EPA Takes Steps to Address Underreporting of Landfill Methane Emissions

Methane is one of the most potent greenhouse gasses, making it a critical target for reducing harmful, planet-warming emissions that fuel the climate crisis. U.S. methane emissions are out of control and one of largest sources is lurking in our communities: landfills.

Katherine Blauvelt, Circular Economy Director

In addition to generating massive amounts of methane emissions, decaying waste from landfills can pollute the air we breathe with toxic gasses that threaten millions of people living near them –  many of whom are low-income or people of color. With dangerous emissions streaming out of poorly-regulated landfills across the nation, there is no time to waste on solutions. If we are to have any hope of tackling this climate and public health issue at its source, we need to know just how extensive landfill emissions actually are and take corrective action to curb them.

Updating the Greenhouse Gas Reporting Program (GHGRP)

The U.S. EPA keeps track of estimated greenhouse gas emissions from large sources through the Greenhouse Gas Reporting Program (GHGRP), which requires certain types of sites that produce lots of emissions, like landfills, to estimate and report them each year. This data informs our national emissions inventory and shapes key policy decisions that control the dangerous pollution putting the health of our communities and environment in danger.

Yet, for years, the GHGRP has been based on outdated, simplistic formulas that do not capture the full picture of emissions coming from landfills. In fact, the EPA’s own top emissions scientist has indicated that the real emissions from landfills are actually twice that of official estimates.

Recognizing that the estimates were not accurately portraying emissions, recently, the EPA finalized a rule to update Subpart HH of the GHGRP, taking several steps to update how emissions are calculated from landfills. Importantly in the rulemaking, the EPA acknowledged the “recent studies indicating that methane emissions from landfills may be considerably higher than what is currently reported.”

The Data & Reality Gap: A Look Under the Surface of Methane Emissions Reporting

The new rule comes in response to discrepancies between what operators are reporting to the EPA on paper and the actual amount of methane emissions flowing into our atmosphere – the numbers simply aren’t adding up. Recent scientific studies published in Science and Atmospheric Chemistry and Physics reveal that these estimates are much too low. The Science paper, led by Carbon Mapper researchers and co-authored by the EPA, collected data from hundreds of individual landfills over months, and in some cases years. The data shows the rate at which emissions are being released into the air is 40 percent  higher on average than what operators claim. Many landfills across the U.S., especially in California and the Permian Basin, may release enough methane emissions to be considered serious “super-emitters.” Worse, the study found that landfills are a far more persistent source of methane pollution than any other part of the oil and gas sector. At the 70 landfills that are compared to the GHGRP, the authors find a median 77 percent increase in observed vs. reported emissions. The authors attribute the discrepancy to two main factors: 1) over-estimated recovery efficiencies at GCCS facilities and 2) under-accounting of site-specific factors (such as noncompliance issues and construction).

By overhauling subpart HH of the GHGRP, the EPA implemented several critical changes to better account for leaking methane from solid waste landfills.

    They changed their baseline assumptions about gas collection system efficiency to better account for the reality of how they work.

    They now require operators to account for times when gas recovery and flare systems aren’t working correctly.

    Operators must report whether a landfill is subject to federal Clean Air Act regulation and which regulation applies. Incredibly, the EPA had not required this basic information as to which landfills have to follow basic standards.

However, there are still issues with these estimations. Unfortunately, the EPA did not take steps in this rulemaking to incorporate advanced monitoring technologies – like drones, aircraft, continuous monitors, and satellites – that actually measure methane emissions from landfills . Modern technologies like these can help quantify landfill emissions for reporting programs and also provide critical data to  control methane leaks. Some landfill operators are already taking up new monitoring practices on their own because it cuts costs, keeps our air clean, and makes them better neighbors to our communities.

This EPA’s reporting program rule itself doesn’t directly regulate or reduce emissions from landfills - it’s like a virtual autopsy of where harmful greenhouse gas emissions are coming from. What’s needed next is for the EPA to use their authority to require action to stop harmful emissions before they get out of control.

Looking forward

Ineffective standards for how landfill operators monitor for methane are allowing huge amounts of the super-polluting greenhouse gas to go undetected. A new report by Industrious Labs reveals that lax regulations are perpetuating a cycle of inefficient landfill management practices and exacerbating the methane crisis. Inspection reports from 292 landfills across the country found more than 711 methane exceedances — often when landfill operators themselves reported few or none. These discrepancies underscore that we need common-sense improvements to how methane emissions are found, quantified, and reported.

Fortunately, the EPA is required by the Clean Air Act to revisit its landfill standards this summer, and it is critical that they take this opportunity to strengthen existing standards for landfill methane emissions. The benefits of tackling landfill emissions are too big to ignore. Stronger EPA standards would slash planet-warming methane and advance our climate goals. Controlling landfill methane also prevents the toxic, smog-forming gases released alongside it, thereby improving air quality, public health, and quality of life for millions of impacted communities.

The EPA must move quickly to adopt a rule that takes advantage of the latest best practices and technologies in methane monitoring and control, while also leading waste prevention and organics recycling to prevent and cut the methane spewing from our landfills. Doing so will help put the U.S. on track to meet our climate, public health, and environmental justice commitments and start to give local communities the protections they need.