EPA’s New Rules for Landfills Won’t Cut Greenhouse Gas Pollution

EPA special interest group proposal flies in the face of science, as well as White House mandates for reduced greenhouse gas emissions


Nick Stumo-Langer

WASHINGTON, D.C. – The Federal Register recently published new landfill rules which fail to meet any of the goals that the White House and EPA have set forth to reduce landfill gas emissions.

In July, US EPA’s “Fuels and Incineration Group” (FIG) pushed through its final revisions to new rules regarding landfills in the United States. The rules state that landfill owners may receive greenhouse gas credits[1] that profit a landfill operation’s bottom line.

Garbage is Not Renewable.” states Neil Seldman of the Institute for Local Self-Reliance. “While we applaud the EPA for its public statement in support of food loss reduction,” he says, “this new landfill policy will do nothing to help move toward the food recovery goal. It will even hurt these efforts.”

The new rules lower the threshold for controlling methane emissions from 50 metric tons per year to 34, but only for landfills built after July 17, 2014.[2] However, the 2016 rule will have no effect on landfills built after 2014, since these are overwhelmingly mega-landfills whose sheer size means that they would have already been required to install gas collection systems.

“In the new proposal, FIG leans heavily on the interests of landfill operators, and false statistics that they say would reduce emissions from methane” says Monica Wilson of the Global Anti Incineration Alliance. “The rules will have no effect on methane release for the large landfills that are presently being built.”
“EPA is using outdated science that understates the climate impacts of methane by three to four times,” says Mike Ewall with the Energy Justice Network.  “Their proposal reinforces ‘business-as-usual’ at landfills, pretending to make a difference while still intensely warming the climate.  A true ‘zero waste’ approach would divert food waste and other clean organic materials for composting, and ensure that any remaining waste is digested before landfilling, to first capture the methane in an enclosed environment to reduce leachate and avoid having gassy, stinky landfills.”[1]

In September 2015 the EPA, USDA, and the White House came out with a forward-thinking goal of 50 percent reduction in food waste over the next 15 years.

By choosing to focus on minor alterations to regulations, as opposed to a plan for sustainable waste management that encourages preventative measures, The Institute for Local Self-Reliance and other organizations believe that the Fuels and Incineration Group fails to adequately respond to the 2014 White House call for decisive action on methane. The Fuel and Incineration Group’s chosen course of action does not tighten controls or lower the amount of methane currently being generated in, and escaping from, landfills.

The EPA group should instead focus on waste management goals and the food hierarchies to prevent organic materials from reaching landfills in the first place, thus reducing the potential for landfill gas to be created. Disregard for truly sustainable waste processing systems is permitting the continuation of the methane problem, rather than redressing it.


Fact Sheet Highlights:

  • Problems with landfills not only include the enormous loss of the resources embodied in landfill discards, but also the fact that systems used in attempt to capture methane and other hazardous air pollutants generated in landfills are inherently flawed. In particular, the effectiveness of landfill gas (LFG) capture systems is undermined when the landfill remains unsealed so as to actively receive materials.[3]
  • Due to organic waste’s innate moisture content and unsealed landfills’ exposure to rainfall, waste management through landfilling does not control organic wastes’ decomposition in the same way as composting or anaerobic digestion, and thus continually releases fugitive emissions into the atmosphere.
  • Factors affecting the amount of landfill gas generation are site-specific, due to high variability in, among other conditions, the moisture content and its movement within the site.[4] Landfills without leachate recirculating technology are estimated to have a moisture content of 20%, whereas those with recirculating systems (i.e. bioreactor landfills), have a moisture content of anywhere between 35 to 65%.[5]
  • The monetary benefits of landfill gas capture in the short-term provide an incentive to continue to bury organic materials in landfills, rather than divert them. Another likely explanation of landfill operators’ motivation for burying organics wastes is to maintain income from abundant tipping fees,[6] rather than transfer the economic benefit to composting operations.
  • The Intergovernmental Panel on Climate Change (IPCC) finds that, on a lifetime basis, landfill gas collection in even some of the most efficient systems is as low as 20%.”[7]
  • Leachate is largely generated by precipitation into the landfill & the leachate’s composition & nastiness is determined by what the individual landfill accepts.



ILSR is a public interest organization, focused on helping communities see the economic benefits of policies and practices that address citizens’ environmental concerns and economic needs. We help citizens fight the incinerators and landfills that pollute their air and water, and drive property prices down.  We help communities research and demonstrate recycling, composting, and zero waste programs that reduce the need for disposal facilities and increase economic growth.


GAIA is a worldwide alliance of more than 650 grassroots groups, non-governmental organizations, and individuals in over 90 countries whose ultimate vision is a just, toxic-free world without incineration. We work both against incinerators and for safe, sustainable and just alternatives.


Energy Justice is the grassroots energy agenda, supporting communities threatened by polluting energy and waste technologies. Taking direction from our grassroots base and the Principles of Environmental Justice, we advocate a clean energy, zero-emission, zero-waste future for all.


To speak with Neil Seldman about the economic and environmental benefits of organics diversion and the zero waste movement, contact Nick Stumo-Langer: 612-844-1330.


[1] For further details on the impact of methane on climate change, see, http://www.energyjustice.net/naturalgas#GWP


[1] “Standards of Performance for Municipal Solid Waste Landfills: Proposed Rule.” Federal Register 79, No. 137 (July 17, 2014): p. 41802. Available at: https://www.federalregister.gov/articles/2014/07/17/2014-16405/standards-of-performance-for-municipal-solid-waste-landfills

[2] “Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills.” Federal Register 80, No. 166 (August 27, 2015): p.52102. Available at: https://www.regulations.gov/document?D=EPA-HQ-OAR-2014-0451-0076

[3] “A comparison of the gas collection efficiency for open and closed landfills shows that the efficiency at closed landfills is 17 percentage points greater than open landfills.” See: Powell, J. T., J. B. Zimmerman, & T. G. Townsend. 2016. “Estimates of solid waste disposal rates and reduction targets for landfill gas emissions.” Nature Climate Change, 6 (2): 162-165. Available at: http://www.nature.com/nclimate/journal/v6/n2/pdf/nclimate2804.pdf

[4] Center for Disease Control, Agency for Toxic Substances and Disease Registry. November 2001. “Landfill Gas Primer: An Overview for Environmental Health Professionals – Chapter 2.” Available at: http://www.atsdr.cdc.gov/hac/landfill/html/ch2.html

[5] US EPA, Office of Air and Radiation. June 2014. “Economic Impact Analysis for the Proposed New Subpart to the New Source Performance Standards.” Available at: https://www3.epa.gov/airtoxics/landfill/landflpg.html

[6] US EPA, Office of Air & Radiation. June 2014. Municipal Solid Waste Landfills: Economic Impact Analysis for the Proposed New Subpart to the New Source Performance Standards. Available at: https://www3.epa.gov/ttnecas1/regdata/EIAs/LandfillsNSPSProposalEIA.pdf

[7] Bogner, J., et al. “Waste Management,” In Climate Change 2007: Mitigation. Contribution of Working Group III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change[B. Metz, et al. (eds)], Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Available at: https://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch10s10-4-2.html


The Institute for Local Self-Reliance (ILSR) is a 42-year-old national nonprofit research and educational organization. ILSR’s mission is to provide innovative strategies, working models, and timely information to support strong, community rooted, environmentally sound, and equitable local economies. 

To contact ILSR about its mission, and learn how citizens and community organizations can the rules can be re-written to break the corporate stranglehold on our economies, email Rebecca Toews: rtoews@ilsr.org or call 612-808-0689.



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