Garbage and greenhouse gas: Landfills brace for new limits on methane emissions

Jennifer Richardson, the county’s solid waste and sustainability division director, worries both about the increased costs the regulations would create for the county’s landfill, and the cost implications for smaller landfills, which unlike larger landfills in the state don’t currently have gas collection systems.

“I mean, our state is on fire,” she said in an interview late last month as several major Western Slope wildfires were winding down. “You can’t be breathing in smoke for the last six weeks and say that we don’t need to do something about greenhouse gases. … But we also have to be realistic about which landfills are getting trapped in this regulation.”

Ryan Call, with the group Eco-Cycle, is glad to see the state moving on addressing landfill methane but also is worried about the degree to which the proposal has been revised since initially being proposed.

“There’s been a lot of input from both the waste industry and publicly-owned landfill operators that from the environmentalists’ perspective have weakened the rule or created off ramps at various points,” he said.

“… We want to see a nation-leading rule in cutting methane. Based on our research and experts’ testimony we believe that cutting methane from landfills is one of the most cost-effective methods to addressing climate change, and the Air Pollution Control Division agrees.”

THE RATIONALE FOR THE RULE

The state APCD proposed the rules. Zachary Aedo, a spokesperson for the Colorado Department of Public Health and Environment, said in an emailed response to questions from the Sentinel that the proposed rule is one of several steps identified in the state’s Greenhouse Gas Pollution Reduction Roadmap 2.0 that would help the state meet the ambitious goal of net-zero greenhouse gas emissions by 2050.

It would reduce not just methane but other harmful pollutants, he said. Methane is considered to be 28 times as potent a greenhouse gas as carbon dioxide over 100 years.

Under the proposal, 32 landfills would have to reduce their methane emissions based on the amount of waste they currently hold and the amount of methane they emit, Aedo said.

Under a lower threshold for emissions controls than federal requirements, some landfills that don’t now have gas collection and control systems would have to install them. That requirement would apply to all landfills generating more than 2,000 tons of methane a year. Collected methane can be flared off, which converts it to less harmful carbon dioxide. It also can be used for purposes such as generating electricity or heat or fueling vehicles such as trash trucks, or can be refined and delivered into natural gas pipelines for use.

Aedo said other key components of the proposal include an 18-month timeline for operators of open landfills to install the gas systems after submitting a design plan; new requirements for methane monitoring, including options to use alternative technologies to identify large emission sources; and a phased ban on the use of open flares. Instead, enclosed flares could be used, which Aedo said allows for performance testing to confirm reductions in methane emissions.

He said landfills are the third-largest source of methane emissions in the state, emitting approximately 1.5 million metric tons of carbon dioxide equivalent each year. Natural gas and oil systems emit about 29.13 million metric tons a year of carbon dioxide equivalent in the state, and agriculture and livestock management, about 7.39 million metric tons of carbon dioxide equivalent a year.

While landfills rank third statewide as a methane emissions source, it’s a distant third, Richardson notes, accounting for just 1.1% of all emissions in the state. But Call believes landfill emissions are vastly underestimated, and said measurements using advanced technology such as satellites, drones and aerial monitoring show those emissions are much higher.

MESA’S VOLUNTARY PROJECT

Richardson said Mesa County installed a voluntary system for dealing with methane in 2012. The county installed a flare to burn off the methane and ran it until 2021, when it would have needed some pretty expensive upgrades to keep it going.

“We were really struggling to keep this flare running in the first place. The amount of methane we were generating that we would be sending to this flare was such a small amount that it’s really hard to keep it going. In 2021 we were done fighting with it and we shut it off,” she said.

She said waste needs oxygen, sunlight and water to break down and biodegrade and produce methane. Keeping the garbage compacted and covered limits the oxygen and sunlight it gets and the local arid climate deprives it of water, so the county’s landfill just doesn’t create that much methane, she said.

She remembers once doing some excavating in a former landfill the county operated at Orchard Mesa until closing it in the early 1980s. She found a Daily Sentinel edition printed in 1974 and still legible and in good shape, and a cardboard Cheerios box in fresh condition with a picture on it of David Hasselhoff from his Knight Rider television series days.

“It looked like I had fed my kids with it that morning. … It looks brand new,” an amused Richardson said about the Hasselhoff-adorned cereal box. “Our trash isn’t really breaking down, we’re not generating a lot of methane.”

But shortly after the county stopped operating its voluntary flare, the Environmental Protection Agency lowered the annual emissions threshold for non-methane organic compounds that landfills can emit before they have to put in a gas collection system, and Mesa County’s site ended up above that threshold. The EPA focuses on those ozone-forming compounds, but the gas systems collect and control gases including methane.

Richardson said the county last year installed a flare designed for the amount of methane it was generating, as opposed to the previous flare, which was a little too big, and it has been running well.

She said the county landfill last year generated about 4,615 metric tons of methane, but it doesn’t all go to the atmosphere because it has a cover and a gas control system.

That level of emissions would mean it would have to have a gas collection system in place under the proposed state rules if it didn’t already have one in place.

COST CONCERNS

Richardson worries particularly about smaller landfills that under the new rules also could have to put in such systems and comply with expensive monitoring, landfill cover and other requirements.

“How are these tiny little landfills going to pay for that?” she asked.

She said it cost Mesa County $3.3 million to put in its new flare and collection system, which involves 34 wells across 64 acres. It costs another $350,000 a year for maintaining and operating the system and for surface emissions monitoring and reporting requirements. To comply with the additional requirements proposed by the state would boost that expense up to $630,000 a year, she said.

The state rules as written could result in a $4-a-ton increase in tipping fees at the landfill, Richardson estimates.

The landfill currently charges $30 a ton, after county commissioners reduced it from $42 dollars early this year to try to discourage illegal dumping in places other than the landfill. Richardson said it needs to be at $42 to cover the landfill’s expenses, and if it were at that rate the state rules could mean it would have to rise to $46.

Richardson is particularly concerned about smaller landfills that are supported by smaller populations and don’t already have a gas collection system in place like Mesa County does. Mesa County was involved in helping put together a coalition that has been actively participating in the state rulemaking process and raising concerns about potential impacts, particularly in the case of smaller landfills. The coalition includes Garfield, Rio Blanco, Montrose and Delta counties, and some more distant ones.

Richardson said some smaller counterpart landfills are looking at potential tipping fee increases of up to $20 a ton, and in the case of a Rio Blanco County landfill, almost $70 a ton, to pay to comply with the new rules.

DIFFERING ESTIMATES

The Air Pollution Control Division has taken issue with some of the cost estimates of the coalition of which Mesa County is a part, saying they have significant flaws that inflate the cost of compliance.

Aedo said, “While it is difficult to make exact predictions on how costs of services may be impacted, data from other states with similar landfill methane rules indicate that, on average, tipping fees, which can affect the cost for trash service, did not significantly increase in those states. Colorado modeled its rule proposal on rules adopted by other states like Washington, California, Maryland, and Oregon.”

He said the compliance cost would be $5,900 per acre per year for smaller landfills without a gas collection system and $1,600 per acre per year for larger landfills with such a system.

“While this seems like smaller landfills bear a higher cost per acre, lower acreage results in a lower cost overall. Landfills with existing control systems would also incur fewer compliance costs because estimates only assess new or additional costs,” he said.

Aedo said that if municipal solid waste landfill operators passed on all compliance costs for the rule to the households they serve, the Air Pollution Control Division’s latest estimate shows a potential increase in the average yearly tipping fee of $22.90 per household per year, but a more recent analysis shows that number may actually be less than $4 per household.

Richardson said an estimate that the cost would be $3.66 per household is based on considering the state population as a whole. Given the discrepancies between larger and smaller landfills and the sizes of the populations they serve, the cost likely would be substantially higher in a place like Montrose County, and lower in Denver, she maintains.

The APCD estimates that the total cost of compliance by 2050 would be $209 million, but the climate benefit of the rule would be at or just above $1 billion thanks to a total reduction in emissions of roughly 11.2 million to 12.4 million metric tons of carbon dioxide equivalent by then.

CONCESSIONS WON

The coalition of which Mesa County is a part has won some concessions as a result of its advocacy efforts during the rulemaking process. Among them, under the revised proposals, some local government-owned landfills would have an extra three years to comply with the rule. Richardson said the delay is only for small landfills, and Mesa County’s is small enough to qualify for it.

She said the proposal also originally called for all landfills of any size to use an expensive biocover, which promotes bacteria that eat methane, as intermediate cover for landfills. Landfills cover garbage each day and install a final cover once they are full, but Richardson said the vast majority of a landfill has an intermediate cover, with Mesa County’s currently consisting of 12 inches of soil. The state division has since revised its proposal to make the biocover requirement apply only to landfills with gas collection systems, and only in areas with new intermediate cover.

The Air Quality Control Commission recently held a hearing on the Air Pollution Control Division’s proposed rule but delayed action on it until December.

Richardson said that while she still has concerns about the proposal, “I do feel like the Air Quality Control Commission heard us and heard our concerns and so did the Air Pollution Control Division.”

Said Call, “Really the conflict around this whole issue comes around the issue of cost.”

He said the ACPD has determined that the cost per ton of methane kept out of the atmosphere is quite low when it comes to controlling landfill emissions, when compared to efforts to do the same in the oil and gas sector.

Eco-Cycle sees the rule as important in controlling not just methane but ozone-forming compounds and specific toxic air pollutants such as toluene and benzene.

Call said the proposed rule also is just a part of a larger conversation when it comes to the environmental impact of waste. He said that while environmental groups and the waste management industry are on opposite sides of the landfill issue he hopes to see them collaborate in the future to find innovative ways to minimize impacts of waste, through means such as diversion of food and other organic waste, composting, recycling and waste minimization.