Rulemaking - Chapter 173-408 WAC, Landfill Methane Emissions

Submitted By

41 Results

Search Type

Sort:

Sort Results By

Comment From: Suellen Mele

12/13/23 @ 11:41 PM

Attachments:

Download

Comment From: Greater Maple Valley Unincorpo... (LarKen Buchanan)

12/13/23 @ 10:45 PM

Attachments:

Download

Comment From: Sniffer Robotics (David Barron)

12/13/23 @ 10:10 PM

Please see attached.

Attachments:

Download

Comment From: Janet Dobrowolski

12/13/23 @ 8:31 PM

Please see the attached file for comments on the proposed new methane emission rules. Thank you.

Attachments:

Download

Comment From: Waste Connections (George Duvendack)

12/13/23 @ 7:56 PM

Attachments:

Download

Comment From: Elena Guilfoil

12/13/23 @ 6:34 PM

My comments to Chapter 173-408 WAC are attached.

Attachments:

Download

Comment From: Heather Trim (Heather Trim)

12/13/23 @ 4:55 PM

Please see attached joint letter

Attachments:

Download

Comment From: Peter Rimbos

12/13/23 @ 4:32 PM

Attachments:

Download

Comment From: Washington Refuse & Recycling ... (Rod Whittaker)

12/13/23 @ 2:18 PM

Comments from WRRA on the WAC 173-408 Rulemaking.

Attachments:

Download

Comment From: Scott Cave (Scott Cave)

12/13/23 @ 11:11 AM

Please see my comment letter on behalf of Carole DeGrave and Friends of Rocky Top attached.

Attachments:

Download

Comment From: King County Solid Waste Divisi...

12/13/23 @ 11:04 AM

Attachments:

Download

Comment From: Kampmeier & Knutsen, PLLC on b... (Mariah Harrod)

12/13/23 @ 9:20 AM

Please see attached. Thank you!

Attachments:

Download

Comment From: Friends of Rocky Top, a Cascad... (Nancy Lust)

12/13/23 @ 8:49 AM

Attachments:

Download

Comment From: Bio Energy Washington (Kevin Singer)

12/13/23 @ 8:40 AM

The following are comments from Bio Energy Washington, LLC regarding rulemaking Chapter 173-408 WAC Landfill Methane Emissions:
1. For this rule to effectively reduce landfill methane emissions, it must include the latest technologies to measure meth...↓ane emissions, target higher collection efficiencies and minimize the burden to beneficial use and post-treatment facilities that convert the landfill gas methane into beneficial, renewable electricity and gas.
2. According to the current rulemaking language, both active landfill sites and side slopes of the landfill would be exempt from surface emission monitoring. However, Bio Energy Washington (BEW) performed a methane overflight inspection with a drone equipped with a laser spectrophotometer to detect methane over the Cedar Hills Regional Landfill in January 2021 demonstrating significant methane leaks from the active landfill area and surrounding side slopes. A copy of the results from this study is provided as "Cedar Hills Regional Landfill Final Pergam report.pdf". We've been advised that several jurisdictions are utilizing these laser-equipped drones and incorporating them into regulatory framework to more effectively characterize and reduce methane emissions from landfills.
3. Given the stringent requirements on leak rates and destruction efficiencies in this rule, the omission of rules regarding a minimum gas collection efficiency creates a significant gap in minimizing fugitive/surface emissions from landfills. While the rule asks that collected gas measurements are reported, the collection efficiency (the measure of how much landfill gas is collected as a percentage of the landfill gas generated) is not a standard. Additionally, the low expected collection efficiency of 75%, used in calculating the Heat Input Capacity [equation 1] allows for 25% of the generated landfill gas to go unaccounted for and uncollected. This allows a greater number of landfills to be exempted from the regulation. A landfill gas collection efficiency study was performed at the Cedar Hills Regional Landfill showing that collection efficiencies of above 90% were achievable and subsequent reductions in collection efficiencies were due to inadequacies in the landfill gas collection system. These values are provided in the attached report "KCSWMD10_LFG Assessment Report Consultant Review Final.pdf" on pg 57 � 59 of the file (note: page numbering is inconsistent in this report). The term "LFG System Coverage" describes the same measurement as landfill gas collection efficiency.
4. One way to incorporate collection efficiency would be to set a minimum, for example, of 85%. As an example, if the collection efficiency is less than 85%, the rule could require a laser-equipped drone to monitor surface emissions, particularly in the active landfill areas and topography that cannot be traversed easily. As the two attachments show, it is possible to have significant landfill gas emissions from the side slopes and active areas AND still be in compliance with the surface emissions monitoring standards.
5. The impact of the collection efficiency on greenhouse gas (GHG) emissions, as reported to the EPA, is staggering. In 2018, the landfill had a collection efficiency of 93% and a GHG emission of 68,422 MT CO2e. In 2021, the landfill had a collection efficiency of 78% and a GHG emission of 245,041 MT CO2e. That represents over 258% increase in emissions. The source data for these emissions are the publicly available GHG inventories through the EPA's FLIGHT website tool.
6. On section WAC 173-408-080 - Gas collection and control systems, (5)(b), the language reads "If a gas collection and control system routes the collected gas to a treatment system that processes the collected gas for subsequent sale or use, the owner or operator of the treatment system must ensure the system achieves a methane leak rate of three percent or less by weight. Venting of processed landfill gas to the ambient air is not allowed. If the processed landfill gas cannot be routed for subsequent sale or use, then the treated landfill gas must be controlled according to this subsection (5)." There is no proposed calculation for leak rate. Additionally, fugitive emissions for BEW are covered by more stringent requirements in our air operating permit issued by PSCAA.
7. "Gas control system" or "Energy recovery device" definitions cover combustion (of landfill gas); gas treatment for subsequent sale, or sale for processing offsite, including for transportation fuel and injection into a natural gas pipeline. Based on these definitions, BEW wants to clarify that its electricity generation process is neither a Gas control system nor an Energy recovery device.

Attachments:

Download

Comment From: Shelley Byington

12/13/23 @ 8:31 AM

Comments regarding: Chapter 173-408 WAC – Landfill Methane Emissions
As a Yakima County tax paying citizen, I strongly encourage DOE and other agencies to add Limited Purpose Landfills to the same rigors as Municipal Waste Facilities and additional m...↓ethane/water monitoring. Caton LPL and DTG LPL have brought this dangerous matter to our attention in the last two years with above ground fires and underground fires that persist at both sites to date. Last week's snow fall confirms subsurface thermal activity with snow melt patterns. Caton LPL pictures have been taken. These fires, undoubtedly, contribute to carbon emissions and add to greenhouse environmental impact. It is proven that the LPL's are accepting illegal refuse that contributes to these active fires with their acceptance of organic material. At a minimum, both LPLs should install liners, monitor water, monitor air quality on a rigorous level and report publicly.
Also, please add a new WAC for Mandatory Landfill Water Monitoring. It is all of our responsibility to leave future generations a safe environment if we want continued human population sustainability. Currently, Caton and DTG LPLs are SUPERFUND sites in the making. Caton is currently operating ILLEGALLY without permits since 7/1/2023 AND they are not acting on YHD's required compliance items that might bring them into good standing. Catan's blatant disregard for the rule of law leaves all of us scratching our heads, and how/why they are allowed to get away with it. Other Yak County businesses should be upset over this unfair treatment. Caton's ILLEGAL activity has gone unregulated for over SIX months, this should leave persons in paid positions to act, sleepless at night.
Caton's location, and potential impact, to the Naches Resort and its dense population is shocking and should be monitored to avoid water and methane emission impacts. The impact on the Wenas valley is also a concern and its animal and human population. Naches Resort was granted County approval to populate close to 300 lots. Potentially, impacting 600 plus lives with the LPL's activity!
Caton continues to creep further up the hill to avoid dust, noise and other potential daily monitoring by neighbors. Thus, continuing to put them outside of their approved SEPA plan. Again, ILLEGALLY dumping, going unmonitored by YRCAA, Code Enforcement, YHD, and DOE regulators is disturbing and unacceptable with irreversible consequences.
Please, please act as if these LPLs are in your immediate backyard with potential to harm your loved ones!

Attachments:

Download

Comment From: Leslie Morgan

12/12/23 @ 7:22 PM

I am making this comment as a citizen that fully realizes the implications of existing weak rules and regulations governing our landfills.
1.) RCW 70A540.050 3.a) needs clarification and a specific description of "working face". The working face shou...↓ld be defined as only that area which is currently receiving daily waste. This clarification is necessary due to the practice at Cedar Hills Landfill using intermediate cover verses final cover on areas that were no longer receiving garbage in order to categorize them as "active areas" therefore exempting them from methane monitoring. This practice was discovered in the discovery phase of the most recent citizen lawsuit.
2.) Size and period of time a working face can be open; Cedar Hills is looking at returning to former pits and top filling them to heights as high as 830'. This could lead to a working face being expansive in size, and active for an extended time, resulting in large amount of GHG's, noxious odors and VOC's being released into the surrounding communities, while falling into the exception category. An example of this practice was area 4 of Cedar Hills Landfill. Area 4 was kept as a working face for years even though they were aware of the environmental risks of having an active pit open for such a long period. Discovery during the class action lawsuit in the early 2000's uncovered exceedances of known VOC's, some more than 33x the acceptable levels, high levels of methane gas, as well as extremely strong noxious odors. With this example I believe there is a need to included strict size and length of time parameters for any working face to remain open.
3.) The working face should not have an exception; It would be beneficial to include this area in monitoring for methane to assess if the type of daily cover is best practices. Cedar Hills now uses tarps rather than 6" of soil for daily cover. This should be tested to make sure that tarps are as good or better than soil to mitigate methane, VOC's and noxious odors and assure that they are in compliance in meeting the EPA standards of best practices.
4.) Monitoring requirements; Updating the type of monitoring systems that the DOE requires for monitoring methane. The best available technology in achieving the largest net area of surface monitoring and accurate data technology should be required for each individual Landfill. The EPA now excepts drone technology as a method of measuring methane. The current monitoring method at Cedar Hills verses the drone monitoring results by Pergam Technical Services in 2021 demonstrates the need for updated technology requirements for landfills. The drone technology was far superior in identifying methane levels and leakage while covering a much greater surface area and cannot be manipulated.
5.) Strict adherence to new regulations; The importance of an industry to be in compliance of environmental standards and regulations is imperative to the health and safety of all. Landfills must meet regulatory standards, must show a history of consistently operate in compliance of their operating permits, should not be given exceptions, and must have stringent oversight in order to meet the environmental goals of Washington State in GHG reduction. This is especially important for an industry that ranks #3 in GHG emissions.
6.)Regulations that bring about change for Environmental Justice; As a citizen that has lived in a community that has been marginalized for years from the constant environmental impacts of the operations at Cedar Hills it is my sincere hope that there can be meaningful protections for our community through these new regulations. Our families and school children matter, we are not inconsequential.

No attachments

Comment From: Anonymous Anonymous

12/12/23 @ 6:46 PM

Rulemaking - Chapter 173-408 WAC, Landfill Methane Emissions

To whom this may concern:
I urge you to add LPLs to your requirements for methane emissions. Living near a landfill, I see what organic (contains carbon) material really goes to LPLs. He...↓

Attachments:

Download

Comment From: Linda Averill

12/12/23 @ 4:32 PM

It would make incredible sense for King County and Washington State to adopt more stringent recycling requirements for large companies that use a lot of containers and packaging as part of their business model.
Other states have done this, providing...↓

No attachments

Comment From: Puget Sound Clean Air Agency (John Dawson)

12/12/23 @ 2:47 PM

Attachments:

Download

Comment From: City of Spokane (Jennifer Lennon)

12/12/23 @ 1:37 PM

Attachments:

Download

Comment From: NLC on behalf of Loci Controls... (Graham Noyes)

12/11/23 @ 3:59 PM

Summary of Comment:

Dear Mr. Flagg,

On behalf of Loci Controls, Inc. ("Loci"), I am writing to confirm Loci's strong support for the Department of Ecology's ("Ecology") proposed landfill methane regulation ("Proposed LMR"). Loci is a well-establis...↓

Attachments:

Download

Comment From: Kim Brighton

12/11/23 @ 3:44 PM

I live in Maple Hills community near Cedar Hills Regional Landfill. There is an elementary school and community park 1/4 mile away. For decades, this landfill has continually had numerous regulation violations, exceedances, multiple lawsuits, with a ...↓history of manipulating data. Economic benefits take priority over public and environmental health.
1. Allowing owner/operators to self monitor and report is like letting the fox guard the hen house. Too many loop holes for them to manipulate true public and environmental impacts. Tighter regulations must be made to prevent this from happening and allow for true protection of neighboring communities, region, and unreported escaping methane landfill gasses containing damaging toxic VOCS/forever more chemicals.
2. No waiver of penalties. No exceptions. Stricter penalties and acceptable methane levels.
3. Mandate drone methane detection over "entire" landfill that has a memory to be used for reporting. No exclusions including working face of landfill. It's accurate, safe for employees, can't be manipulated, fast, and the most effective accountable tool to protect the environment.
4. No alternative compliance. This escaping landfill gas/methane is very toxic to people and environment. No exceptions.
5. Require monthly monitoring and reporting using drone methane detection. Provides accountability, faster detection of leaks that need to be repaired due to all unforeseen unknown causes. Follow up on effectiveness of repairs, etc.
6. Candlestick flares can't be stack tested. There will soon be 2 dirty 24/7 candlestick flares at CHRL that offgass methane and toxic VOCS beyond the landfill. There needs to be stronger regulations for these to ensure safety, accountability.
6. Why so strict? Because current regulations aren't working and are being taken advantage of. No more loop holes. This helps provide accountability now and for future generations.

See Katherine Blauvelt, the circular economy campaign director for Industrious Labs comments. November 7, 2023 Fox 13 News, Concerns over explosive levels of methane in WA landfills
https://www.fox13seattle.com/news/wa-to-overhaul-landfill-rules-epa-docs-uncover-explosive-amount-of-methane-at-local-facilities

See attached Cedar Hills Regional Landfill Final Pergram drone methane report done January 2021 by BEW. Escaping landfill gas is everywhere. CHRL has lost 1/3 of gas from the last 2-3 years and leveled off. Where is it going? Air. This report was done to help improve LFG collection and clearly shows how the current regulations are severely broken and how effective drone methane reporting is compared to regulated methods.

Attachments:

Download

Comment From: Jacquelyn Green

12/11/23 @ 1:01 PM

I'm a citizen that lives near the Cedar Hills Landfill. Cedar Hills Landfill has a long history of non-compliance, litigation, and emissions that harm the surrounding community. My children attend Maple Hills Elementary, which is located only a coupl...↓e thousand feet from the Cedar Hills Landfill. The children at the school are at an increased health risk due to the emissions from landfill operations. I applaud and encourage stricter emissions to protect children and reduce greenhouse gas emissions. As the DOE considers new rule making, I ask that for the following items to be considered in the rule making process:
1. All areas of landfills should be monitored, with the exception of active areas that are accepting new waste. Cedar Hills has been shown to wildly exceed their permitted emissions. This was discovered by drone fly over completed by BioEnergy WA, public information request videos provided by King County Solid Waste showing exceedances, a class action lawsuit in 2000, and another class action lawsuit in the late 2000's that poisoned several homeowners. One of the ways Cedar Hills has evaded regulatory agency oversight is to not monitor sloped areas and interim areas. DOE should require monitoring on ALL areas (except active) to accurately gauge emissions. If ground monitoring cannot be done, drone monitoring should be required.
2. Cedar Hills Landfill is planning and has adopted a large scale expansion. This will include top filling closed areas, top filling interim areas, and constructing an additional area. DOE should not allow top filling of closed or interim areas, due to damage that construction and additional filling will cause to existing gas collection systems and also the amount of methane that will be released when permanent or interim covers are removed or damaged due to top filling and/or construction.
3. DOE should require that all landfills be in compliance of emission regulations before expansion activities are permitted. If current emissions are not in compliance, increasing the size of the problem will only increase emission issues.
4. Landfills that are located within two miles of schools or underserved communities should be tightly held to DOE rules regarding landfill emissions. DOE has a responsibility to protect children and communities who have been historically underserved/under represented. DOE must consider social equity and social justice.
5. DOE should not allow alternative compliance requests. Industries regularly use these to skirt laws and protections for the environment and affected communities. If DOE will be allowing alternative compliance requests, all alternative compliance requests should be made available to the public for comment and review.
6. DOE should dictate what type of landfill each facility is, rather than allowing the landfills to self-categorize.
Thank you for your consideration.

No attachments

Comment From: ED DZEDZY (Ed Dzedzy)

12/06/23 @ 1:32 PM

There are many small landfills, including three in Lincoln County that closed in September of 1993 to comply with new EPA Landfill standards. They closed operation a few months after the date identified in the methane rule that requires compliance. ...↓

No attachments

Comment From: Nancy Lust

12/06/23 @ 12:00 AM

Hi, my name is Nancy Lust and-- hang on, let me-- my video going here. I live next to the-- oh, my name is spelled, N-A-N-C-Y L-U-S-T. I would really encourage you folks to include limited-purpose landfills in this rule. They accept a lot of wood was...↓

No attachments

Comment From: William Lider

12/06/23 @ 12:00 AM

I'm William Lider. That's L-I-D-E-R. I'm a professional civil engineer in Lynwood, Washington. I'm very concerned that the limited-purpose landfills have been excluded from the methane requirements. I've submitted bill flag information on the Fruhl...↓

No attachments

Comment From: RMI (Ellie Garland)

12/06/23 @ 12:00 AM

Thank you. My name is Ellie Garland, E-L-L-I-E G-A-R-L-A-N-D, and I'm a senior associate with RMI. RMI is an independent, nonpartisan nonprofit working to secure a clean, prosperous, zero-carbon future for all, and we're very grateful to the Washingt...↓on State Department of Ecology for taking steps to control planet-warming methane emissions from landfills. As leaders around the world have underscored at this year's COP, fast action on methane is the single best strategy we have to limit near-term warming, and curbing emissions from landfills must be a part of this climate strategy. Beyond the climate benefits, stronger landfill standards bring important safeguards to communities living near landfills who face related impacts from air pollution and odors. We encourage Ecology to move swiftly toward a strong final rule, and we offer the following suggestions for further improvements around methane monitoring, data transparency, and gas capture. First, we recommend Ecology update the surface emission monitoring protocols to encourage the use of the most effective, readily available methane detection technologies. We urge Ecology to look to the US EPA's approved drone method and allow flexibility for future approved alternatives. Advanced detection technologies like drones are cost-effective, efficient, enhance worker safety, and provide better coverage of the landfill surface, including the working phase, than traditional CEM. Importantly, advanced automated methods are also less susceptible to human error or judgment. Canada is taking steps to mandate drone surveys in their proposed regulatory framework, and we encourage Ecology to follow suit. We also recommend Ecology take advantage of publicly available remote sensing data from aerial and satellite technologies to alert operators of large emission events and prompt fast repairs. We've seen successful campaigns conducted in Pennsylvania and California that leverage remote sensing data and have resulted in effective and quantifiable methane abatement. In addition, to improve transparency, we encourage Ecology to expand public access in a timely manner to landfills and emissions data. Finally, we encourage Ecology to take further steps to improve methane capture through more timely installation and expansion of the landfill gas collection system. EPA analysis shows that gas collection and control system expansion within one year of waste in place is feasible, cost-effective, and critical to control emissions from fast-decaying waste, like food waste. We encourage Ecology to consider other best practices that boost gas collection system efficiency and performance, such as automated well-tuning and more robust cover practices. A strong final rule is a win-win for the climate and communities, and we commend Washington's leadership and thank you again for your consideration.

No attachments

Comment From: Zero Waste Washington (Heather Trim)

12/06/23 @ 12:00 AM

Yes, good morning. I'm Heather Trim, H-E-A-T-H-E-R T-R-I-M, Executive Director of Zero Waste Washington. We're a statewide nonprofit, and our goal is to make trash obsolete, which means a lot less material going to the landfill. In fact, we are very ...↓supportive right now of HB 1799 that was passed by the state legislature and signed by the governor in 2022, and are working with many stakeholders on a large organics bill for 2024 to make sure that we don't keep creating more and more methane gas at the landfills because we are continuing to send organic material to them. Specific to this rulemaking, we will be submitting technical formal comments with a lot of detail, and I just want to highlight some of the highlights that, in fact, some of the other speakers have already spoken to. We are now at the point in this time, and as we are certainly having more and more impacts in terms of climate change, we need to be using the latest technology. One problem with the current rule is that it does not facilitate using drones to collect the methane gas by the owner and operators of the landfills, but also by third parties and have that be part of what Ecology considers in terms of regulating the landfills in terms of the methane gas. We should not be relying on people walking on a grid that's 25 feet and ultimately 100 feet wide that we're figuring out if there's methane leaking. There's no question that we need to be using the newest technology and as soon as possible. We'd like to see, A, that required in the rule or at least a very strong process to make that happen. The other thing is that, as was also mentioned, the food waste starts decaying and making methane gas immediately and a large part of that methane that's generated is done in the first three years, and yet the rule waits until five years before there is a requirement to expand the methane gas collection into those areas. That just does not make sense, and we would very much like to see that time frame shortened dramatically. We'll be putting that in our comment letter as well. Thank you so much. Washington's a leader on climate change with our governor and our legislature and our people, and we really would like to see a very, very strong rule coming out of this that goes well beyond all the federal stuff. Thanks so much.

No attachments

Comment From: Suellen Mele

12/06/23 @ 12:00 AM

Thank you for this opportunity to testify on proposed draft rules on landfill methane. I'm Suellen Mele, S-U-E-L-L-E-N M-E-L-E. I live in Seattle, and although I'm now retired, I worked for close to 25 years on recycling and waste prevention issues, ...↓and I'm currently volunteering with the 350 Washington Civic Action Team, as well as 350 Seattle. However, the following comments solely reflect my own point of view. As we watch the climate emergency becoming more and more severe, it's clear that we're running out of time. Methane is a super pollutant, and landfills are a major source of methane in Washington. We need to act as boldly and quickly as we are able. I appreciate the improvements to the draft rules already made by Ecology, but I urge you to further strengthen those rules. Every fraction of a degree increase that we can prevent is important. I want to briefly address three big-picture areas of the rules now, and then we'll follow up with more detailed written comments. First, it's critically important to get the monitoring requirement right. Landfills settle and shift so frequent and comprehensive monitoring is needed. I was extremely concerned to read a recent Grist article describing how EPA inspections at three Washington landfills found excessive levels of methane emissions. Some readings showed concentrations above 10,000 parts per million, more than 20 times higher than the federal limit. Unfortunately, the proposed draft rule does not require comprehensive monitoring and instead would lock in an ineffective and often unsafe system relying on humans walking a grid pattern to search for leaks. The rules should require, or at the very least specifically allow for, the use of remote sensing technologies such as drones. In addition, the rules should be strengthened by requiring more frequent monitoring to identify and correct problems more quickly. Second, I urge you to ensure timely planning and installation of the gas collection systems wherever possible. A recent EPA report indicated that 50% of the carbon in food waste is degraded to landfill gas within 3.6 years. We really need to get these systems in place as soon as possible. Finally, the proposed rules regarding reporting should be further improved to ensure transparency and accessibility by the public, including opportunities to comment on requested alternative compliance measures, as an earlier person here had commented on. Thank you again for this opportunity to comment, and I urge you to strengthen the rules.

No attachments

Comment From: Industrious Labs (Katherine Blauvelt)

12/06/23 @ 12:00 AM

Awesome. Katherine K-A-T-H-E-R-I-N-E, Blauvelt is spelled B as in Boy, L-A-U, V as in Victor, E-L-T. I'm a Circular Economy Director for Industrious Labs, which works across the country to support decarbonization of industry, including landfills. I j...↓ust want to say thank you to the Department of Ecology for shepherding this role, and certainly saw a number of improvements from the very preliminary rule that was provided. Unfortunately, the draft rule as it stands leaves quite a number of effective strategies, parameters, and technologies on the table. There's a real opportunity for Ecology to indeed strengthen the final rule and really make sure that the rule accomplishes what the legislature set out for the state, which is effectively mitigating methane from landfills. I'll just note a couple particular pathways. Just again, want to emphasize what we've heard from other folks today, which is the current looking for methane leaks, the current system is like Swiss cheese. We simply don't have to have that be the case anymore, because there are technologies, whether it's satellites or air flights, flying over to identify super emitter events, or it's using drone or other remote sensing technology, that technology is available today. This is the opportunity, really the only opportunity for Ecology to recognize that and include that in the rule, instead of the current, as I read it, sort of shuts the door on that. I also want to draw a distinction between allowing an alternative pathway and a requirement. We should always require the most effective practices, not make it optional. We are currently on an honor system using emissions monitoring technology and practices that are not getting the job done. Then one other piece that I wanted to note was simply the fact that there are a number of instances in the rule where surface emission monitoring and gas collection systems are weakened. I'll just give one example, which is the rule currently allows, during the detection of annual monitoring, if the leak cannot be remediated within 10 calendar days, that will result in a return to quarterly monitoring of the landfill. That is faulty logic. The length of time of remediation of a leak does not indicate whether there will be a leak in the future. There are many simple tweaks to the rule that can simply help us ensure that the rule does the job that it needs to, which is check these landfill emissions and methane emissions that are coming out of the ground today. Thanks.

No attachments

Comment From: Janet Dobrowolski

12/06/23 @ 12:00 AM

Hello, my name is Janet Dobrowolski, J-A-N-E-T D-O-B-R-O-W-O-L-S-K-I. I would just like to reiterate what I said before concerning technology, and like everybody else has mentioned that, that we need best practices. I would also urge more frequent mo...↓

No attachments

Comment From: Leslie Morgan

12/06/23 @ 12:00 AM

Can you hear me? Great. My name is Leslie Morgan. I had a couple of comments. One of my comments was that I don't believe that there should be any alternative compliance exception allowed. It completely diminishes the purpose of having regulatory sta...↓

No attachments

Comment From: Sarah Robinson

12/06/23 @ 12:00 AM

Hello. My name is Sarah Robinson. S-A-R-A-H R-O-B-I-N-S-O-N. I use she/her pronouns and I serve as advocacy manager for Earth Ministry Washington Interfaith Power and Light. Whether you live near a landfill or not, trash is impacting every person in ...↓the state of Washington. Every day and for many years past and future, lands, waters, and air become sacrificed and toxified in and around landfills. Landfills harm our communities, our kids, and particularly our vulnerable who live, work, and play in proximity to landfills. Washington's current landfill regulations aren't enough and unfortunately the draft rule doesn't get the job done. As our state faces record-setting rainfall, floods, and drought in the same year, we are witnessing the impacts of a changed climate. It is a moral necessity to adjust our policies to meet this unique moment in history. Our vice president offered remarks at the United Nations climate meeting this week addressing the importance of reducing methane to avoid burdening our world and our world's vulnerable with preventable harms. Methane represents over 80 percent or over 80 times the climate impact as carbon dioxide in the near term. Now is the time to prevent harm now and for our shared home into the future. Here in Washington, landfills pose unique challenges, and with robust rulemaking, we have an opportunity to reduce methane releases from landfills, improve job conditions for landfill and collection workers, and protect our communities from toxified soil, air, and water from landfills that mixed compostable food and yard waste with toxic waste. The Department of Ecology can make an immediate impact in dramatically reducing methane emissions across the state. It's not too late to strengthen the rule, close the loopholes, and require the most effective and available technologies and practices to stop the methane coming from Washington landfills. Landfill methane results largely from decomposition from organic matters such as food waste, which then when composted can absorb greenhouse gases instead of emitting them. Since moving to Washington, although I know how to sort garbage for recycling and compost, without municipal compost pickup, I haven't had the opportunity. Many people would be glad to create soil instead of garbage from their food waste. Compost in healthy topsoil can both help with water shortage and excess, preventing erosion during storm events like we are facing right now in Washington. The Hebrew Bible describes people as Adam from Adama translated as human being from living topsoil. Tribal religious and spiritual accounts speak of people as caretakers of the land and trust from the creator. Let us make meaningful change to contribute to future flourishing for people of Washington State and the world. Thank you for your time.

No attachments

Comment From: Spokane Zero Waste (Elyse Hochstadt)

12/06/23 @ 12:00 AM

Thank you. My name is Elyse Hochstadt. H-O-C-H-S-T-A-D-T. I'm in Spokane and I represent Spokane Zero Waste. We support Washington taking a lead on reducing climate impacts and strengthening this draft rule. Here in Spokane, much of our green waste, ...↓

No attachments

Comment From: Hope Barker

11/16/23 @ 9:47 PM

I would like to see Chapter 173-408 WAC become the new law regulating landfill gas emissions. I am specifically interested in the Bellevue WA proposed project at Airfield Park which is an old landfill. I am against building an aquatic center at thi...↓

No attachments

Comment From: Pamela W. Elicker

11/11/23 @ 6:26 PM

In Madison, Wisconsin the gases from the landfills have been captured to run the city's cars, originally. Now they sell the gas to a company that uses it to to make electricity or fuel for vehicles.
Could this be done in our state, at some of the la...↓

No attachments

Comment From: Diane Landry

11/05/23 @ 3:45 PM

Thank you for providing funding to the landfill operators to go along with the mandate.

No attachments

Comment From: Lois Powell

11/04/23 @ 11:06 AM

more important things in this state.

No attachments

Comment From: Emily McBride

11/04/23 @ 6:30 AM

Please enact rules to reduce methane emissions from Washington State landfills. It is direly important that we meet goals to halt further climate change damage.

No attachments

Comment From: Matthew Moore

10/31/23 @ 7:10 AM

Great! We are so far behind in mitigating our impact from daily activities. When true costs are ignored, behaviors will never change.

My only addition to this ruling, which I do not have time to read in depth is to include a requirement for a publi...↓

No attachments

Comment From: Paul Tabayoyon

10/30/23 @ 2:22 PM

Will all county operations be included in this policy process and regulations?

Are there permitting difference in different counties? In Yakima County our rules are often based around industrial exporting businesses or industry that do not correspon...↓

Attachments:

Download