPOSED S TANDARDS

................................ ................................ ............................ 6

- 1 6.3 N ET B ENEFITS OF THE A LTERNATE S TANDARDS

................................ ................................ .......................... 6

- 2 7 S UPPLEMENTAL NSPS P ROPOSAL ................................ ................................ ...................... 7

- 1
7.1 I NTRODUCTION

................................ ................................ ................................ ................................ ............ 7

- 1 7.2 R EGULA TORY B ASELINE AND O PTIONS

................................ ................................ ................................ ....... 7

- 2 7.3 B ENEFITS

................................ ................................ ................................ ................................ ..................... 7

- 8v 7.4 E CONOMIC I MPACTS

................................ ................................ ................................ ................................ .. 7

- 11 7.4.1 Economic Impact Analysis

................................ ................................ ................................ .............. 7

- 11 7.4.2 Employment Impacts

................................ ................................ ................................ ....................... 7

- 11 7.4.3 Small Business Impacts Analysis

................................ ................................ ................................ .... 7

- 11 7.5 C OMPARISON OF B ENEFITS AND C OSTS

................................ ................................ ................................ ..... 7

- 13 7.6 N ET B ENEFITS OF THE P ROPOSED S TANDARDS

................................ ................................ .......................... 7

- 14 7.7 N ET B ENEFITS OF THE A LTERNATE S TANDARDS

................................ ................................ ........................ 7

- 15 7.8 A LTERNATIVE Y EARS OF A NALYSIS

................................ ................................ ................................ .......... 7

- 18 8 S TATUTORY AND E XECUTIVE O RDER R EVIEWS ................................ ................................ 8

- 1
8.1 E XECUTIVE O RDER 12866, R EGULATORY P LANNING AND R EVIEW AND E XECUTIVE O RDER 13563, I MPROVING R EGULATION AND R EGULATORY R EVIEW

................................ ................................ .......................... 8

- 1 8.2 P APERWORK R EDUCTION A CT

................................ ................................ ................................ ..................... 8

- 2 8.3 R EGULATORY F LEXIBILITY A CT

................................ ................................ ................................ .................. 8

- 4 8.4 U NFUNDED M ANDATES R EFORM A CT

................................ ................................ ................................ ......... 8

- 5 8.5 E XECUTIVE O RDER 13132: F EDERALISM

................................ ................................ ................................ .... 8

- 7 8.6 E XECUTIVE O RDER 13175: C ONSULTATION AND C OORDINATION WITH I NDIAN T RIBAL G OVERNMENTS

... 8

- 8 8.7 E XECUTIVE O RDER 13045: P ROTECTION OF C HILDREN FROM E NVIRONMENTAL H EALTH R ISKS AND S AFETY R ISKS

................................ ................................ ................................ ................................ ................................ ..... 8

- 9 8.8 E XECUTIVE O RDER 13211: A CTIONS C ONCERNING R EGULATIONS T HAT S IGNIFICANTLY A FFECT E NERGY S UPPLY , D ISTRIBUTION , OR U SE

................................ ................................ ................................ .......................... 8

- 10 8.9 N ATIONAL T ECHNOLOGY T RANSFER AND A DVANCEMENT A CT

................................ ................................ 8

- 10 8.10 E XECUTIVE O RDER 12898: E NVIRONMENTAL J USTICE

................................ ................................ ............. 8

- 11vi 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$)

................................ ................................ ................................ ............... ES

- 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$)

................................ ................................ ...... ES

- 5 Table 2

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

................................ . 2

- 5 Table 2

- 2 Materials Discarded a 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 2013 a

................................ ................................ ................................ ................................ ................................ ........ 2

- 14 Table 2

- 4 Typical Costs Per Acre for Components o f 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

- 29 Table 2

- 7 Average LFG Direct

- use Project Components Costs

................................ ................................ ............ 2

- 31 Table 2

- 8 Waste Management of O rganics in the United States

................................ ................................ ........... 2

- 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

- 10 Table 3

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

................................ ................................ ................................ ................................ ................................ ........ 3

- 11 Table 3

- 5 Estimated Cost

- effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate)

.. 3

- 12 Table 3

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

. 3

- 13 Table 3

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

................................ ................................ ................................ ................................ ................................ ........ 3

- 13 Table 3

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

. 3

- 14 Table 3

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

................................ ................................ ................................ ................................ ................................ ........ 3

- 14 Table 3

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

- 15 Table 3

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

................................ ................................ ................................ ................................ ................................ ........ 3

- 15 Table 4

- 1 Climate and Human Health Effects of Emission Reductions in this Rule

................................ ............... 4

- 2 Table 4

- 2 Social Cost of CH 4 , 2012

– 2050 a [in 2012$ per metric ton] (Source: Marten et al., 2014 b )

................ 4

- 12 Table 4

- 3 Estimated Global Benefits of CH 4 Reductions in 2025* (in millions, 2012$)

................................ ...... 4

- 14 Table 4

- 4 Estimated Global Benefits of Net CO 2 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 CH 4 Reductions in 2020* (in millions, 2012$)

................................ ...... 4

- 35 Table 4

- 7 Estimated Global Benefits of CH 4 Reductions in 2030* (in millions, 2012$)

................................ ...... 4

- 36 Table 4

- 8 Estimated Global Benefits of CH 4 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 T able 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

- 6 Table 7

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

................................ ................................ ................................ ................................ ................................ .......... 7

- 7 Table 7

- 5 Estimated Cost

- effectiveness in 2025 for the Baseline and Alternative Options (7% Discount Rate)

.... 7

- 8 Table 7

- 6 Estimated Global Benefits of CH 4 Reductions in 2025* (in millions, 2012$)

................................ ...... 7

- 10 Table 7

- 7 Estimated Global Disbenefits of Net CO 2 Increases in 2025* (in millions, 2012$)

.............................. 7

- 10 T able 7

- 8 Small Business Impact Screening Assessment Results (Reporters and Controllers)

............................ 7

- 13vii Table 7

- 9 Summary of the Monetized Benefits, Costs, and Net Benef its for the Proposed NSPS Option 2.5/34 in 2025 (2012$)

................................ ................................ ................................ ................................ ........................... 7

- 15 Table 7

- 10 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Opti on 2.5/40 in 2025 (2012$)

................................ ................................ ................................ ................................ ........................... 7

- 17 Table 7

- 11 Summary of the Monetized Benefits, Costs, and Net Benefits for the Alternative NSPS Option 2.0/34 in 2025 (2012$)

................................ ................................ ................................ ................................ ........................... 7

- 18 Table 7

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

- 19 Table 7

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

................................ ................................ ................................ ................................ ................................ ........ 7

- 19 Table 7

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

- 20 Table 7

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

................................ ................................ ................................ ................................ ................................ ........ 7

- 20 Table 7

- 16 Estimated Annu al Average Emissions Reductions in 2040 for the Baseline and Alternative Options 7

- 21 Table 7

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

................................ ................................ ................................ ................................ ................................ ........ 7

- 21 Table 7

- 18 Estimated Global Benefits of CH 4 Reductions in 2020* (in millions, 2012$)

................................ .... 7

- 22 Table 7

- 19 Estimated Global Benefits of CH 4 Reductions in 2030* (in millions, 2012$)

................................ .... 7

- 22 Table 7

- 20 Estimated Global Benefits of CH 4 Reductions in 2040* (in millions, 2012$)

................................ .... 7

- 22viii 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

- 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 200 5 National Toxic Inventory 4

- 29ES

- 1 EXECUTIVE SUMMARY

ES.1 Background

The U.S. Environmental Protection Agency ( EPA ) is proposing revisions to the Emission
G uidelines for existing Municipal Solid Waste Landfills. T he EPA is not statutorily obligated to
conduct a review of the Emission G uidelines, but has the discretionary authority to do so when
circumstances indicate t hat this is appropriate. Based on changes in the landfills industry and changes in size, ownership, and age of landfills since the E mission G uidelines were promulgated in 1996, the EPA has concluded that it is appropriate to review the landfills E mission G uidelines
at this time. Based on our revi ew, 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 modif ied Municipal Solid Wa ste Landfills. On July 17, 2014, the EPA proposed a new NSPS subpart that retained the same design capacity size threshold of 2.5 million m 3 or 2.5 million Mg, but presented several options for revising the NMOC emission rate at which a MSW
landfill must i nstall 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 E mission G uidelines for existing MSW landfills, the key results of the RIA follow and are summarize d 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 i nto the net control costs using state

- specific data on wholesale purchase prices. The annualized costs also includ e testing and monitoring costs. For this proposal, which tightens the emissions threshold, the EPA estimated the nationwide incremental annual ized compliance cost in 2025 to be $ 46.8 million (2012$) using a 7 % discount rate. Using a 3% discount rate, theES

- 2 nationwide incremental annualized compliance cost in 2025 is estimated to be $ 35 million (2012$).
Emissions Analysis: In 2025, t h is propos al would achieve reductions of 2,770 Mg NMOC and 436,100 Mg methane ( 10.9 million Mg CO 2

- e quivalents 1 ) compared to the baseline. In addition, the proposal is expected to result in the net reduction of 238,000 Mg CO 2 , 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 f rom reducing 436,100 Mg methane, which are valued using the social cost of methane (SC

- CH 4 ), and the reductions in CO 2 , which are valued using the social cost of carbon (SC

- CO 2 ). The EPA estimates that, in 2025, the proposal will yield monetized climate benefits of $ 310 milli on (2012$) to approximately $ 1. 7 billion (2012$) 3 ; the mean SC

- CH 4 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 CO 2 are estimated to be $ 12 million (2 012$) 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 benefit s 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 Numb er 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 s mall 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 model s , 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 propos al 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 propos al should be minimal on the affected industries and their consumers.

1 A global warming potential of 25 is used to convert methane to CO 2 - e quivalents.
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 m ean 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 S ection 4.2 for a complete discussion.ES

- 3 Table ES

- 1 Summary of the Monetized Benefits, Costs, and Net Ben efits for the Proposed Emission Guidelines for Existing MSW Landfills in 2025 (2012$)

3% Discount Rate 7% Discount Rate
Total Monetized Benefits 1 $ 670 million
Total Costs 2 $ 35 million $ 47 million Net Benefits $ 640 million $ 620 million

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 2,770 Mg NMOC/yr reduce d Health effects of HAP exposure from 2,770 Mg NMOC/yr reduce d 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 CO 2 ($ 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 purpos es 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 cl imate 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 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.

ES.3 Results for Supplemental Proposed New Source Performance Standards

For the Supplemental Proposed New Source Performance Standards for n ew 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 collecti on. 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 incorp orated into the net control costs using state

- specific data on wholesale purchase prices. The annualized costs also includ e testing and monitoring costs. For this proposal, which tightens the emissions threshold, the EPA estimated the nationwide incrementa l annualized com pliance 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$).ES

- 4 Emissions Analysis: In 2025, this p roposal would achieve reductions of 300 Mg NMOC and 51,400 Mg methane ( 1.3 million Mg CO 2

- equivalents 4 ) compared to the baseline. T he proposal is also expected to result in minor secondary air impacts, specifically an increase of 670 Mg CO 2 , 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

- CH 4 ), offset by the small increases in CO 2 , which are valued using the social cost of carbon (SC

- CO 2 ). The EPA estimates that, in 2025, the pr oposal will yield monetized climate benefits of $36 million (2012$) to approximately $ 210 m illion (2012$) 5 ; the mean SC

- CH 4 at the 3% discount rate resu lts in an estimate of about $78 million (2012$) in 2025. The climate dis benefits associated with the increase of 6 70 Mg CO 2 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 (includi ng 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 num ber 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 l andfill 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 ch anges 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 w arming potential of 25 is used to convert methane to CO 2 - e quivalents. 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 S ection 4.2 for a complete discussion.ES

- 5 Ta ble ES

- 2 Summary of the Monetized Benefits, Costs, and Net Ben efits for the Supplemental Proposed New Source Performance Standards for MSW Landfills in 2025 (2012$)

3% Discount Rate 7% Discount Rate

Monetized Methane

- related Benefits 1 $78 million
Monetized CO 2 disbenefits 1 $ 0.03 million
Total Costs 2 $7.1 million $8.5 million Net Benefits $ 71 million $ 7 0 million

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 300 Mg NMOC/yr reduce d Health effects of HAP exposure from 300 Mg NMOC/yr reduce d 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 6 70 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 discoun t 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 valu es , 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 impr ovements 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 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.

ES.3 Organization of this Report

The remainder of this report details the methodo logy and the results of the RIA

. Chapter
1 provides an introduction. Chapter 2 presents the industry profile for the municipal solid waste landfill industry. Chapter 3 describe s emissions, emissions control optio ns , and engineering costs of the Emission Guidelines for existing landfills . Chapter 4 presents estimates of the benefits of
emissions reductions f rom the Emission Guidelines for existing landfills . Chapter 5 present the economic impacts, employment impact s, and small en tity 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.1

- 1 1 INTRODUCTION

1.1 Background

The EPA is proposing revisions to the E mission G uidelines for existing Municipal Solid
Waste Landfills. T he EPA is not statutorily obligated to conduct a review of the Emission
G uidelines, but has the discretionary authority to do so when circumstances ind icate that this is appropriate. Based on changes in the landfills industry and changes in size, ownership, and age
of landfills since the E mission G uidelines were promulgated in 1996, the EPA has concluded that it is appro priate to review the landfills E mi ssion G uidelines at this time. Based on our
revi ew, 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 m 3 or 2.5 million Mg, but presented several options for revising the NMOC emission rate at which a MSW
landfi ll 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 “sig nificant 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, productivi ty, competition, jobs, the environment, public health or safety, or state, local, or tribal governments
or communities. 6 In this R IA, 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.1

- 2 the United States and an analysis of the costs and emi ssions 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 y ears (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 exis ting 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 Emissio n Guidelines for existing MSW
landfills shown in this RIA are expressed as the incremental difference between facilities complying with the current Emission G uidelines for existing MSW landfills (40 CFR part 60, subpart Cc ) and facilities that would be req uired to compl y with proposed subpart Cf

. Likewise,

t he 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 compl y with proposed subpart XXX. All impacts are shown for the year 202 5

. 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 yea r 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 accordin g 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 Sign ificant Impact on a Substantial Numb er 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 regula ted 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 subs tantial number of small entities1

- 3 (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 G uidelines 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, in cluding methane and NMOC, some of which are toxic

. 7 The 1996
NSPS/EG r egulated 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, we are proposing to lower the annual NMOC emissions threshold from 50 Mg/year to 34 Mg/year. 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 (PM 2.5 ) 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 w elfare effects

. Thus, the proposed rule is expected to reduce human morbidity and premature mortality due to exposure to PM 2.5 , in addition to providing human health and ecosystem benefits due to reduced emissions of methane
and HAP, and improved visibilit y due to reduced PM levels

.

7 LFG is composed of approximately 50 percent methane, 50 percent CO 2 , 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.1

- 4 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, t he 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 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 th e 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 by

product that can be ignored or disposed of che aply 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.

1.3 Organization of this Report

The remainder of this report details the methodo logy and the results of the R IA. Chapter
2 presents the industry profile for the municipal solid waste landfill industry. Chapter 3 describe s 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, empl oyment1

- 5 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 sup plemental 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). 20 08. 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

.2

- 1 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 Performa nce 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 type s 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 wit h 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, grou ndwater 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 201 2 was approximately 25 1 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 201 2 . 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 ). T he number of active MSW landfills in the United States has decreased from approximately 7,900 in 1988 to approximately 1, 800 in 20 14 ( 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 creat ing 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 of2

- 2 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 o n 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, 201 5h ).
E ntities 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

. F irms engaged in the collection and disposal of refuse in a landfill operation are
classi fied under the North American Industry Classification System (NAICS) code s 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 d isposal 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 esta blishments 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 land fill owners include cities, counties/parishes, regional authorities, state governments, and the federal government (including military branches, Bureau of Land Management
, Departme nt of Agriculture, Forest Service
, and Department of the Interior

- National Park Service ).2

- 3 2.2 Waste Stream Background

2.2.1 Municipal Waste

2.2.1.1 Generation of M SW
MSW is generally defined as nonhazardous waste from household, commercial, and institutional sources. These three broad categories of primary MSW generators are described as:

• Househ old

– solid waste from single

- and multiple

- family homes, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day

use recreation areas.

• Commercial

– solid waste from stores, offices, restaurants, warehouses, and o ther 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 amount s 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 f low, although some industrial waste do es 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, tr ends 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 gen erated 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. Th is structure may provide little economic2

- 4 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, e ach 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 pric e 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 sta tes “h ousehold 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 201 2 , Americans generated about 25 1 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

per cent recycling rate ( EPA, 2014a ). In addition, about 29 million tons of waste w as 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 p erson 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 )

.2

- 5 Table 2

- 1 Generation and Discards of MSW, 1960 to 201 2 (in pounds per person per day) 8 Activity 1960 1970 1980 1990 2000 2005 200 8 20 10 20 11 201 2

Generation
2.68 3.25 3.66 4.57 4.7 4 4.6 9 4. 55 4. 44 4. 40 4. 38
Discards to landfill a 2.51 3.02 3.24 3.19 2.7 3 2.6 3 2. 46 2.4 1 2.36 2. 36
Discards to landfill (% of total generation) 94% 93% 89% 70% 5 8 % 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 S ent to Landfills
In 2012, o rganic materials continue d 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 1 4.8 percent. Plastics comprise 17. 6 percent while metals and wood make up 9.0 per cent and 8.2 percent, respectively. Rubber, leather, and t extiles 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 201 2 , and Table 2

- 2 shows the amounts
of different m aterials discarded in the MSW stream from 1960 to 201 2

.

8 Table ada pted from U.S. Environmental Protection Agency. 201 4 . “ Municipal Solid Waste Generation, Recycling, and Disposal in the United States : Facts and Figures for 201 2 .” Table 4

. EPA

- 530

- F

- 14

- 0 01. Washington, DC: U.S. EPA. < http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_fs.pdf >. Accessed January 6, 2015

.2

- 6 Figure 2

- 1 Material Composition of the MSW Discard Stream, 201 2 9

9 Figure adapted from U.S. Environmental Protection Agency. 201 4 . “ Municipal Solid Waste Generation, Recycling, and Disposal in the United States : Facts and Figures for 201 2 .” Figure 7

. EPA

- 530

- F

- 14

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

. Accessed Janu ary 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 & textiles2

- 7 Table 2

- 2 Materials Discarded a In the MSW Stream, 1960 to 201 2 (in thousands of tons) 10

Wastes 1960 1970 1980 1990 2000 2005 2010 201 2 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 Materials b 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

c entrally 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. 201 4 . “Municipal Solid Waste Generation, Recycling, and Disposal in the United States Tables and Figures for 201 2 .” Table 3. Washington, DC: U.S. EPA.
< http://www.epa.gov/osw/nonhaz/municipal/pubs/2012_msw_dat_tbls.pdf >. Accessed January 15, 2015

.2

- 8 of vehicles because they do not have to haul waste to distan t 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 we ll

- 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 req uired to comply with federal regulations contained in Subtitle D of RCRA [40 CFR p art 258], or equivalent state regulations. RCRA requirements include location
restrictions that ensure landfills are constructed away from environmentally

- sensitive areas,
in cluding 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 or iginally 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 landfill s sited in attainment areas, or areas where the air2

- 9 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 land fill 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 a re 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 uni form 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 determi ne 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, c over material is applied on top of the waste mass at the end of each day t o prevent od ors 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 a n extended period of time. Intermediate covers have trad itionally consisted of layers of soil, geotextiles, or other materials. The reason s 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 la ndfill 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 instal led, t hen ga s wells are monitored to ensure oxygen is not being pulled
into the landfill due to excessive vacuum levels.2

- 10 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 co mpacted 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 sys tem 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 closu re, 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 re quires liners for landfills as well as
leachate collection and removal and groundwater monitoring systems. Composite l iner 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 materi als (e.g., high

- density polyethylene) ( NW&RA, 2008 ). Lan dfill 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.2

- 11 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 wastewat er. Conventional landfills typically have in

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

may maintain moisture content s 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, 8 00 in 20 14 ) and the share of sites that are publicly owned has also decreased

— from 83 percent in 1984 to 58 percent in 20 14 ( EPA, 2010; WBJ, 2014; O’Brien, 2006; EPA, 2014 c ). However, the overall volume of disposal capacity has remained fairly cons tant, 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 o f 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 amou nt 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 comp elling factors that likely led to the closure of many existing sites and to the idea of regional landfills ( EPA, 2002b ). The passage of federal2

- 12 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

m ultiple 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 op t 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 tr ansfer 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 int o 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 sit e(s) ( EPA, 2012f ). Given the dramatic decrease in the number of active landfills in the past 2 5 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 l arge, 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 privatel y 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.2

- 13 There are more than 100 private companies that own and/or operate currently act ive MSW landfills, ranging from large companies with numerous landfills throughout the country to local businesses that own a single landfill ( EPA, 2014 c ). The handling of MSW in the United States generated $55 billion of revenue in 2011 , of which landfill ing contributed $13 billion ( WBJ, 2012 a ). In terms of their overall 201 3 revenue, the top two companies that own and/or operate MSW landfills in the United States were Waste Management ($13. 9 8 billion) and Republic Services ($8. 42 billion), which together accounted for approximately 40 percent of the solid waste management revenue share in 201 3 ( Bloomberg, 2014WM; Bloomberg, 2014RSG ). The next tier of companies involved in landfill management includes Clean Harbors ($3.51 billion), Progressive Waste Solutio ns ($ 2.03 billion), and Waste Connections ($1. 93 billion) ( Bloomberg, 2014CLH; Bloomberg, 2014BIN; Bloomberg, 2014WCN ). Table 2

- 3 contains a summary of the 201 3 revenue for the top five companies, as well as information about their
MSW landfills and transfer stations.2

- 14 Table 2

- 3 Top 5 Waste Management Companies That Owned or Operated MSW Landfills in the United S tates in 2013 a

Company 201 3 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. 9 8 26 7 9 3.8 300

Republic Services ( Bloomberg, 2014RSG ) 8. 42 19 0 active/
1 24 closed N / A 19 9

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 1 9.5 61

a Ranking of top five companies adapted from “The 2013 Waste Age 100”. < http://waste360.com/%5Bprimary

term%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, admi nistrative staff, weigh scale operators, salespersons, and landfill operations managers. In 20 12 , 1, 290 private
establishments had 15,426 employees in the continental United States under NAICS 562212 (Solid Waste Landfill) ( Census, 2012 ). In 201 3 , solid wa ste management departments of local governments reported 9 5,674 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 con tinues 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, 201 5h ). 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.2

- 15 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 p art 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, correct ive actions, financial assurance requirements, LFG migration controls, closure requirements, and post

closure requirements ( EPA, 2012g ). It can cost more than $1 million per acre to construct, operate, and close a landfill in compliance with these regulati ons ( 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. Lan dfill 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 operat e 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 art icles 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

co nstructing 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 ).2

- 16 Table 2

- 4 Typica l 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 whic h 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), l eachate 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 re latively small2

- 17 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 connectio n 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 cappin g 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 cost s. 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 syste m, 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, p ost

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

- 18 Figure 2

- 2 shows that landfill costs peak prior to the landfill opening and again following the landfill closing ( EPA, 1997 ).

Figure 2

- 2 Landfill Co st 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, t he average national

sp ot 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 compa res to average national tip fees of approximately $32 in 1998 ( Repa, 2005 ) and $8 in 1985 ( NW&RA, 2011 ).2

- 19 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 ( Wri ght, 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 p roximity of other landfills.

Table 2

- 5 Average Regional and National Per

- Ton Tip Fees (Rounded): 1995

- 2011 U.S. Region 1995 a 1998 a 2000 a 2002 a 2004 a 2008 b 2010 c 201 1 d
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 Bio C ycle, 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 d isposed in the local community

- owned landfill means more
money generated to fund their solid waste system s , including non

- dis posal s ervices 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 set2

- 20 competitive tip fees has caused some communities to reduce their own tip fees in an effort to attract enough disposal volume to keep revenues at a sufficient level ( Burgiel, 2003 )

. Historically, the construction and operating costs of public MSW landfills have been funded by tip fees, tax revenues (e.g. , county/city property tax revenue that goes into a general fund), or a combination of these. Factors influencing tip fee values have included population and economic growth, recycling rates, operating and transportation costs, land values, and legislation

. Traditionally, 30 percent of landfills receive all revenue from tip fees, 35 percent receive all revenue from taxes, and 35 percent cover the costs of waste disposal through a combination of tip fees and taxes. The use of taxes as a revenue source rather than tip fees has implications on waste disposal services. When disposal costs are included in taxes, most people are not aware of the actual costs involved and there is little incentive to reduce waste generation rates. Also,

tax

- supported facilities are typically underfunded relative to actual disposal costs, resulting in poorer operation than fully funded landfills supported by tip fees. Factors that influence the choice of revenue sources include landfill size and ownership. Landfills receiving small

q uantities 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 whethe r 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 dec lines 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 fe es 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 benefici al 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 to2

- 21 tip fees and total landfill revenues, but can help o ffset 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 o f
NMOC include items such as household cleaning products and materials coated with or containing paints and adhesives; d uring decomposition , NMO C can be stripped from these
materials by other gases (e.g., methane or carbon dioxide) and become part of the L FG ( EPA,
2012h )

.2

- 22 The concentration of NMOC in uncontrolled LFG depends on severa l factors, including waste types in the landfill and the local climate. EPA’ s Compilation of Air Pollutant Emiss ion 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

- 36 tim es 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,
20 13 ). 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, 201 5h). When waste is first placed in a landfill, it enters an aerobic decomposition stage

. The availability of oxygen at t his stage means that carbon released from the decomposition of organic waste materials is in the form of carbon dioxide, and 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 CO 2 equivalency calculations, consistent with the GHG emissions inventories and the IPCC Fourth Assessment Report.2

- 23 Figure 2

- 3 Typica l LFG Generation Curve

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 propo sed rule.

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 (NO X ), sulfur dioxide (SO 2 ), and particulate2

- 24 matter (PM) ( EPA, 1998 ). NO X 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. SO 2 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 ene rgy 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 s ection w as obtained from the U.S. EPA’s Landfill Methane Outreach Program (LMOP) L F G Energy Project Development Handbook ( EPA, 2015a ).

2.6.2 Gas Collection Systems

LFG collection typically begin s after a portion of the landfill (known as a “cell”) is
closed to additiona l 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 m ethod of 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. Bot h types of collection systems connect the wellheads to lateral piping that transports the gas to a collection header

.2

- 25 Source: EPA, 2015a
Figure 2

- 4 Vertical Well LFG Collection

Source: EPA, 2015a
Figure 2

- 5 Horizontal Well LFG Collection2

- 26 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 m ove 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 eff iciency 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. C ollection efficiencies at landfills with comprehensive gas collection systems typically range from 5 0 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 c over 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
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 esti mated capital cost (in
20 12 $’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 20 12 $’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 Des truction

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 t o a 20 ppmv outlet2

- 27 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 sy stem 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 regulat ing the supply of combustion air ( ATSDR, 2001 ). Enclosed flares are more expensive but may be preferable (or required by state regulations) because they provide greater control of combustion conditions and allow for stack testing . They can also reduce nois e 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 c ondensate forms when warm ga s from the landfill cools as it travels through the collection system. If condensate is not removed, it can block the co llection 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, 2014 b )

.2

- 28 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 develop ment potential, indicates that approximately 6 40 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 t hermal 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 utiliz ation 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 speci fic meaning within the MSW landfill s 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 typically dehumid ifi ed , filt ered , and compress ed 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 ).
Elec tricity 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. Advanta ges 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)2

- 29 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 generati ng 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 engi nes) because they can operate with as little as 35 percent methane and less than 300 cfm, and also produce low nitrogen oxide emissions.
An LFG energy project may use multiple units to accommodate a landfill’s specific gas flow over time. For example, a pr oject 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 o f electricity generation equipment, the necessary compression and treatment system, and the interconnect equipment. Table 2

- 6 presents examples of typical costs
for se veral 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, 5 00 $2 2 0

Gas turbine 10,000 kW $1,400 $130
Microturbine 200 kW $ 2,900 $ 220
Source: EPA, 2014 b

a 201 2 $2

- 30 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 inc lude 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 turbin e that combusts LFG with a steam turbine that uses steam generated from the gas turbine’s exhaust to create electricity. Boiler/steam turbine and combined cycle applications tend to be larger in scale than the majority of LFG electricity projects that use internal combustion engines.

2.6.4.1.3 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 use r ’ 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 s till 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 faciliti es 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 cos ts of modifications will vary. If retuning the boiler burner is the only2

- 31 modification required, costs will be minimal. However, retrofitting a n existing natural gas boiler to include LFG may cost between $100,000 and $400,000, depending on the extent of th e retrofit ( EPA, 2014 b )

. Direct thermal applications include kilns (e.g., cement, pottery, and brick), tunnel furnaces, process heaters, and bla cksmithing forges . In addition, infrared heaters can use LFG to fulfill space heating needs. Greenhouses can com bust 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 c omponents 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
th an 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 w ill 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 Costs a Typical Annual O&M Costs a ,b
Gas compression and treatment $ 1,200 /cfm $ 130 /cfm Gas pipeline and condensate management system $ 449 ,000/mile Negligible

Source : EPA, 2014 b

a 201 2 $ , 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 A lternative Fuel
Production of alternative fuels from LFG, by upgrading the gas using high

- Btu conversion technologies, is be coming more prevalent. LFG can be used to produce the2

- 32 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 colle ction 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 conten t and, conversely, reducing its carbon dioxide, nitrogen, and oxygen content. In the U nited 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.
C apital costs of high

- Btu processing equipment (in 2012$ ) range from $2, 5 00 per cfm LFG for a 10,000

- cfm processing system to $ 5,900 per cfm LFG for a 1,000

- cfm processing system . The annual cost to provide electricity to, operate, and maintain these systems (in 2012$ ) is approximately $500 per cfm LFG ( EPA, 2014 b ). Costs will depend on the purity of the high

Btu gas required by the receiving pipeline or energy end user as well as the s ize of the project, since some economies of scale can be achieved when producing larger quantities of high

- Btu

gas. For alternative fuel projects, the c apital costs of converting LFG into CNG also vary, depending primarily on the quantity of fuel being con verted 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, 2014 b ).2

- 33 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. H owever, the revenue received represents only a small percent age of the operating
costs of a landfill.

2.6.4.2.1 G HG 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 equivalen ts. 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 cr edits. In these cases, corporate entities or public institutions, such as universities, may wish to reduce their “carbon footprint” or meet internal sustainability goals, but do not have direct access to developing their own project. Therefore, a buyer may help finance a specific project in exchange for the credit of offsetting 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 jurisdict ions. 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 emis sions, 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

- and

trade programs, suc h 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 projec t (typically CHP projects receive more revenue due to credit for avoided boiler fuel use).2

- 34 2.6.4.2.2 Electric i ty 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 a nd the type of contract available to the project, but typically range between 2.5 and 11 cents per kWh ( EPA, 2014 b ). When assessing the economics of an electricity project, it is also important to consider the avoided cost of the electricity used on site. Electricity generated by the project that is used in other operations at the landfill is, in effect, electricity that the landfill does not have to purchase from a utility. This electricity is not valued at the buy

- back rate, but at the rate the landfill is charged to purchase electricity (i.e., retail rate). The retail rate is often significantly higher than the buy

- back rate. LFG energy projects can potentially use a variety of additional environmental revenue streams, which typically take advantage of the fact that LFG is recognized as a renewable, or “green,” energy resource. These additional revenues can come from premium pricing, tax credits,
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 electric ity project credits: a direct cash grant, a n 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 stream s that an LFG e lectricity 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), o r 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

- hour2

- 35 (MWh) units, and are sold by LFG electricity generators to industries, comme rcial 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 po wer 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 20 14 calendar year, all electricity produced must be sold to an unrelated person during the taxable year. Under legislation passed i n December 2014 , the placed

- in

- service date deadline for LFG energy projects to be eligible was extended to December 31, 201 4 ( DSIRE, 2015 )

.

2.6.4.2.3 D irect

- 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

- spec ific 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 use r 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 re venue 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
renewab le fuel produced which are purchased by parties required to meet specified volumes of renewable fuel (EPA, 2014 d ). In 2014, RIN credits for advanced biofuels (such as LFG

- based2

- 36 biogas) were between $0.74 and $1.00 per RIN, equivalent to a range of $9 to $1 3 per million Btu (ABC, 2014). GHG emissions trading programs are also potential revenue streams for direct

use projects.

2.7 Integrated Waste Management Strategies

2.7.1 Introduction

Landfills are one method of waste disposal, but alternative strategies are availa ble 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 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. R ecyclable 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 a im 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 of2

- 37 organic waste diversion, nor does it compete with waste prevent ion 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 methan e 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 org anic 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 was tes can be composted or anaerobically digested. 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, ventila ting 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, alt hough 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 f uel 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 U nited 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 p lants operating by 2013, some of them digesting food waste alone and others co

-2

- 38 digesting food waste with w astewater and other organics ( Arsova, 2010; RWI, 2013a; RWI,
2013b )

.

2.7.2.1 Trends
States and municipalities in the U nited States are increasingly moving toward the diversion of organic wastes from landfills. State initiatives to recycle organic wastes ha ve contributed to the growth of curbside organic s collection as well as commercial and institutional
collection and treatment. Table 2

- 8 lists the 21 states that have m andated 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, 20 14b; 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 households grew by nearly 50 percent ( BioCycle, 2015 ). The assortment of organics management in itiatives and programs at state and local levels varies across the country by:

• T ype of organic wastes targeted (e.g., food waste, yard waste);

• Source of organic waste g eneration (e.g., commercial, residential, institutional);

• P hase of implementation (from pilot projects to mandatory requirements with fines for violations) ; and

• P ricing formats (e.g., “pay

- as

- you

- throw,” property tax, fixed fee) ( BioCycle, 2015 ).2

- 39 Table 2

- 8 Waste Management of Organics in the United States

State State

- wide Organics Diversion Mandate and/or Disposal Ban 1 ,2,3 Local Residential Food Waste Collection Program 4 Arkansas 

###  California 

###  (F W ) 

###  Colorado 

###  Connecticut 

###  (F W ) 

###  Delaware 

###  Illinois 

###  Indiana 

###  Iowa 

###   Kentucky 

###  Maryland 

###   Massachusetts 

###  (F W ) 

###  Michigan 

###  Minnesota 

###   Nebraska 

###  New Hampshire 

###  New Jersey 

###   New York 

###  North Carolina 

###  Ohio 

###   Oregon 

###  Rhode Island 2 

###  (F W ) Pennsylvania 

###   South Carolina 

###  South Dakota 

###  Tennessee 

###  Texas 

###  Vermont 

###  (F W ) 

###  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. Program s are not state

- wide initiative s

.2

- 40 2.7.2.2 Benefits

The b enefits 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 com post 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 b arriers 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 compost ing 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 legi slation 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 ). Less ening 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 t reatment 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 diverte d 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 si tes to onsite2

- 41 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
incr eased 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 U nited States has been based o n 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, 201 4 ). 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 t o 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 digeste r ( Waste360, 2014 ). More recently, local solid waste age ncies 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 p riced 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, an d 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 and2

- 42 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
infra structure 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 infor mation 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 challengin g 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). 20 14. “A Snapshot of RNG and the Market.” May 12, 2014.
< https://www.americanbiogascouncil.org/biogasProcessing/rngMarket_snapshot.pdf >. Arsova, Ljupka. 2010. “Anae robic D igestion of F ood W aste: Current S tatus, P roblems and an Alternative P roduct .” Columbia University. Earth Engineering Center. May 2010.
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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. “17 th Nationwide Survey of MSW Management in the U.S.: The State of Garbage in America.” October 2010. < http://www.biocycle.net/2010/10/the

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. 2015. “LFGTE Supplement: The Organic Factor.” January/February 2015.
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management

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waste.com/pdf/AnaerobicDigestionEbrief.pdf >. Renewable Waste Intelligence (RWI). 2013b. “ Commercial Updates: Municipal Solid Waste Conversion o n t he West Coast U

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< http://freewaterindependence.com/tipping_fee_bulletin_2005.pdf >.
Shin, Dolly. 2014. “Generation and Disposition of Municipal Solid Waste (MSW) in the United States

– A National Survey.” Columbia University. Earth Engineering Center. January 3, 2014. < http://www.seas.columbia.edu/earth/wtert/sofos/Dolly_Shin_Thesis.pdf >. Solid Waste Association of North America (SWANA). 2007. “The Regional Privately

- Owned Landfill Trend and Its Impact on Integrated Solid Waste Management Systems.” February 200 7. Sullivan, Patrick. 2010. “The Importance of Landfill Gas Capture and Utilization in the U.S.” Columbia University. Earth Engineering Center. Council for Sustainable Use of Resources . April 6, 2010.
< http://www.seas.columbia.edu/earth/wtert/sofos/Importance_of_LFG_Capture_and_Util ization_in_the_US.pdf >. U.S. Census Bureau (Census). 2012. Economic Census and Population Estimates. Economic Census : Industry Snapshot s . Solid Waste Landfill (NAICS 562212). 2012.
< http://thedataweb .rm.census.gov/TheDataWeb_HotReport2/econsnapshot/2012/snapsho t.hrml?NAICS=562212 >

. U.S. Census Bureau (Census). 201 3

. Annual Survey of Public Employment & Payroll. Local Government Employment and Payroll Data

. March 2013

. < http://www.census.gov/govs/apes/ >

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< http://www.epa.gov/ttn/chief/ap42/ch02/final/c02s04.pdf >. U.S. Environmental Protection Agency (EPA). 2000 . Office of Air and Radiation, Office of Air Quality Planning and Standards. “Compilation of Air Pollutant Emission Factors, Fifth Editio n, Volume I: Stationary Point and Area Sources, Chapter 3: Stationary Internal Combustion Sources, Section 3.1: Stationary Gas Turbines”. April 2000.
< http://www.epa.gov/ttn/chief/ap42/ch03/ index.html >. U.S. Environmental Protection Agency (EPA). 2002a. “Economic Impact Analysis for the Supplemental to the Municipal Solid Waste (MSW) NESHAP.” December 2002. EPA

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fees

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- s >.3

- 1 3 REGULATORY PROGRAM C OSTS AND EMISSIONS R EDU CTIONS

3.1 Introduction

Currently, the Emission G uidelines for existing MSW landfills r equire s 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 R IA includes three sets o f discussions related to the proposed new Emission
G uidelines :

• Emissions Analysis

• Engineering and Administrative Cost Analysis

• Regulatory Option Analysis
This discussion of the emissions and cost analyses is mea nt to assist the reader of the R IA to better understand the regulatory impact analysis. However, we provide reference s to technical
memoranda for reader s interested in a greater level of detail.

3.2 General Assumptions and Procedures

The proposed Emission G uidelines 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, 1987 12 , and that commenced construction, reconstruction, or modification prior to July 17, 2014 (the date of publication of proposed
revisions to the land fills NSPS, 40 CFR part 60, subpart XXX). However, t he 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 subcatego ry 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.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. Thes e 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
existin g 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 f ive 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 C hapter 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 Re gulations. 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 202 5 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 o f 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 p roposed subpart Cf. While the analysis focuses on impacts3

- 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 E stimating Cost and Emission Impacts of Proposed MSW Landfill Regulations. 201 5

. ”

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 S ubpart Cc . Each regulatory option was compared to this baseline.

• Each l andfill would install gas collection and control systems (GCCS) when the landfill exceeds the emission rate and design capacity threshold

.

• Each l andfill would remove GCCS when the act ual 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 p resented 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 Analysi s

To estimate emission reductions, the amount of LFG and NMOC emitted at each l andfill was estimated using a model programmed in Microsoft® Access . The model assumes that the collection equipment is installed and operational at the landfill 30 months after the emissions exceed the NMOC emission threshold in each option 13

. As the landfill is filled over time, the

13 Note that even though the proposed rule allows a 30

- month initial lag time, t he 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, becau se 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.3

- 4 model assumes the landfill expands the GCCS into new areas of waste placement in accordance with the expansion l ag time of the standard

. Once the landfill has reached maximum gas production, gas generation will beg in 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
thresho ld 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 destructi on efficiency of 98 percent

. 14

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 fr om 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 i n 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 requ ired by the rule. Landfills are required to install contr ols 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.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 c ontrol 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 cos ts, 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 ar e 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 evalua tion, the EPA assessed costs in 2012 $. The costs included in LFGcost

Web 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 t o calculate the annualization factors,
the EPA assumes that flares, wells, we ll 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 syst em 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/LFGcost

WebV3_0manual.pdf3

- 6 A number of the capital costs equati ons 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 e ach 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 inst all 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 ft 3 per year of collected LFG (at 50 percent methane). Therefore, engines are
assumed to be installed at landf ills that have at least 195 million ft 3 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. Th e 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 ft 3 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 ft 3 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 particula tes and moisture (e.g., a chiller), reciprocating engine and generator, electrical interconnect equipment, and site work including housings, utilities, and total facility engineering, design, and permitting.3

- 7 Several of the compliance requirements require l abor 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, depe nding 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, t he alternative regulatory options differ from the baseline by varying in the design capacity thresholds and emission rate thresholds:

• Baseline: d esign 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

• P roposed Option 2.5/ 34 : d esign 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

r educed 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 emissi ons , and 233 landfills in the closed subcategory in
2025.3

- 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 m 3 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 contr olling 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 r equired 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 a dditional 2,770 Mg
NMOC and 436,100 Mg methane ( 1 0 , 9 00 ,000 Mg CO 2 Eq. ) compared to the baseline in 202 5

. The less stringent alternative option 2.5/40 would yield emissi ons reductions of 1,720 Mg
NMOC and 270,700 Mg methane ( 6 , 8 00,000 Mg CO 2 Eq. ) compared t o the baseline, while the more stringent alternative option 2.0/34 would result in emissi ons reductions of 3,040 Mg
NMOC and 479,100 Mg methane ( 1 2 , 0 00,000 Mg CO 2 Eq. ) compared to the baseline. The wide range in magnitude of emission reductions among pollutants is due to the composition of landfill3

- 9 gas: NMOC represents less than 1 percent of landfill gas, while methane represents approximately 50 percent. The emission reductions are summarized i n 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 CO 2 - equivalents )*

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 57,300 9 ,03 5,000 2 26 , 0 00,000

Increment al values versus the current EG Alternative option 2.5 /40 1,720 270,700 6,800,000 P roposed 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is table.
Under the proposed option 2.5/ 34, when using a 7% discount rate the additional cost of

c ontrol over the baseline in 202 5 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 ( Table 3

- 3 ). The additional cost of control for the less stringent alternative option 2.5/40 is estimated to be $60.3 million, $33.6 million of which is e stimated to be offset by increased revenue from beneficial

- use projects, so the net cost is estimated to be $ 27
million

. The cost of control for the more stringent alternative option 2.0/34 is estimated to be $111 million, $60.7 million of which is estimat ed to be offset by increased revenue from
beneficial

- use projects, so the net cost is estimated to be $ 51 million. T hese options represent approximately between 9 to 17 percent in addit ional 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.3

- 10 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

- u se Projects Net Cost

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 7.3 1,700 1,410 2 9 9

Incremental values versus the current EG Alternative option 2

. 5 /40 0. 40 6 0.3 3 3.6 27.0 P roposed option 2.5/ 34 0 .6 9 1 0 1 5 5.3 46.8 Alternative option 2.0/ 34 0. 84 1 1 1 6 0

. 7 51.0 Note: A ll total are independently rounded and m ay 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 th e baseline in 2025 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 ( Table 3

- 4 ).
The cost of control for the less stringent alternative option 2.5/40 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 n et cost is estimated to be $ 20.1 million

. The cost of control for the more stringent alternative option 2.0/34 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 c ost 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 in dustry 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.3

- 11 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

- u se Projects Net Cost

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 7. 1 2 , 19 0 2 , 1 2 0 8 4. 5

Incremental values versus the current EG Alternative option 2

. 5 /40 0. 37 72.1 52.3 20.1 P roposed option 2.5/ 34 0.66 117 82.5 35.0 Alternative option 2.0/ 34 0.80 126 89.1 38.1
Note: A ll 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 effecti veness for NMOC reductions is $ 5, 2 00 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

- 5 ). The average cost

- effectiveness of controlling methane is significantly lower than for
NMO C 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
reduc tions is roughly $ 33 per Mg methane under the baseline an d approximat ely $ 1 0 0

- $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

- 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 t han 1 percent of landfill gas. The overall average cost effectiveness for methane reductions is $189 per Mg methane under the baseline and approximately $225

- $235 per Mg methane under the proposed option 2.5/34 and the alternative options 2.5/40 and 2.0/ 34.3

- 12 Table 3

- 5 Estimated Cost

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

- effectiven ess (2012$ per Mg )

NMOC Methane Methane (in CO 2 - equivalents )* Net Cost b /ton Total Cost /ton Net Cost b /ton Total Cost /ton Net Cost b /ton Total Cost /ton

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 5, 2 00 29,800 3 3 .1 189 1.3 7

. 6

Incremen tal 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 CO 2 emission reductions are not reflected in these estimates. b Net Cost is the total control and testing an d 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. Reciprocati ng 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 t he EPA is assessing impacts in year 2025 as a representative year for th e 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. T his section present s 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 an d monitoring costs are typically a very small percentage of
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.3

- 13 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 CO 2 - equivalents )*

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 56,300 8.9 222

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 595 1,660 1,390 262

Incremental values versus the current EG Alternative option 2

. 5 /40 57 53.0 42.9 18.1 P roposed option 2.5/ 34 93 88.4 65.8 30.5 Alternative option 2.0/ 34 108 96.9 70.0 34.9 Note: A ll 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.3

- 14 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 CO 2 - equivalents )*

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 55,600 8.8 219

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 554 1,680 1,360 325

Incremental values versus the current EG Alternative option 2

. 5 /40 65 69.4 31.5 32.9 P roposed option 2.5/ 34 107 112.9 58.5 49.4 Alternative option 2.0/ 34 123 122.4 63.9 53.5 Note: A ll total are independently rounded and may not sum.3

- 15 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 CO 2 - equivalents )*

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 49,500 7.8 195

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 464 1,500 1,100 398

Incremental values versus the current EG Alternative option 2

. 5 /40 47 51.6 26.7 27.0 P roposed option 2.5/ 34 74 89.4 56.4 35.0 Alternative option 2.0/ 34 81 93.0 58.2 36.7
Note: A ll total are independently rounded and may not sum.4

- 1 4 BENEFITS OF EMISSION S REDUCTIONS

4.1 Introduction

The proposed Emission Guidelines are expected to result in significant emissions
reductions of landfill gas (LFG) from existing MSW landfills

. 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 organ ic HAP. VOC emissions are precursors to both fine particulate matter (PM 2.5 ) and ozone formation, while methane is a GHG and a precursor to global ozone formation. As described in the su bsequent sections, these pollutants are associated
with substantial health effects, climate effects , and other welfare effects

. T he only categor ies of
benefits monetized in this RIA are methane

- related climate effects and CO 2 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. T h e CO 2 co

- benefits are estimated to range from $ 3.6 million (2012$) to $ 36 million (2012$) in 2025; estimated CO 2 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 (PM 2.5 ), we have determined that quantification of those health benefits cannot be accomplished for this rule in a defensi ble 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 th e data available, we are not able to provide a credible health PM 2.5 benefits estimates for th is 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 r esponses associated with HAP and4

- 2 VOC reductions. 16 Nearly 30 organic HAPs have been identified in uncontrolled LFG, including benzene, ethyl benzene, toluene, and vinyl chloride, and they will be reduced by this rule. In this chapter, we provide a qualitati ve assessment of the health benefits associated with reducing exposure to these pollutants, as well as vis i bility 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 Effec t Has Been Monetized More Information Improved Environment

Reduced climate effects Global climate impacts from methane (CH 4 ) and carbon dioxide (CO 2 ) — 1  Marten et al. (2014), SC

- CO 2 TSDs Other climate impacts (e.g., ozone
, black carbon, aerosols, other impacts) — — IPCC, Ozone ISA, PM ISA 2 Improved Human Health Reduced incidence of premature mortality from exposure to PM 2.5 Adult premature mortality based on cohort study estimates and expert elicitation estimates (age >25 or age >30) — — PM ISA 3

Infant mortality (age <1)

— — PM ISA 3

Reduced incidence of morbidity from exposure to PM 2.5 Non

- fatal heart attacks (age > 18)

— — PM ISA 3 Hospital admissions

— respiratory (all ages)

— — PM ISA 3 Hospital admissions

— cardiovascular (age >20)

— — PM ISA 3 Emergency room visits for asthma (all ages)

— — PM ISA 3 Acute bronchitis (age 8

- 12)

— — PM ISA 3 Lower respiratory symptoms (age 7

- 14)

— — PM ISA 3 Upper respiratory symptoms (asthmatics age 9

- 11) — — PM ISA 3 Asthma exacerbation (asthmatics age 6

- 18)

— — PM ISA 3 Lost work days (age 18

- 65)

— — PM ISA 3 Minor restricted

- activity days (age 18

- 65)

— — PM ISA 3 Chronic Bronchitis (age >26)

— — PM ISA 3 Emergency room visits for cardiovascular effects (all ages) — — PM ISA 3

16 Previous studies have estimated the monetized benefits

- per

- ton of reducing VOC emissions associated with the effect that those emissions have on ambient PM 2.5 levels and the health effects associated with PM 2.5 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 add ition, 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 PM 2.5 and the highly localized na ture 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.4

- 3 Category Specific Effect Effect Has Been Quantified Effec t Has Been Monetized More Information Strokes and cerebrovascular disease (age 50

- 79) — — PM ISA 3 Other cardiovascular effects (e.g., other ages)

— — PM ISA 2 Other respiratory effects (e.g., pulmonary function, non

- asthma ER visits, non

- bronchitis chronic diseases, other ages and populations) — — PM ISA 2
Reproductive and developmental effects (e.g., low birth weight, pre

- term births, etc) — — PM ISA 2, 4 Cancer, mutagenicity, and genotoxicity effects

— — PM ISA 2, 4

Reduced incidence of mortality from exposure to ozone Premature mortality based on short

- term study estimates (all ages) — — Ozone ISA 3 Premature mortality based on long

- term study estimates (age 30

– 99) — — Ozone ISA 3

Reduced incidence of morbidity from exposure to ozone Hospital admissions

— respiratory causes (age > 65) — — Ozone ISA 3 Hospital admissions

— respiratory causes (age <2) — — Ozone ISA 3 Emergency department visits for asthma (all ages) — — Ozone ISA 3

Minor restricted

- activity days (age 18

– 65)

— — Ozone ISA 3 School absence days (age 5

– 17)

— — Ozone ISA 3 Decreased outdoor worker productivity (age 18

– 65) — — Ozone ISA 3 Other respiratory effects (e.g., premature aging of lungs) — — Ozone ISA 2 Cardiovascular and nervous system effects

— — Ozone ISA 2 Reproductive and developmental effects

— — Ozone ISA 2, 4 Reduced incidence of morbidity from exposure to HAP Effects associated with exposure to hazardous air pollutants such as benzene — — ATSDR, IRIS 2 ,3

Improved Environment Reduced visibility impairment Visibility in Class 1 areas

— — PM ISA 3 Visibility in residential areas

— — PM ISA 3 Reduced effects from PM deposition (organics) Effects on Individual organisms and ecosystems — — PM ISA 2

Reduced vegetation and ecosystem effects from exposure to

ozone Visible foliar injury on vegetation

— — Ozone ISA 3 Reduced vegetation growth and reproduction

— — Ozone ISA 3 Yield and quality of commercial forest products and crops — — Ozone ISA 3 Damage to urban ornamental plants

— — Ozone ISA 2 Carbon sequestration in terrestrial ecosystems

— — Ozone ISA 3 Recreational demand associated with forest aesthetics — — Ozone ISA 2

Other non

- use effects Ozone ISA 2 Ecosystem functions (e.g., water cycling, biogeochemical cycles, net primary productivity, leaf

- gas exchange, community composition) — — Ozone ISA 2

1 The global climate and related impacts of CO 2 and CH 4 emissions changes, such as sea level rise, are estimated within each integrated assessment model as part of the calculation of the SC

- CO 2 and SC

- CH 4 . 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 CO 2 emissions.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 analys es.

4 We asse ss 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 (CH 4 )

4.2.1 Methane climate effects and valuation

Methane is the one of the principal component s 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 atmos phere to form ozone and ozone als o 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, meltin g 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 (A R5, 2015), c hanges in methane concentrations since 1750 contribute d 0.48 W/m 2 of forcing, which is about 1 7 % of all global forcing due to increases in anthropogenic GHG concentrations, and which makes methane the second leading long

- lived climate forcer after
CO 2 . 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/m 2 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

- 201 3 (published April 201 5 ) estimates 2013 methane emissions
from MSW l andfills to be 97.5 MMt CO 2 Eq

. In 201 3 , total methane emissions from MSW
landfills represented approximately 1 5 percent of the total methane emissions from all sources
and account for about 1. 5 percent of all CO 2 - equivalent (CO 2 Eq. ) emissions in the U.S., with
landfills being the third largest contributor to U.S. anthro pogenic methane emissions ( EPA,
201 5 ).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 benef its of methane emission s reductions expected from the proposed guidelines for existing MSW landfills using estimates of the social cost of methane (SC

- CH 4 ), a metric that estimates the monetary value of impacts associated with marginal changes in methane e missions 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 h eating and increased costs for air conditioning. The SC

- CH 4 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 CO 2 (SC

- CO 2 ), provides important context for understanding the Marten et al. SC

- CH4 estimates. Estimates of the SC

- CO 2 have been used by EPA and other federal agencies to value the impacts of CO 2 emissions changes in benefit cost analysis for GHG

- related rulemakings since 2008. The SC

- CO 2 is a metric that estimates the monetary value of impacts associated with marginal changes in CO 2 emissions in a given year. Similar to the SC

- CH 4 , i t includes a wide range of anticipated climate impacts, such as net changes in agricultural productivity, propert y 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 CO 2 emissions, or the disbenefit from increasing emissions, in regulatory impact analyses.

The SC

- CO 2 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

- CO 2 estimates and recommended four global values for use in regulatory analyses. The SC

- CO 2 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,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

- CO 2 Technical Support Document (2010 SC

- CO 2 TSD) provides a complete di scussion of the methods used to develop these estimates and the current SC

- CO 2 TSD presents and discusses the
2013 update (including recent minor technical corrections to the estimates )

. 17

The 2010 SC

- C O 2 TSD noted a number of limitations to the SC

- CO 2 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 assump tion s regarding risk aversion. Current ly 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 CO 2 reducti ons to inform
benefit

- cost analysis; see RIA of this rule and the SC

- CO 2 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

- CO 2 estimates from stakeholders through a range of channels, including pu blic comments on Agency rulemakings that use the SC

- CO 2 in supporting analyses and through regular interactions with stakeholders and research analysts implementing the SC

- CO 2 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 201 0 SC

- CO2 TSD and the current TSD are available at: https://www.whitehouse.gov/omb/oira/social

cost

- of

- carbon

.4

- 7 used to develop the SC

- CO 2 estimates through a separate comment period that ended on February 26, 2014.

After careful evaluation of the full range of comments, the interagency wo rking group
continues to recommend the use of the SC

- CO 2 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 Academ ies of Sciences , Engineering, and
Medicine to ensure that the SC

- CO 2 estimates continue to reflect the best available scientific and economic information on climate change. The 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

- CO 2 estimates in future updates.

Concurrent with OMB’s publication of the response to comments on SC

- CO 2 and
announcement of the 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 SC

CO 2 estimates are one dollar less than the mean SC

- CO 2 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 slightl y larger, as those estimates are heavily influenced by the results from the model that was affected by the indexing error.

The four SC

- CO 2 estimates are: $15 , $ 50 , $ 73 , and $1 5 0 per metric ton of CO 2 emissions in the year 202 5 (2012 dollars). 19 The first three values are based on the average SC

- CO 2 from the three IAMs, at discount rates of 5, 3, and 2.5 percent, respectively. Estimates of the SC

- CO 2 for several discount rates are included because the literature shows that the SC

- CO 2 is sensiti ve to assumptions about the discount rate, and because no consensus exists on the appropriate rate

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 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

- C O 2 values have been rounded to two significant digits. Unrounded numbers from the 2013 SCC TSD were adjusted to 2012$ and use d to calculate the CO 2 benefits.4

- 8 to use in an intergenerational context (where costs and benefits are incurred by different generations). The fourth value is the 95 th percentile of the SC

- CO 2 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

- CO 2 distribution. The SC

- CO 2 increases over time because future emissions are expected to p roduce 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

- CO 2 GHG emissions at the time the SC

- CO 2 estimates were developed. One
alternative approach to value methane impacts is to use the global warming potential (GWP) to
convert the emissions to CO 2 equivalents which are then valued using the SC

- CO 2 estimat es.

The GWP measures the cumulative radiative forcing from a perturbation of a non

- CO 2 GHG relative to a perturbation of CO 2 over a fixed time horizon , often 100 years

. The GWP mainly reflects differences in the radiative efficiency of gases and differenc es in their atmospheric lifetimes. While t he GWP is a simple, transparent, and well

- established metric for assessing the relative impacts of non

- CO 2 emissions compared to CO 2 on a purely physical basis
, there are several well

- documented limitations in usin g it to value non

- CO 2 GHG benefits, as discussed in the 2010 SCC TSD and previous rulemak ings (e.g., EPA 2012 b, 2012d )

. 20 In particular, s everal recent studies found that GWP

- weighted benefit estimates for methane are likely to be lower than the estimates d erived using directly modeled social cost estimates for these gases. Gas comparison metrics, such as the GWP, are designed to measure the impact of

non

- CO 2 GHG emissions relative to CO 2 at a specific point along the pathway from emissions to
monetized dama ges (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

.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

- CO 2 GHGs because it ignore s important nonlinear relationships beyond radiative forcing in the chain between emissions and damages. These can become relevant be cause gases have different lifetimes and the SC

- C O 2 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 prod uctivity due to higher atmospheric CO 2 concentrations included in the SC

- C O 2 woul d 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

con sistent with the assumptions underlying SC

- C O 2 e stimates in general, and the SC

- C O 2 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

- C O 2 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 prefe rence for earlier over later gains in utility and expectations regarding future levels of ec onomic growth. In the case of methane , which has a relatively short lifetime compared to CO 2 , the temporal independence of the GWP could lead the4

- 10 GWP approach to un derestimate the SC

- CH 4 with a larger downward bias under higher discount rates (Marten and Newbold 2012). 21

EPA sought public comments on the valuation of non

- CO 2 GHG impacts in previous rulemakings (EPA , 2012 b; EPA , 2012 d ) . In general, the commenters strongly encouraged EPA to incorporate the monetized value of non

- CO 2 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 o f the SC

- CH 4 to overcome those challenges.

EPA had cited several researchers that had directly estimated the social cost of non

- CO 2 emissions usi ng IAMs but noted that the number of such estimates was small compared to the large number of SC

- CO 2 estimate s available in the literature. EPA found considerable variation among these published estimates in terms of the models and input assumptions they employ (EPA , 2012 b ; EPA , 2012 d ). These studies differed in the emissions perturbation year, employed
a wide ra nge 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 soci al cost of non

- CO 2 GHG were consistent with the SC

- CO 2 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 in terim method of analysis until directly modeled social cost estimates for non

- CO 2 GHGs, consistent with the SC

CO 2 estimates developed by the IWG, were developed. EPA presented GWP

- weighted estimates in sensitivity analyses rather than the main benefit

- co st analyses.

Since then , a paper by Marten et al. (2014) has provided the first set of published SC

- CH 4 estimates in the peer

- reviewed literature that are consistent with the modeling assumptions underlying the SC

- CO 2 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

- CH 4 for near term perturbation years in cases whe re the SC

- CO 2 is based on a sufficiently low or steeply declining discount rate

. 22 Marten et al. (2014) also provided the first set of SC

- N 2 O estimates that are consistent with the assumptions underlying the SC

- CO 2 estimates.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 d evelop the SC

- CO 2 estimates. The a ggregation method involved distill ing the 45 distribution s of the SC

- CH 4 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 95 th 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 Fourt h Assessment Report (AR4, 20 07 ), including an adjust ment in
the radiative effic acy of methane to account for its role as a precursor for tropospheric ozone and stratospheric water

. T he se values represent the same ones used by in the IPCC in AR4 for calculating GWP s

. At the time Marten et al. developed their estimates of the SC

- CH 4 , 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 m ethane 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 CO 2 , changes in the lifetime estimate for methane, and changes in the correction fa ctor 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 choi ces 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 d one 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 CO 2 equivalency calculations, consistent with the GHG emission s inventories and the IPCC Fourth Assessment Report.4

- 12 Marten et al. (2014) discuss these estimates (SC

- CH 4 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 b etter basis for comparison (see Hope (2006), Waldhoff et al. (201 4 ), Marten and Newbold (2012)). Marten et al. found that in general the SC

- CH 4 estimates from their 2014 paper are higher than previous estimates. The higher SC

- CH 4 estimates are partially d riven by the higher effective radiative forcing due to the inclus ion of indirect effects
from methane emissions in their modeling. Marten et al., similar to other recent studies, also find that their directly modeled SC

- CH 4 estimates are higher than the GW P

- weighted estimates.
More detailed discussion of the SC

- CH 4 estimation methodology, results and a comparison to other published estimates can be found in Marten et al.

Table 4

- 2 Social Cost of CH 4 , 2012

– 2050 a [in 2012$ per metric ton] (Source: Marten et al., 2014 b )

Year SC

- CH 4 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

- CO 2 estimates described above. See 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 G ross Domestic Product ( US Department of Commerce, Bureau of Economic Analysis ), http://www.bea.gov/iTable/index_nipa.cfm Accessed 3/3/15.4

- 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

- CO 2 estimates. Specifically, the
SC

- CH 4 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

- CH 4 estimate for that year. To obtain a present value estimate, the monetized stream
of future non

- CO 2 benefits are discounted back to the analysis year using the same discount rate
used to estimate the social cost of the n on

- CO 2 GHG emission changes. In addition, the
limitations for the SC

- CO 2 estimates discussed above likewise apply to the SC

- CH 4 estimates, given the consistency in the methodology.

EPA recently conducted a peer review of the application of the Marten et al. (2014) non

CO 2 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, t he consistency of the estimates with the SC

CO 2 estimates, EPA’s characterization of the limits of the GWP

- approach to value non

- CO 2 GHG impacts, and the appropriateness of using the Marten et al. estimates in regulatory impact analyses. The reviewers agre ed with EPA’s interpretation of Marten et al.’s estimates; generally
found the estimates to be consistent with the SC

- CO 2 estimates; and concurred with the limitations of the GWP approach, finding directly modeled estimates to be more appropriate.
While ou tside of the scope of the review, the reviewers briefly considered the limitations in the
SC

- CO 2 methodology (e.g., those discussed earlier in this section) and noted that because the
SC

- CO 2 and SC

- CH 4 methodologies are similar, the limitations also apply to the resulting SC

CH 4 estimates. Two of the reviewers concluded that use in RIAs of the SC

- CH 4 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

- CO 2 and other economic analyses. All three reviewers encouraged continued improvements in the SC

- CO 2 estimates and suggested that as those improvements are realized they should also be reflected in
the SC

- CH 4 estimates, with one reviewer suggesting the SC

- CH 4 estimates lag this process. EPA supports continued improvement in the SC

- CO 2 estimates developed by the U.S. government and4

- 14 agrees that improvements in the SC

- CO 2 estimates should also be reflected in the SC

- CH 4 estimates . T he fact that the reviewers agree that the SC

- CH 4 estimates are generally consistent
with the SC

- CO 2 estimates that are recommended by OMB’s guidance on valuing CO 2 emissions
reductions leads EPA to conclude that use of the SC

- CH 4 estima tes is an analytic al 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

- CO 2 GHG impacts in its rulemakings, the Agency has used the Marten et al. (2014) SC

- CH 4 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 t hese directly modeled estimates, from the peer

- reviewed literature, for the social cost of non

- CO 2 GHG.

The methane benefits calculated using Marten et al. (2014) are presented below in Table
4

- 3 for 2025. Apply ing 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

- CH 4 at the 3 % discount rate results in an estimate of about $ 6 60 million in 2025.

Table 4

- 3 Estimated Global Benefits of CH 4 Reductions in 2025* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 values represent only a partial accounting of climate impacts.
While t he vast majority of this proposal’s climate

- related benefits are asso ciated with methane reductions, a dditional climate

- related benefits are expected from the proposal’s secondary air impacts, specifically, a net reduction in CO 2 emissions due to reduced demand for4

- 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 CO 2 reductions with the SC

- CO 2 estimates described in this section yields benefits that vary by discoun t rate and range from about $ 3

. 6 million to approximately $ 36 m illion in 2025. For the proposed option, the mean SC

- CO 2 at the
3 % discount rate resu lts in an estimate of about $ 12 million in 2025, which is about 2 percent of
the estimated methane benefits in 2025 (average SC

- CH 4 , 3 percent discount rate).

Table 4

- 4 Estimated Global Benefits of Net CO 2 Reductions in 2025* (in millions, 2012$)

Metric tonnes of net CO 2 reduced Discount rate and statistic 5% (average) 3% (average) 2.5% (average) 3% (95 th percentile) Alternative Option 2.5/40 10 2 ,000 $1.5 $5.0 $7.5 $15 Proposed Option 2.5/34 2 38 ,000 $3.6 $12 $18 $36 Alternative Option 2.0/34 2 38 ,000 $3.6 $12 $18 $36
*The SC

- CO 2 values are dollar

- year and emissions

- year specific. SC

- CO 2 values represent only a partial accounting of climate impacts.
Finally, in addition to the CO 2 impacts discussed above, there is a small increase in CO 2 emissions resulting from flaring of methane in response to this rule. We are not estimating the

mon etized disbenefits of these secondary emissions of CO 2 because much of the methane that would have been released in the absence of the flare would have eventually oxidized into CO 2 in the atmosphere. Note that the CO 2 produced from the methane oxidizing in the atmosphere is not
included in the calculation of the SC

- CH 4
. However, EPA does recognize that because the growth rate of the SC

- CO 2 estimates are lower than their associated discount rates, the estimated impact of CO 2 produced in the future
from oxid ized methane would be less than the estimated impact of CO 2 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 IPC C AR4, the

26 The reduced demand for electricity from the grid more th an offsets the additional energy demand required to operate the control system and the by

- product emissions from the combustion of LFG.4

- 16 disbenefits associated with destroying one metric ton of methane and releasing the CO 2 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 CH 4 depending on the S C

- CO2 value or 0.7 percent to 0.9 percent of the SC

- CH 4 estimates per metric ton for 2020. The analogous estimates for 2025 are $7 to $34 per metric ton CH 4 or 0.8 percent to 1.0 percent of the SC

- CH 4 estimates per metric
ton for 2025. 27 While EPA is not ac counting for the CO 2 disbenefits at this time, we request comment on the appropriateness of the monetization of such impacts using the SC

- CO 2 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 tro pospheric ozone formation ( EPA,
20 13 ). 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 NO X 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, ther efore, 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 ru ral 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 shorter

lived ozone precursors such as NO X , carbon monoxide, or non

- methane VOC has larger local

27 To calculate the disbenefits associated the complete destruction of a ton of CH 4 through flaring, EPA took the differe nce between the SC

- CO 2 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

- CO 2 . This value was then scaled by 44/16 to account for the relative mass of car bon contained in a ton of CH 4 versus a ton of CO 2 . The value of the SC

- CO 2 8.7 years after flaring was estimated by linearly interpolating between the annual SC

- CO 2 estimates reported in the TSD and inflated to 2012 dollars.4

- 17 health benefits from greater reductions in local ozone concentrations (West and Fior e, 2005; West et al., 2006 ; Fiore et al. 2008; Dentener e t 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 wil l have on ozone concentrations at particular locations. However,
the global monetized benefit of ozone reduction due to methane mitigation have been estimated
in several studies (Anenberg et al.
, 2012; Shindell et al.
, 2012).

Recently, a paper was publishe d 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 climate and ozo ne effects of methane

A recent United Nations Environment Programme (UNEP) assessment provide d a comprehensive analysis of the health, climate, and agricultural benefits of measures to reduce methane, as well as black carbon, a component of fine particulat e matter that absorbs radiation (UNEP/WMO, 2011; Shindell et al., 2012). The UNEP assessment found that w hile reducing longer

- lived GHGs such as CO 2 is necessary to protect against long

- term climate change, reducing global methane and black carbon emission s would have global health benefits by reducing exposure to ozone and PM 2.5 as well as potentially slowing the rate of climate change4

- 18 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

- rela ted 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 agricu ltural impacts, were valued at $700 to $5,000 per metric ton. 28 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.

4.3 VOC as a PM 2.5 precursor
This rulemaking would reduce emissions of VOC, which are a precursor to PM 2.5. Most VOC emitted are oxidized to carbon dioxide ( CO 2 ) rather than to PM, but a portion of VOC
emission contributes to ambient PM 2.5 levels a s organic carbon aerosols ( EPA, 2009a). Therefore, reducing these emissions would reduce PM 2.5 formation, human exposure to PM 2.5 , and the incidence of PM 2.5 - related health effects. However, we have not quantified the PM 2.5 - 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 an thropogenic 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 amoun t of VOC emissions from this sector relative to the entire VOC inventory it is unlikely this sector has a large contribution to

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 S ection 4. 4 .1, since they include climate and agricultural impacts, a re 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 S ection 4. 2 .1 since they include health and agricultural benefits and use different assumptions for the Social Cost of Carbon.4

- 19 ambient secondary organic carbon aerosols. Photochemical models typically estimate secondary organic carbon from anthropogenic VOC emissions to be less than 0.1 μg/m 3

.
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 PM 2.5 benefits associated wit h reducing VOC emissions. Due to the high degree of variability in the responsiveness of PM 2.5 formation to VOC emission reductions, we are unable to estimate the effect that reducing VOC will have on ambient PM 2.5 levels without air quality modeling. Howe ver, we provide the discussion below for context regarding findings from previous modeling.

4.3.1 PM 2.5 health effects and valuation

Reducing VOC emissions would reduce PM 2.5 formation, human exposure, and the
incidence of PM 2.5 - related health effects. Reducing exposure to PM 2.5 is associated with significant human health benefits, including avoiding mortality and respiratory morbidity.
Researchers have associated PM 2.5 exposure with adverse health effects in numerous toxicological, clinical an d epidemiological studies ( EPA, 2009a). When adequate data and resources are available, EPA generally quantifies several health effects associated with exposure
to PM 2.5 (e.g., EPA , 2011 d ). These health effects include premature mortality for adults and infants, cardiova scular 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 q uantified these effects in previous benefits analyses, the scientific literature suggests that exposure to PM 2.5 is also associated with adverse effects on birth weight, pre

- term births, pulmonary function, other cardiovascular effects, and other respirato ry effects ( EPA, 2009a).

When EPA quantifies PM 2.5 - 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 suffic ient to allow differentiation of effect e stimates 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. This4

- 20 decision is su pported by the data, which are quite consistent in showing effects down to the
lowest measured levels of PM 2.5 in the underlying epidemiology studies.

Previous studies have estimated the monetized benefits

- per

- ton of reducing VOC
emissions associated wit h the effect that those emissions have on ambient PM 2.5 levels and the
health effects associated with PM 2.5 exposure (Fann, Fulcher, and Hubbell, 2009), and these estimates can provide useful context for this rulemaking. Using the estimates in Fann, Fulch er, 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 avail able from this dataset using alternate assumptions regarding the relationship between PM 2.5 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 pr esents 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

- designe d and extensively peer reviewed, and EPA provides the benefit estimates derived from expert opinions in Roman et al. (2008) as a ch aracterization of uncertainty. As shown in Table 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, 2012 b), 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

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) estima te. 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 t hese updates, please see Section 5.3 of the RIA for the final PM NAAQS (EPA, 2012c).4

- 21 would not lead t o 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 PM 2.5 , 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.4

- 22 Table 4

- 5 Monetized Benefits

- per - Ton Estimates for VOC based on Previous Modeling in 2015 (20 12 $)

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 assume d 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 u pdated 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.4

- 23 4.3.2 Visibility E ffects

Reducing secondary formation of PM 2.5 from VOC emissions would improve visibility throughout the U.S. Fin e 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 impairme nt 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 acti vities. Previous analyses ( EPA, 2006 b ; EPA, 201 1 d ; EPA, 2011a; EPA, 2012c ) show that visibility benefits are a significant welfare benefit category. Without air quality modeling, w e are unable to estimate visibility related benefits, nor are we able to determine whether VOC emission reductions would be likely to have a signifi cant 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 precursor s 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 (NO X ), 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 em itted from vegetation tend to be more important compounds in non

- urban vegetated areas ( EPA, 20 13 ). 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 th e pollu tant targeted for control ( EPA, 2010 a ; 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 g rowth

. Third, the impact of reducing VOC emissions is spatially heterogeneous depending on local air4

- 24 chemistry. Urban areas with a hig h population concentration are often VOC

- limited, which means that ozone is most effectively reduced by lowering VOC . R ural areas and downwind
suburban areas are often NO X - limited, which means that ozone concentrations are most effectively reduced by lowering NO X emissions, rather than lowering emissions of VOC

. Between these areas, ozone is relatively insensitive to marg inal changes in both NO X 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). R esearchers have associated ozone exposure with adverse health effects in numerous toxicological, clinical an d epidemiological studies ( EPA, 20 13 ). When adequate data and resources are available, EPA generally quantifies several health effects associated wit h exposure to ozone (e.g., EPA , 2010a ; EPA, 2011a ). These health effec ts include respiratory morbidity such as asthma attacks, hospital and emergency department visits, school loss days, as well as premature mortality. T he scientific
literature is also suggestive that exposure to ozone is also associated with chronic respira tory 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 fr om reduced ozone exposure ( EPA, 2011 b ). 31 After updating the currency year to 2012$, t his implies a
benefit

- per

- ton for ozone of $2 6 0 to $1,0 7 0 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 NO X emissions, which make it difficult to isolate the benefits attribu table to VOC reductions.4

- 25 analysis of industrial boilers, EPA published the Integrated Science Assessment for Ozone ( EPA, 2013), the Hea lth 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 av ailable. 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 benefit

per

- 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 estimate s 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 p ublished literature ( EPA, 2013 a ). 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 o f 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 crop s, visible foliar injury, species composition shift, and chan ges 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, t ropospheric 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 globa l 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) study4

- 26 reports that the threefold increase in groun d level ozone during the past 100 years makes it the third most important contributor to human contributed climate change behind CO 2 and methane

. This quantifiable influence of ground level ozone on climate lead s to increases in global surface temperature and changes in hydrological cycle s

.

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 th at most Americans are exposed to ambient concentrations of air toxics at levels that have the potential to cau se 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 toxi cs 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/nata2005/4

- 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 cont ribute 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 contribut e almost equal portions of the remaining
cancer risk.

Noncancer health effects can result from chronic, 36 subchronic, 37 or acute 38 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.
R esults 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 haz ard from the assessment. It is important to note that l arge 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. Thus, it is important to account for the toxicity and exposure, as well as the mass of the targeted emissions.

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 individ ual 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 approximatel y 90 days to 2 years in typically used laboratory animal species).

37 Defined in the IRIS database as r epeated 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.4

- 28 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

- 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

an alyses, 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 estim ate of risk.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 deleter ious noncancer health effects during a lifetime. As part of the second prospective analysis of the benefits and costs of the C lean 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 re sult 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 h ave long latency periods” ( EPA

- SAB, 2008 ).

In 2009, EPA convened a workshop to address the inherent complexities, limitations, and
uncertainties in curre nt 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 avoide d 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 des cribe the health effects associated with the main HAP
of concern from the MSW landfill sector : benzene, eth ylbenzene, 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 no t possible to estimate the tons of each individual HAP that would be reduced.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 da tabase 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 bon e 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 b lood disorders, such as preleukemia and aplastic anemia, have also been associated with long

- term exposure to benzene. 44 , 45

39 U.S. Enviro nmental 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: ht tp://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 Can cer, 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 chemical s 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/1618 3

. 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

- 554.4

- 32 4.5.2 Ethylbenzene

Ethylbenzene is a major industrial chemical produced by alkylation of benzene. The pure
chemical is used almost exclusive ly 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
i rritation 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, li ver, 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 b irth 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 studi es 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 Canc er (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 inc idences of renal tubule adenoma or carcinoma in male rats and renal tubule adenoma in females. NTP (1999) also noted increases in

46 Maltoni C, Conti B, Giuliano C and Belp oggi 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 lo ng

- term experimental carcinogenicity studies of the effects of gasoline, correlated fuels, and major gasoline aromatics on rats. Annals NY Acad Sci 837:15

- 52.

48 International 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 (Inhalat ion 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.4

- 33 the incidence 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 Toluene 50

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 tol uene was not carcinogenic in adequate inhalation cancer bioassays of rats and mice exposed for life

. 51 , 52 , 53 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 classifiabl e 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 rat s 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 H ealth 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; e t 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 monograp hs 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

- 864.4

- 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 inc lude 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 developmen tal 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 occupation ally 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 Chloride 56

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 n ervous system effects (CNS), such as dizziness, drowsiness, and headaches in humans. Chronic (long

term) exposure to vinyl chloride through inhalation and oral exposure in humans has resulted in liver damage. Cancer is a major concern from exposure to viny l 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 Prote ction Agency. Integrated Ris k Information System (IRIS) on Vinyl Chloride. 2000.

Available online at http://www.epa.gov/iris/subst/1001.htm

.4

- 35 EPA has classified vinyl chloride as a Group A, “ human carcinogen” . IARC has classified vinyl
chloride as carcinogenic to hu mans (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 t he EPA is assessing impacts in year 2025 as a representative year for th e 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 t he 2020 snapshot year.

Table 4

- 6 Estimated Global Benefits of CH 4 Reductions in 202 0 * (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rat e and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 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 o f 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/iris4

- 36 Table 4

- 7 presents the climate benefits of the alternatives in the 2030 snapshot year.

Table 4

- 7 Estimated Global Benefits of CH 4 Reductions in 2030* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 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 CH 4 Reductions in 2040* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 values represent only a partial accounting of climate impacts.

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- 1 5 ECONOMIC IMPACT ANA LYSIS AND DISTRIBUTI ONAL ASSESSMENTS

5.1 Introduction

This chapter of the RIA includes three sets of discussion s related to the proposed
Emission Guidelines for MSW landfills:

• Economic Impact Analysis

• Employment Analysis

• Small Business Analysis
Th e s e discussion s are intended to assist the reader of the RIA to better understand the potential economic impacts of t he proposal, though data and methodological limitations prevented a complete assessment of the economic impacts of the proposed Emission Guide lines

.

5.2 Economic Impact Analysis

The i mpacts 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
retain s 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 syste m, there are inc remental costs associated with capturing and/or utilizing the additional LFG under this more stringent option. These costs were shown in Chapter 3 o f 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 . H ouseholds 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, affect ed
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 t he5

- 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 ov er 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 abl e 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 disc ussed 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 approxi mately 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 i mpacts of the options on the supply and demand for MSW landfill
services. However, b ecause of the relative ly 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 o verall 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 interest5

- 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 requiremen ts 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 orde r to ensure that the way EPA characterizes the employme nt 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 wast e 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. LF G 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

59 Executive 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).5

- 4 lack of appropriate economic parameter s 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 c hanges 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 d escribed 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 in crease 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 a re 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 (E PA, 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 re venue 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 owne d 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
collect ion 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 collection5

- 5 trucks into a single shipment, communities and waste management co mpanies 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, de posits 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, administrati ve staff, weigh scale operators, salespersons, and landfill operations

managers. For employment estimates related to public ly

- 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, becau se 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 Busi ness 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 Statis tics, 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/methodo logy.htm

.5

- 6 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 (E PA, 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 resp onse 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 e conomic 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 e conomy 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 po sitive 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 equ ipment) 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/cgi

bin/sssd/naics/naicsrch?chart_code=56&search=2012%20NAICS%20Search >.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 sector s 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. Econo mic 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 labo r’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 r egulation 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 c hanges 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 t echnology 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
eit her 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 equipmen t

— 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 in5

- 8 most cases there is no scient ifically 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 producti on 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 addit ional 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 demons trate 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 secto r 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 (NO X ) 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 stri ngent 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 Ind ustry

- Level Perspective. Journal of Environmental Economics and Management 43(3):412

- 436.5

- 9 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, t hey 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 fairl y 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 employmen t in four highly regulated sectors (pulp and paper, plastics, steel, and petroleum refining). Thus, in contrast to Berman and Bui (2001), t his study identifies employment effects by examining differences in abatement expenditures rather than geographical d ifferences 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 considere d 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 landf ill 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 t he 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 in clude 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.5

- 10 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 en vironmental 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 regula ted 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 fra mework 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 h ere 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 earl y 1990’s) are quite different than
those in th e 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 withi n 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 fr om compliance with this rule can be obtained can be found in Chapter 3 of this RIA.5

- 11 The preceding sections have outlined the challenges associated with estimating net employment effects in the regulated secto r 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 benef its 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 (SA B) 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 reg ulated 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.

Beca use 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 op tion, 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 m inimal 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, executi ves, 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 o ther 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.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 t he 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 s tatute , 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 t he 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 co de 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 dist r ict 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 certif ies 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,
E mission G uidelines 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 E mission G uidelines are promulgated, states establ ish 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 American5

- 13 Trucking Associations v. EP A , 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 th e 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 Ser vices 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 1 970 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

- 952.5

- 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

. 201 2

. Quarterly Census of Emplo yment 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&yea r=2012&qtr =1&own=5&ind=562&supp=1 >.

U.S. Bureau of Labor Statistics

. 201 3

. Quarterly Census of Emplo yment 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/tableservice s/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.
< ht tp://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/r0 2002.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 Res ponse (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, 2012.5

- 15 U.S. Environmental Protection Agency ( EPA). 2014 . “Landfill

- level data only (all landfills)

– updated August 2014.” LMOP, Cl imate Change Division, U.S. EPA.
< http://www.epa.gov/lmop/projects

- candidates/index.html >.
Walker, Reed. 2011 . “ Environmental Reg ulation and Labor Reallocation. ” American Economic Revie w: 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, 2015.6

- 1 6 COMPARISON OF BENEFI TS AND COST

6.1 Introduction

The EPA compared the monetized methane

- related climate benefits and CO 2 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 larg er 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 o f air pollutants, includ ing 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, t he 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 CO 2 co

- benefits are estimated to range from $ 3.6 million to $ 36 milli on (2012$) 69 in 2025; estimated CO 2 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, t he net
benefits , using a 7% discount rate, are expected to be $ 2 6 0 million to $ 1.7 b illion , with a central estimate of $ 620 million

. These results are summarized in Table 6

- 1

.

68 The range of estimates reflects four SC

- CH 4 estimates: the mean across all mod els and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion. 69 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and t he 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.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 Benefits 1 $ 31 0 million

- $ 1.7 billion
Monetized CO 2 co

- benefits 1 $ 3.6 million

- $ 36 million
Total Costs 2 $ 35 million $ 4 7 million Net Benefits $2 7 0 mi llion

- $1.7 billion $ 2 6 0 million

- $1.7 billion

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 2,770 Mg NMOC/yr reduce d Health effects of HAP exposure from 2,770 Mg NMOC/yr reduce d 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 2 38 ,000 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of est imates reflects four SC

- CH 4 and four SC

CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th 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 impr ovements 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 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.

6.3 Net Benefits of the Alternate Standards

F or the less stringent 2.5/40 option, t he 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 CO 2 co

- benefits are estimated to range from $ 1.5 million to $ 15 million (2012$) 71 in 2025; estimated CO 2 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

- CH 4 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion. 71 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.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, t he net benefits , when using a 7% discount rate, would be expected to be $ 1 6 0 million to $ 1.1 b illion , 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 Benefits 1 $ 190 million

- $1. 1 billion
Monetized CO 2 co

- benefits 1 $ 1.5 million

- $ 15 million
Total Costs 2 $ 20 million $ 27 million Net Benefits $170 million

- $1.1 billion $1 6 0 million

- $1.1 billion

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 1,720 Mg NMOC/yr reduce d Health effects of HAP exposure from 1,720 Mg NMOC/yr reduce d 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 1 02 ,000 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of estimates reflects four SC

- CH 4 and four SC

CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See Section 4.2 for a complete discus sion.
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 accomplishe d 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.
For the more stringent 2.0/34 option, t he 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

- CH 4 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.6

- 4 estimated to be $ 720 m illion ( 2012$) in 2025 using a 3% discount rate. The CO 2 co

- benefits are estimated to range from $ 3.6 million to $ 36 million (2012$) 73 in 2025; estimated CO 2 benefits are $ 12 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7%
discount rate the additiona l 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, t he net benefits , when using a 7% discount rate, would be expected to be $ 290 million to $ 1.9 b illion , with a central estimate of $ 6 9 0 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 Benefits 1 $ 340 million

- $1

. 9 billion
Monetized CO 2 co

- benefits 1 $ 3.6 million

- $ 3 6 million
Total Costs 2 $38 million $ 51 million Net Benefits $3 0 0 million

- $1

. 9 billion $ 29 0 million

- $1

. 9 billion

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 3,040 Mg NMOC/yr reduce d Health effects of HAP exposure from 3,040 Mg NMOC/yr reduce d 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 2 38 ,000 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of estimates reflects four SC

- CH 4 and four SC

CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discoun t 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 impr ovements 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 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.

73 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.7

- 1 7 SUPPLEMENTAL NSPS PR OPOSAL

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 m 3 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 propos al 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 t he 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 beco me 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.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: d esi gn 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

• P roposed Option 2.5/ 40 : d esign 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

r educed to 40 Mg NMOC/year

.
Consistent with the Methane Strategy that was developed as part of the President’s Climate
Action Plan
, when p reparing 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

capa city 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 s ubpart XXX. In addition to responding to feedback received during the NSPS proposal comment period , the EPA beli eves consistency
between the thresholds in the e mission g uidelines and the NSPS is important, given that an existing landfill can modify and become subject to the proposed s ubpart 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 s ubpa rt XXX for new landfills and s ubpart 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 mo dification by allowing them to comply with less rigorous requirements. In7

- 3 addition, two regulatory agencies requested harmonizing requirements for existing and new landfills between the current regulations in s ubpart WWW and the new proposed s ubpart 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: d esign capacity retaine d 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

• P roposed Option 2.5/ 34 : d esign 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

r educed 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 compar ed 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 emiss ions 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 >.7

- 4 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 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

- 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 co ntrol. 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 CO 2 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 CO 2 Eq.) compared to the baseline, while the more stringent alternative option 2.0/34 would result in emissions reduction s of 400 Mg NMOC and 62,500 Mg methane (1,600,000 Mg CO 2 Eq.) compared to the baseline. The emission reductions are
summarized in Table 7

- 2

.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 CO 2 - equivalents )*

Current NSPS = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 11,600 1,834,000 45,900,000

Increment al 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 CO 2 - equivalents. Minor secondary air impacts are not included in th is 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 c ontrol in 2025 is estimated to be $9.0 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 $8.5 million ( Table 7

- 3 ). The cost
of control for the less stringent alternative option 2.5/40 is estimated to be $6.6 million, which is estimated to be supplemented by approximately $0.65 million in reduced reven ue from
beneficial

- use projects, so the net cost is estimated to be approximately $7.4 million

. The cost of
control for the more stringent alternative option 2.0/34 is estimated to be $10.7 million, of which approximately $0.6 million is estimated to be of fset 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.7

- 6 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

- u se Projects Net Cost

Current NSPS = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 1.3 322 262 61

Incremental values versus the current NSPS Alternative option 2

. 5 /40 0.06 6.6

- 0.65 7.4 P roposed option 2.5/ 34 0.08 9.0 0.6 0 8.5 Alternative option 2.0/ 34 0.11 10.7 0.6 0 10 .2 Note: A ll 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 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 ( Table 7

- 4 ). The cost of
control for the less stringent alternative option 2.5/40 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

. 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 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 indust ry 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
i ncreased revenue from energy generation.7

- 7 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 1.2 404 382 22

Incremental values versus the current NSPS Alternative option 2

. 5 /40 0.06 8 1.6 6.4 P roposed 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: A ll 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 ( T able 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 repre sents 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

- 5 ). The average cost

- effe ctiveness 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 reduct ions is $176 per Mg methane under the baseline and7

- 8 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

- effectiven ess (2012$ per Mg )

NMOC Methane Methane (in CO 2 - equivalents )* Net Cost b /ton Total Cost /ton Net Cost b /ton Total Cost /ton Net Cost b /ton Total Cost /ton

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 5,271 27,800 33.5 176 1.3 7. 1

Incremen tal 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 CO 2 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 new or modified MSW landfills

. By lowering the current
N MOC 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. V OC emissions are precursors to both fine particulate matter (PM 2.5 ) 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 other7

- 9 welfare effects

. As with the proposed emissions guidelines, t he only categor ies of benefits
monetized for the proposed NSPS are methane

- related and CO 2 - related climate effects. While
the methane

- related climate effects are positive as with the proposed emissions guidelines, for the proposed NSPS there are small CO 2 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 (PM 2.5 ), 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 im pacts 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
S ection 4.2 of this RIA. Apply ing the approach discussed in that sectio n to the CH 4 reductions estimated for this proposal, the 2025 methane benefits vary by discount rate and range from about $ 36 million to approximately $2 10 m illion; for the proposed option, the mean SC

- CH 4 at the 3% discount rate results in an estimate of about $ 78 million in 2025. These benefits are presented below in Table 7

- 6

.7

- 10 Table 7

- 6 Estimated Global Benefits of CH 4 Reductions in 2025* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th percentile)

Alternative Option 2.5/40 0.044 1.1 $32 $67 $86 $180 Proposed Option 2.5/34 0.051 1.3 $3 6 $78 $100 $210 Alternative Option 2.0/34 0.063 1.6 $4 4 $95 $120 $25 0 *The SC

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 values represent only a partial accounting of climate impacts.

However, there are climate

- related dis benefits that are expected from the proposal’s secondary air impacts, specifically, a net increase in CO 2 emissions. These disbenefits arise
because mor e 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 CO 2 increase s with the SC

- CO 2 estimates also described in S ection
4.2 yields dis benefits that vary by discoun t rate and range from about $0.01 million to approximately $0.10 m illion in 2025. For the proposed option, the mean SC

- CO 2 at the 3 %
discount rate resu lts in an estimate of about $0.03 million in 2025.

Table 7

- 7 Estimated Global Disbenefits of Net CO 2 Increases in 2025* (in millions, 2012$)

Metric tonnes of net CO 2 increased Discount rate and statistic 5% (average) 3% (average) 2.5% (average) 3% (95 th percentile) Alternative Option 2.5/40 11,000 $0.17 $0.5 5 $0.8 1 $1. 6 Proposed Option 2.5/34 670 $0.010 $0.03 3 $0.049 $0.10 Alternative Option 2.0/34 2,000 $0.030 $0.10 $0.1 4 $0.29 *The SC

- CO 2 values are dollar

- year and emissions

- year specific. SC

- CO 2 values represent only a partial accounting of climate impacts.

75 As in the case of the proposed Emissions Guidelines, there is an additional CO 2 impact, specifically a small increase in CO 2 emissions resulting from flaring of methane in response to this rule. We are not estimating the monetized disbenefits of these secondary emissions of CO 2 because much of the methane that would have been released in the absence of the flare would h ave eventually oxidized into CO 2 in the atmosphere. See Section 4.2.1 for more discussion.7

- 11 7.4 Economic Impacts

7.4.1 Economic Impact Analysis

As was discussed in S ection 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 indu stry as was discussed in Chapter 2 and S ection 5.2, as well as the lack of appropriate economic parameters or model, the
EPA is unable to estimate the i mpacts of the options on the supply and demand for MSW landfill
services. However, b ecause 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 S ection 5.3, and is relevant for the proposed NSPS a s well as the proposed emissions guidelines.

7.4.3 Small Business Impacts Analysis

As discussed in S ection 5.4, t he 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 subs tantial number of small entities. Small entities include small businesses, small governmental jurisdictions, and
small not

- for

- profit enterprises.7

- 12 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 :

SSSSSSSSSS TT TT ii = TTTTTT AAAAAAAA AAAA AA CC CCCC aa CC ii TTTTTT RR RR ii
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 SBREFA 76 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/r faguidance11

- 00

- 06.pdf>7

- 13 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 a ppear 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 milli on 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 1 3 1 3 1 3 1 3 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 CO 2 co

- benefits
of the proposed NSPS for new or modified MSW landfills against the estimated annualized costs

77 U.S. SBA, Office of Advocacy. A Guide for Government Agencies, How to Comply with the Regulatory Flexibility Act, Implementing the President’s Small Business Agenda and Executive Order 13272, Ju ne 2010

.7

- 14 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, t he monetized methane

- related climate benefits are estimated to range from $ 36 million to $ 210 m illion (2012$) 78 in 2025 ; these benefits are estimated to be $ 78 million ( 2012$) in 2025 using a 3% discount rate. The CO 2 dis benefits are estimated to range from $ 0.01 million to $ 0.10 million (2012$) 79 in 2025; estimated CO 2 dis benefits are $ 0.033 million (2012$) in 2025 using a 3% discount rate. Under the proposed option 2.5/34, when using a 7% disco unt 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, t he net benefits in 2025 , when using a 7% discount rate, are expected to be $28 million to $ 200 m illion , with a central estimate of $69 million

. These results are summarized in Table 7

- 9.

78 The range of estimates reflects four SC

- CH 4 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion. 79 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.7

- 15 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 Benefits 1 $36 million

- $210 million
Monetized CO 2 disbenefits 1 $0.010 million

- $0.10 million
Total Costs 2 $7.1 million $ 8.5 million Net Benefits $29 million

- $200 million $ 28 million

- $200 million

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 300 Mg NMOC/yr reduce d Health effects of HAP exposure from 300 Mg NMOC/yr reduce d Visibility impairment Vegetation effects

1 Monetized benefits include the climate

- related benefits associated with the reduction of 51,4 00 Mg/yr methane, valued using the social cost of methane
, and the net increase of 665 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of estimates reflects four SC

- CH 4 and four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. S ee S ection 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 accomplishe d 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.

7.7 Net Benefits of the Alternate Standards

For the less stringent 2.5/40 option, t he monetized methane

- related climate benefits are estimated to range from $ 31 million to $ 180 m illion (2012$) 80 in 2025 ; these benefits are
estimated to be $ 67 million ( 2012$) in 2025 using a 3% discount rate. The CO 2 dis benefits are estimated to range from $ 0.17 million to $ 1.6 million (2012$) 81 in 2025; estimated CO 2 dis benefits are $ 0.55 million (2012$) in 2025 using a 3% discount rate. Under this option, when

80 The range of estimates reflects four SC

- CH 4 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion. 81 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.7

- 16 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, t he net benefits
, when using a 7% discount rate, would be expected to be $23 million to $ 170 m illion in 2025, with a primary estimate of $59 million

. These results are summarized in Table 7

- 10

.7

- 17 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 R ate 7% Discount Rate
Monetized Methane

- related Benefits 1 $31 million

- $180 million
Monetized CO 2 disbenefits 1 $0.17 million

- $1.6 0 million
Total Costs 2 $6.4 million $ 7.4 million Net Benefits $24 million

- $170 million $ 23 million

- $170 million

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 300 Mg NMOC/yr reduce d Health effects of HAP exposure from 300 Mg NMOC/yr reduce d Visibility impairment Vegetation effects

1 Monetized benefits include the climate

- related benefits associated with the reduction of 44,4 00 Mg/yr methane, valued using the social cost of methane
, and the net increase of 11,000 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of estima tes reflects four SC

- CH 4 and four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.
2 The engineering compliance costs are annualized and include estimated revenue from el ectricity 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 accomplishe d 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.
For the more stringent 2.0/34 option, t he monetized methane

- related climate benefits are estimated to range from $ 44 million to $ 25 0 m illion (2012$) 82 in 2025 ; these benefits are estimated to be $ 95 m illion (2012$) in 2025 using a 3% discount rate. The CO 2 dis benefits are estimated to range from $ 0.03 million to $ 0.29 million (2012$) 83 in 2025; estimated CO 2 dis benefits are $ 0.10 million (2012$) in 2025 using a 3% discount rate. Under this option, when using a 7% discount rate the add itional 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, t he net benefits
,

82 The range of estimates reflects four SC

- CH 4 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion. 83 The range of estimates reflects four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 4.2 for a complete discussion.7

- 18 when using a 7% discount rate, would be expected to be $34 million to $ 24 0 m illion in 2025,
wi th 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 Benefits 1 $44 million

- $25 0 million
Monetized CO 2 disbenefits 1 $0.03 million

- $0.29 million
Total Costs 2 $8.6 million $ 10.0 million Net Benefits $35 million

- $24 0 million $ 34 million

- $24 0 million

Non

- monetized Benefits 3 Health effects of PM 2.5 and ozone exposure from 400 Mg NMOC/yr reduce d Health effects of HAP exposure from 400 Mg NMOC/yr reduce d Visibility impairment Vegetation effects

1 Monetized benefits include the climate

- related benefits associated with the reduction of 62,5 00 Mg/yr methane, valued using the social cost of methane
, and the net increase of 1,970 Mg/yr of CO 2 , valued using the social cost of carbon

. The range of estimates reflects four SC

- CH 4 and four SC

- CO 2 estimates: the mean across all models and scenarios using a 2.5 percent, 3 percent, and 5 percent discount rate, and the 95 th percentile of the pooled estimates from all models and scenarios using a 3% discount rate. See S ection 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 accomplishe d 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.

7.8 Alternative Years of Analysis

While t he EPA is assessing impacts in year 2025 as a representative year for th e landfills NSPS for new or modified MSW landfills, the quantity and composition of landfill gas does change over the lifeti me 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.
Tables 7

- 12 and 7

- 13 present the emissions reductions and c ompliance costs, respectively, of the alternatives in the 2020 snapshot year.7

- 19 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 CO 2 - equivalents )*

Current NSPS = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 10,100 1.6 39.9

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 106 294 251 42.0

Incremental values versus the current NSPS Alternative option 2

. 5 /40 13 13.2 6.5 6.7 P roposed option 2.5/ 34 16 15.9 8.3 7.6 Alternative option 2.0/ 34 20 17.5 8.3 9.3 Note: A ll 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.7

- 20 Table 7

- 14 Estimated Annual Average Emissions Reductions in 2030 for the Baseline and Alternative Options
A nnual Average Reduction (Mg )

NMOC Million Methane Million Methane (in CO 2 - equivalents )*

Current NSPS = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 12,200 1.9 48.1

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 115 331 258 74.0

Incremental values versus the current EG Alternative option 2

. 5 /40 7 3.8

- 0.5 4.3 P roposed option 2.5/ 34 12 5.9

- 1.0 7.0 Alternative option 2.0/ 34 16 7.6

- 1.0 8.6 Note: A ll total are independently rounded and may not sum. Costs do not include testing and monitoring costs.7

- 21 Tables 7

- 1 6 and 7

- 1 7 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 CO 2 - equivalents )*

Current EG = 2.5 million Mg and m 3 design capacity and 50 Mg/yr NMOC B aseline 11,600 1.8 45.7

Increment al 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 CO 2 - equivalents. Secondary CO 2 emission reductions are not included in th is 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 m 3 design capacity and 50 Mg/yr NMOC B aseline 107 321 228 93.0

Incremental values versus the current EG Alternative option 2

. 5 /40 7 5.0

- 0.4 5.3 P roposed option 2.5/ 34 12 11.6 3.2 8.4 Alternative option 2.0/ 34 13 12.0 3.2 8.7
Note: A ll 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.7

- 22 Table 7

- 18 Estimated Global Benefits of CH 4 Reductions in 2020 * (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

re duced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 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 CH 4 Reductions in 2030* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 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 CH 4 Reductions in 2040* (in millions, 2012$)

Million metric tonnes of CH 4 reduced Million metric tonnes of

CO 2 - equivalent

reduced Discount rate and statistic

5% (average) 3% (average) 2.5% (average) 3% (95 th 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

- CH 4 values are dollar

- year and emissions

- year specific. SC

- CH 4 values represent only a partial accounting of climate impacts.8

- 1 8 STATUTORY AND EXECUT IVE O RDER 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),
th is 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 additio n, the EPA prepared this RIA of the potential costs and benefits associated with this action. For the proposed Emission
Guidelines , t he monetized methane

- related climate benefits are estimated to range from $ 310 million to $ 1.7 billion (2012$); these benef its are estimated to be $ 660 million ( 2012$) in 2025 using a 3% discount rate. The CO 2 co

- benefits are estimated to range from $ 3.6 million to $ 36 million (2012$) in 2025; estimated CO 2 benefits are $ 12 million (2012$) in 2025 using a 3%
discount rate. Un der 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, t he net benefits are expected to be $ 2 6 0 million to $ 1.7 b illion
, 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 pr oposed NSPS is also economically significant . For the proposed rule, t he monetized methane

- related climate benefits are estimated to range from $ 36 million to $ 210 m illion (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 CO 2 dis benefits are estimated to range from $ 0.01 million to $ 0.10 million (2012$) in 2025 , depending on the discount rate ; estimated CO 2 dis benefits are $ 0.033 million (2012$) in 2025 using a 3% d iscount 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 be8

- 2 $ 7.1 million. Thus, t he net benefits in 2025 a re expected to be $28 million to $ 200 m illion , 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 i s 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 se ction 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 resp ond : 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 a nd 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).8

- 3 Total estimated cost : $41,755,793 (per year), which includes annualized capita l 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 sup plemental 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 i n 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 app roval 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, b ecome 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 resu lt, 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 b riefly summarized
here.

Respondents/affected entities : Municipal solid waste landfills that commence construction, reconstruction, or modification after July 17, 2014.8

- 4 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 : $6,70 1,401 (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 impac ts 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 th at 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 f ield.8

- 5 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 wil l not impose any requirements on small entities. Specifically,
E mission G uidelines 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 o f 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 th e 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 entiti es).

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 percen t 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 requi rements 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, the8

- 6 EPA generally must prepare a written statement, including a cost

- benefit analy sis, 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 o bjectives 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 devel opment 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 m illion 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 landfil ls . 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 S ection 7 .5 under Federalism consultations.8

- 7 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 recons tructed 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 implica tions.” “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 o f 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

stat es, 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 represent atives 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 Federa lism Consultation Outreach Meeting on September 10, 2013. Due to interest in that meeting, additional outreach meetings were held on November 7, 2013 and8

- 8 November 14, 2013. With the pending proposal of these Emission Guidelines, an additional
Federalism ou treach 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 Na tional 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, Associ ation 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 intere sted 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 signi ficant 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 tim ely 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. O ne 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 antic ipated to meet the definition of the closed landfill subcategory. One of the landfills, the Tri Cities Landfill is already controlling emissions8

- 9 under the current NSPS/EG framework and will not incur substantial additional compliance costs
under Cf. The ot her 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 exi sting 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 rulemaki ng. 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 Risk s and S afety 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 a ctions 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 w ill have positive health effects including for children as previously discussed in Chapter 4

.8

- 10 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 i s not likely to have a significant adverse effect on the supply, distribution, or use of energy. The EPA ha s concluded that this rule is not likely to have any adverse energy effects because there are a small number of landfills subject to control requirem ents under subpart Cf. Further, the EPA ha s 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 addi tional energy supply from landfill gas energy projects.

8.9 National Technology Transfer and Advancement Ac t

Section 12(d) of the National Technology Trans fer 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, s ampling 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 voluntar y 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,8

- 11 validation data, and other important techn ical 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 Guide lines 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 heal th 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 populatio ns, 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
mino rity
, 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 welf are effects8

- 12 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 Mun icipal 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 th ere 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 previousl y mentioned proximity analysis conducted for the proposed Emission Guidelines provides information about the populations likely to be impacted.United States Environmental Protection Agency Office of Air Quality Planning and Standards Health and Environmental Impacts Division Research Triangle Park, NC Publication No. EPA

- 452/R

- 15

- 008 August 2015