It will have a detrimental impact on Michigan s fledgling composting industry, resulting in a net loss of jobs in Michigan.

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1 Introduction While landfill gas (lfg) capture and its conversion to usable energy has its merits, the effort to introduce additional organic material, such as yard clippings, into Michigan s landfills is an ill-advised policy. Such efforts, like SB 864, are clearly bad for Michigan s economy and Michigan s environment. Reasons to oppose SB 864 include the following: Landfill gas is an insignificant source of energy and introducing yard clippings into Michigan s landfills will not have an appreciable impact on energy production. Landfills designed to capture methane still emit considerable amounts of methane into the atmosphere. As such, the proposal would have a net negative impact on the environment. Landfill gas is a poor performing and dirty source of energy. It will have a detrimental impact on Michigan s fledgling composting industry, resulting in a net loss of jobs in Michigan. It runs counter to sophisticated waste management trends throughout the country and the world, placing Michigan at a competitive disadvantage with regard to the development and implementation of state-of-the-art and emerging technologies. It will accelerate the depletion of existing landfill space in Michigan, causing an increase in disposal costs for Michigan s businesses, cities, and residents. Landfill Gas is an Insignificant Source of Energy Generation According to Michigan s 21 st Century Electric Energy Plan, Appendix Volume II, electricity generated from lfg has the potential to be only a very minor component of Michigan s energy portfolio. The Plan projects that lfg can only generate slightly more than 1,000 GWh/year by 2015, which is only 8.1% of the renewable portfolio standard and only 0.81% of the entire amount of projected energy production. 1 Yard clippings can only represent a fraction of that potential. However, data from the United States Environmental Protection Agency and the Department of Energy suggest that the potential is far less. According to the EPA, there are currently 425 lfg projects nationwide, generating about 10 million megawatt hours per year. 2 The EPA also projects that another 560 landfills are candidates for similar projects. 3 If all of those candidate landfills were also to generate electricity from landfill gas, a total of less than 23.2 million megawatt hours could be generated annually. According to the U.S. Department of Energy, electricity production in the U.S. in 2006 was nearly Michigan s 21 st Century Electric Energy Plan, Appendix Volume II, January 2007, p U.S. EPA, An Overview of Landfill Gas Energy in the United States, Landfill Methane Outreach Program (LMOP), May 2007, p. 8 3 U.S. EPA, Landfill Methane Outreach Program, 1

2 billion megawatt hours. 4 As a consequence, lfg-generated electricity could only fulfill 0.57% of America s electricity needs. Importantly, the impact of adding yard clippings to this small energy potential is minor. A June 2006 report entitled, Examining Increased Renewable Energy Production from Landfill Gas in Michigan, was prepared for Granger III and Associates, LLC, which is a company advocating exemptions to the current yard waste ban. Exhibit 11 of that report shows the impact of including yard clippings on the statewide landfill energy production capacity. Allowing the current major landfills with lfg-to-energy systems to add yard clippings to the waste stream may result in increasing year 2015 total megawatts from to 265.6, which is less than a 15.3% increase. 5 Given that the lfg energy potential is only 0.81% according to Michigan s 21 st Century Energy Plan and 0.57% according to USEPA/DOE data, the 15.3% increase from adding yard clippings to landfills means that the energy potential of those yard clippings is between only 0.124% and 0.087% of energy production. Negative Environmental Impacts One of the most important factors that argues strongly against disposal of organics in landfills focuses on the impact of organics management on global climate change. Carbon emissions come from either long-term carbon cycle activities (e.g. burning of fossil fuels to create energy) or short-term carbon cycle activities (decay of carbon based organics that have been created in our lifetime). All organic wastes, including yard debris organics, fall into this category. Unlike fossil fuels, which we can prevent from turning into carbon dioxide (CO 2 ) or other green house gasses (GHG), we assume all short-term carbon cycle materials will decay into some form of carbon based gas. Its seems like the products derived from the short-term carbon cycle might not matter in the GHG emission calculation because they are all going to become carbon dioxide in any case. For the most part this is true, however, there are carbon-based gasses into which they can transform that are considerable worse than carbon dioxide. Methane (CH 4 ) can also be produced by these decaying organics. Methane has been scientifically shown to be 23 times more effective in retaining heat in our atmosphere than carbon dioxide, creating quite an incentive to prevent the uncontrolled production of this gas. The dramatic difference between the impact of carbon dioxide and methane on the potential for warming of the earth lays at the core of the discussion about the costs and benefits of banning organics from landfills. Landfills place heavily compacted wastes in deep holes in the ground where oxygen seldom penetrates creating circumstances that lead to the transformation of organic material to methane. After several near disasters with migrating flammable gas, increasingly landfill owners have begun to implement collection systems for the methane. Original EPA estimates 4 U.S. Energy Information Administration, Electric Power Annual, October 22, 2007, 5 Public Sector Consultants Inc., Examining Increased Renewable Energy Production from Landfill Gas in Michigan, June 6, 2007, p. 25 2

3 suggested that collection of methane in well-designed systems could reach 75% 6, but later evidence now estimates that only 20% of the generated methane can be collected. The rest makes its way to the surface by other routes and is emitted to the atmosphere. A quick analysis of the situation shows that, for an equal GHG outcome, approximately a 95% collection efficiency of methane in landfills would need to occur if the organics management solution were to EQUAL aerobic decomposition (like composting or land application). At a collection efficiency of 75%, which was erroneously claimed by the EPA, the outcome would actually be four times worse in a landfill setting. In the more likely circumstance that collection efficiencies are closer to 20% 7, the outcome is FIFTEEN TIMES worse. Implementation of landfill gas collection systems remains a good idea. Current estimates suggest that the contribution of landfill methane emission to the atmosphere contributes between 8-9% 8 of the total GHG emission by the United States. Any methane that can be collected substantially reduces our state s impact on the heat retaining characteristics of our atmosphere. But adding additional organics, which would inevitably increase methane production, creates a situation that is worse overall than the current situation where yard waste organics are banned. Landfill Gas is a Poor Performing Source of Energy Natural gas is typically 70-90% methane, with the remainder primarily being ethane, propane, and butane, as well as smaller amounts of carbon dioxide, oxygen, nitrogen, and hydrogen sulphide. 9 Landfill gas, on the other hand, is only 45 60% methane and 40 60% carbon dioxide, with the remainder primarily being varying amounts of nitrogen, oxygen, hydrogen, sulfides carbon monoxide, and nonmethane organic compounds (NMOCs) such as trichoclorothylene, benzene, and vinyl chloride. 10 According to the EPA, landfill gas contains hundreds of contaminants, most of which are NMOCs. 11 Many NMOCs are toxic chemicals such as benzene, toluene, chloroform, vinyl chloride, and carbon tetrachloride. Many NMOCs are halogenated chemicals that can recombine into highly toxic compounds such as dioxins and furans when combusted in the presence of hydrocarbons U.S. EPA, Greenhouse Gas Emissions from Management of Selected Materials in Municipal Solid Waste (EPA 530-R )(September 1998)( GHG Report ), p Memorandum to Brian Guzzone, EPA, from Chad Leatherwood, Eastern Research Group, Inc., November 18, 2002, re: Review of Available Data and Industry Contacts Regarding Landfill Gas Collection Efficiency, p. 2 8 Anderson, Peter, Comments to the California Air Resources Board on Landfills Responsibility for Anthropogenic Greenhouse Gases and the Appropriate Response to Those Facts, January 2008, p. 1 9 NaturalGas.org, Background, accessed January 29, Agency for Toxic Substances and Disease Registry, Landfill Gas Primer, An Overview for Environmental Health Professionals, November 2001, Chapter 2 11 U.S. EPA, Air Emissions from Municipal Solid Waste Landfills Background Information for Proposed Standards and Guidelines, (EPA/450/3-90/011A) March Ewall, Mike. Primer on Landfill Gas as Green Energy, February 10, 2000, p. 1 3

4 In addition, according to the Center for a Competitive Waste Industry, most installed landfill-gas-toenergy capacity uses polluting internal combustion engines, burning landfill gas, which is significantly dirtier than pipeline natural gas. Moreover, that new capacity also tends to displace newer, advanced combined-cycle natural gas units, not older, polluting coal systems. Many of the old coal plants have been largely depreciated so that they can be bid on their operating costs alone, while the newer, cleaner facilities need to be priced based upon both their capital and operating costs. 13 Weakening the Yard Waste Ban Will Cause Job Losses in Michigan On the other hand, Michigan s composting industry is an evolving industry that is working to follow the example of best waste management practices found throughout the country and the world. Such sophisticated management systems take advantage of the organic content of the waste stream to generate environmentally sound products and/or use state-of-the-art technology to generate electricity and steam. It is unfortunate that just as other areas throughout North America and the world are taking steps to eliminate organic content in landfills and engage in value-added economic activity with that material, benefiting both the environment and the economy, some in Michigan are working to move counter to that trend. According to the Institute for Local Self-Reliance, composting creates four jobs for every one job created through landfilling or incineration. 14 So while the inclusion of yard clippings in landfills will have an insignificant impact on the amount of electricity available, it will have a detrimental affect on the composting industry by diverting important feedstock and revenue to Michigan s low-cost landfills. This will undoubtedly result in lost jobs. In addition, it should be noted that the operational concerns of compost sites raised by advocates of SB 864 are misleading. Like any business, there have been site operators that haven t performed to industry standards. However, there are plenty of well-run compost sites in the state and the recently passed SB 513 will ensure that all compost sites in Michigan perform to those same high standards. SB 864 undermines the efforts of the state s compost industry and places Michigan at a competitive disadvantage with regard to the development and implementation of state-of-the-art and emerging technologies. Further, it is important to recognize that composting not only not only reduces greenhouse gas emissions by avoiding methane generation but it also provides significant environmental benefits. The use of compost decreases fertilizer and pesticide use, improves soil structure, reduces irrigation needs, decreases the effects of high salinity, increases soil productivity, limits erosion, and helps store carbon in soil. State and local governments have spent considerable effort establishing yard waste collection and composting programs designed to comply with the existing regulations, and promoting to Michigan residents the importance composting and earth-friendly ways of managing our waste. Allowing landfills to accept yard clippings confounds these programs and the message that we have shared with residents and taxpayers for years. 13 Anderson, Peter, Comments to the California Air Resources Board on Landfills Responsibility for Anthropogenic Greenhouse Gases and the Appropriate Response to Those Facts, January 2008, p Institute for Local Self-Reliance, Recycling Means Business, Washington, DC,

5 Cost Increases to Michigan s Businesses and Cities Also of vital importance is the impact on local government, businesses, and consumers that will result from the accelerated depletion of landfill space and the consequential increase in prices. The availability of low cost landfilling in Michigan is no secret. Landfills are often in fierce competition for waste volumes. Should SB 864 become law, it is likely that landfills will be anxious to qualify to accept yard clippings. According to testimony by Curtis T. Ranger, President, DTE Biomass Energy, Inc. and the Solid Waste Association of North America, before the Subcommittee on Select Revenue Measures of the U.S. House Committee on Ways and Means in May of 2005, a medium sized landfill typically could annually provide 3,000 kilowatts of power and a typical landfill gas-fired electric generating facility costs about $1 million per megawatt to install. In other words, according this testimony, the typical medium-sized landfill could become eligible to accept yard clippings for a $3 million investment. Parenthetically, many landfill owners have already made or will make investments in such facilities even without adding yard clippings. Based on known data such as the MDEQ Report of Solid Waste Landfilled in Michigan and various waste characterization studies, it can be estimated that an additional 500,000 to 1,200,000 tons of material could become available for landfill disposal. Not only will this additional volume compete with existing waste volume from Michigan s businesses and consumers, it will hasten the depletion of existing landfill capacity causing an increase in prices. Finally, with landfill tip fees in Michigan generally ranging between $15 and $45 per ton, SB 864 represents a potential boon to landfill owners. For example, assuming that 700,000 tons of yard clippings are disposed of at eligible landfills at an average tip fee of $25 per ton, $17.5 million per year of new revenue becomes available for landfill owners, albeit at the expense of other Michigan industries, consumers, and the environment. Summary In short, it is clear that all landfills should capture their methane and generate electricity from it when feasible and safe. However, this can be effectively done without allowing yard clippings to be landfilled and the negative consequences of circumventing existing waste management practices far outweigh the minimal benefits. SB 864 can only improve Michigan s electricity generating capacity by about one tenth of one percent. The trade-off for this insignificant change is a loss of Michigan jobs, increased costs to Michigan businesses and cities, and increased pollution. 5