Comment Details
| Comment Author: | Charles White |
| Organization: | Waste Management |
| Comment Date: | Saturday, 29 August 2009 |
| Uploaded Comment File: | Download File |
| Comments: |
Other/General Comments: On behalf of Waste Management Inc, I am pleased to take this opportunity to comment on the WCI Reporting Subcommittee document “Essential Requirements of Mandatory Reporting for the Western Climate Initiative, Second Draft” released on September 30, 2008. A Diversified Company Committed to Action on Climate Change As the members of the WCI are aware, Waste Management is the leading provider of comprehensive waste and environmental services in North America. We operate in 48 states and the territory of Puerto Rico in the U.S. and most Canadian provinces. Operations include a fleet of more than 20,000 collection vehicles, and our diverse operations include 413 waste collection operations, 370 waste transfer stations, 283 active landfill disposal sites, 17 waste-to-energy plants, 131 recycling plants, about 100 beneficial use landfill gas-to-energy projects, and six independent power production plants. We take great pride in our work, most particularly pride in the company’s efforts to reduce the impact on climate change resulting from the waste each of us generates on a daily basis. We continue to commend the WCI for its leadership in Climate Change initiatives. The categorization and ultimate control of greenhouse gas emissions is a daunting task, but one that is vitally important and one in which Waste Management will take part as a willing and ready participant. A Question of Competition in the Solid Waste Industry Our comments today focus solely on the competitive nature of the cap & trade system. In particular, we are concerned that an arbitrary threshold of 10,000 metric tons of CO2e annually to trigger reporting and 25,000 metric tons of CO2e annually to subject a source to the cap and trade program can be counterproductive to the goal of reducing greenhouse emission by penalizing more efficient, albeit larger, operations while allowing smaller and less advanced and effective operations to continue without regulation. Reporting and program thresholds must be sensitive to the competitive and operational issues of any given industry. In the case of solid waste, larger and more highly regulated landfills, recycling and composting operations may be better stewards of Climate Change than their smaller counterparts. If an arbitrary reporting and/or cap and trade threshold of 10,000 tons is enforced, there will be greater incentive to develop and operate at the less efficient scale. At the least, reporting threshold be industry specific and take into account all sources of emissions and sinks within that particular industry. At best, regulatory programs should be designed on an industry and source specific basis to gain the greatest amount of greenhouse gas savings while protecting the competitive nature of a business. When a large number of a certain source category that is subjected to cap and trade are below the cap and trade threshold for inclusion, incentives are put into place that reward these smaller, and often more inefficient facilities. The unintended result of this policy is the growth of small, inefficient facilities that, when aggregated, emit far more greenhouse gas than would be emitted if larger facilities handled the material but that because of their size escape regulation. A Look At California Landfills as Example For example, WCI recommends that sources emitting 25,000 MTCO2e annually be subject to cap and trade. We have provided with these comments an excel spreadsheet of emissions estimated by the California Air Resource Board from California landfills. The attached spreadsheet is sorted to show the landfills under the "Landfill CH4 Emissions" tab from largest to smallest emissions. The tab labeled "Landfill CH4 Emissions" contains the CARB estimate of emissions of all regulated landfills through 2005 -- with the landfill ranking in descending order according to their 2005 emissions. In the 2005 column of this tab there are 48 landfills with emissions > 25,000 MTCO2e, according to the CARB. It is important to understand that Waste Management does not wholly agree with the emissions estimates contained in this spreadsheet because CARB used the default USEPA assumption estimating that only 75% gas collection efficiency is achieved at large landfills with gas collections systems, and 10% cover/cap oxidation efficiency is achieved. This equates to an overall control efficiency of 77.5%. Our experience shows that gas control efficiency is much higher than this -- probably in the range of 90% control efficiency at larger landfills in California. Nonetheless, we agree that there are a number of large landfills with CH4 emissions >25,000 MTCO2e -- although in truth the number would be a good deal less than 48. For example, if overall control efficiency increases from 77.5% to 90%, then the number of 2005 landfills > 25,000 MTCO2e emission would decline from 48 to 25 -- almost a 50% reduction in landfills above the 25,000 MTCO2e threshold in 2005. Assuming 90% efficiency, we are left with 340 landfills with emissions less than 25,000 MTCO2e. These smaller landfills are much more likely to have lower methane control efficiencies than larger landfills. This is because larger landfills have the financial resources to take extra steps to control emissions. For example, wastes placed in larger landfills are more likely to be covered quickly. Note the landfill with the largest 2005 methane emission is LACSD's Puente Hills. LACSD estimates that the overall collection efficiency of this very large landfill is close to 99%. If this is true, than rather than 632,758 MTCO2e of methane emissions, the landfill would have only 28,123 MMTCO2e of methane emissions in 2005 -- barely above the 25,000 MTCO2e threshold. If the amount of waste going to Puente Hills were disposed instead in a smaller landfill, the result most probably would be higher greenhouse gas emissions per ton of waste disposed. Thus, the threshold creates a competitive issue for the solid waste industry. The cap and trade system, if imposed on solid waste, would focus attention on a relatively few, very large, yet most probably very efficient landfills. The program would totally ignore more than 93% of the other California landfills that likely operate at far low methane control efficiencies. Most important to Climate Change policy, the threshold would result in greater greenhouse gas emissions than if direct regulatory burdens were placed on all landfills. One Size Does Not Fit All -- Sometimes Another Program is Required We urge the WCI to evaluate the competitive impact of the cap and trade program on source categories in which there are many members that fall below the cap and trade regulatory threshold. Landfill facilities are just one example. An evaluation of such categories will lead to the conclusion that such sources are not well regulated under such a program. We would cite other reasons as well to exclude landfills from a cap and trade system including the inability to accurately monitor landfill methane emissions and the considerable dispute over the actual level of landfill methane emissions. We urge WCI instead to look at other approaches to lowering greenhouse gas emissions such as minimum regulatory controls on landfill methane emissions. Landfills that control emissions above and beyond minimum threshold levels should be able to generate offset credits to help pay for these additional more expensive controls beyond minimum standards. Thank you for consideration of our comments. We look forward to working with you in development of regulations to report greenhouse gas emissions. Sincerely, Chuck White, Director Regulatory Affairs/West Waste Management 915 L Street, Suite 1430 Sacramento, CA 95814 Phone: 916-552-5859 Cell: 916-761-7882 Email: cwhite1@wm.com |