Undermining Alternative Energy Options with New Ozone Rule

Everyone agrees that developing alternative energy sources is one way to achieve better air quality. However, a new ground-level ozone standard that will go into effect just a few months from now is a perfect example of how a legitimate public policy objectives can sometimes be contradictory and even cancel each other out.

Recycling efforts and changes in packaging have actually reduced the amount of solid waste Americans are producing. However, a nation of 300 million people is still going to generate a lot of what we call “trash.” Much of this discarded material ends up in landfills. Fortunately, scientists and engineers have become innovative in how to tap the natural gas, a renewable biogenic fuel source, that is produced from these sites and use it to generate electricity in a relatively clean and efficient manner. Landfill gas (LFG) sites produce nearly 2,000 Megawatts (MW) of waste-based, renewable energy generated in the United States. Such projects generate enough energy to power approximately 1.2 million households and we’re just getting started.

However, the Environmental Protection Agency is getting ready to require states, cities and counties across the country to hold ground-level ozone, the particles that lead to unhealthy air, to just 65-70 parts per billion. The current requirement, in place since 2008, is 75 parts per billion. This incremental reduction over the next few years is going to very difficult to achieve. A lot of state-of-the-art technology is already in use to reduce ground-level ozone in places such as factories, industrial facilities and power generation facilities and more of us are adopting voluntary measures as well, such as not filling the gas tank until after sundown on hot days. So, to move the needle just five parts per billion would necessitate aggressive actions beyond those already in place.

The fact is, many areas of the country have not been able to meet the current ground-level ozone standard. When the more stringent standard goes into effect, many of these areas will have to take extraordinary measures to reduce ozone levels. An expansion in industrial, agricultural, construction work and other activities in these areas will have to apply the lowest achievable emission rate (LAER) technology. The only way for these areas to meet the new standard is to bar practically any new or expanded activity of this nature, which raises the specter of broader, unintended economic consequences. At the same time, getting to EPA-acceptable levels would be extremely challenging if at all impossible.

Landfill gas projects are underway throughout the country, helping to meet the growing demand for stable and renewable energy. In addition, such projects are an important component of EPA efforts to meet greenhouse gas reduction targets established in EPA’s Clean Power Plan. Under the proposed ozone standard, LAER would apply to many more landfills looking to utilize renewable energy projects requiring the use of more complex and expensive control equipment. In many cases this would not be cost effective or practical so the gas would simply be burned off, or “flared.” In other words, in this scenario, it would not contribute to the national effort to adopt innovations for renewable energy. Further, the new ozone standards would also adversely affect biogas projects, which also tend to be economically marginal.  The result is more flaring, fewer successful renewable energy projects and less incentive to pursue these innovative technologies in the first place.

The operators of solid waste disposal sites represented by the National Waste & Recycling Association (NWRA), as well as public sector solid waste disposal facilities are proud to play a role in advancing innovations in renewable energy. However, harnessing natural gas at these sites for power generation remains rather expensive. Since the EPA is not required to impose more stringent standards on ozone, it would be better to incentivize efforts to meet standards to succeed. According to the EPA, the new standard would cost our economy up to $15 billion.. Many experts project the cost to be much higher, and we will end up jeopardizing the very types of renewable energy projects the EPA wants to encourage.  The standards as proposed are counterproductive to renewable energy efforts, the environment and the economy.

Sharon Kneiss is the Chief Executive Officer of the National Waste & Recycling Association (NWRA).