Technology Shaping the Future of Landfills

The rollbacks to federal regulations announced by the U.S. EPA on March 12 could take months or years to go into effect if the agency follows federal procedures for rulemaking, experts say. But combined with the Trump administration’s plans for destaffing and budget cuts, the announcement could result in a dramatic shift in permitting rules and enforcement for owners of landfills, incinerators and other facilities.

Ryan Hathaway, the former White House director of environmental justice during Joe Biden’s administration, said the consequences of these actions would appear most immediately in communities near new or existing waste facilities.

“They are going to feel the impacts pretty quickly,” Hathaway said. “The lag isn’t going to be ... in regulations, the lag is going to be, how long does it take for increased impacts from health toxins in communities to show up?”

The EPA proposed 31 actions on March 12 that it said would reduce “burdensome” regulations on industry and undo the agency’s focus on climate change. Among those actions were planned rollbacks of certain industrial air standards and a planned change in the agency’s enforcement priorities, which previously focused on climate change, PFAS and other growing issues.

The EPA also confirmed it would shut down the Office of Environmental Justice and all related work.

Agency leadership released a series of memos laying out their proposed changes. One memo guiding EPA’s enforcement priorities instructed agency staff to deprioritize “environmental justice considerations” that “inform EPA’s enforcement and compliance assurance work.” 

The document also said enforcement of landfill methane emissions rules would “return to the core enforcement program.” The agency plans to continue enforcing Clean Air Act rules against MSW landfills that are out of compliance, according to EPA spokesman Jeff Landis.

“EPA continues to uncover noncompliance and for this reason, will proceed with investigating and initiating cases as part of the core civil enforcement program, as appropriate,” Landis said in an emailed statement.

For waste industry participants, these announcements are likely to mean little change to their work in the short term. While some states or local jurisdictions may respond with increased regulations, facility operators could expect greater flexibility in operations if reporting requirements are rolled back, according to the Solid Waste Association of North America.

“The waste and resource management industry will need to closely monitor the changes to stay in compliance with all federal, state, and local regulations and permits. Certain organizations have internal goals and commitments that they may continue to follow voluntarily, regardless of the mandated requirements,” Kristyn Oldendorf, senior director of public policy and communications at SWANA, said in an emailed statement.

The National Waste and Recycling Association did not respond to a request for comment.

Air emissions

Among the EPA’s planned rollbacks are changes to the Greenhouse Gas Reporting Program. For over a decade, the program has required thousands of facilities to report their greenhouse gas emissions for compilation in a public data portal. 

The EPA announced on March 14 that it would extend the deadline for operators to report their 2024 emissions from March 31 to May 30. It also released guidance documents explaining some of the changes it’s looking at for the program’s underlying regulation.

Specifically, the agency said it would address concerns brought by the waste industry regarding the accuracy of landfill emissions estimates. The agency is also contemplating revisions to the program as a whole to "streamline the reporting requirements."

Alterations to the data collection requirements could harm efforts to tackle the waste industry’s greenhouse gas emissions, according to environmental groups. Landfills are responsible for nearly three-quarters of the industry’s total greenhouse gas emissions and are the third largest source of methane emissions in the country.

“Removing access to vital information at such a crucial crossroads is like asking the American people to navigate a dark maze with no map or flashlight. It will do untold harm,” Katherine Blauvelt, circular economy campaign director at industrial climate solutions group Industrious Labs, said in an emailed statement.

The EPA administrator likely has broad latitude to shape the requirements of the Greenhouse Gas Reporting Program, said Mike McLaughlin, a senior vice president specializing in landfills at SCS Engineers.

“An administrator that wants to eliminate greenhouse gas reporting might say that we’ll require reports when hell freezes over. And if hell freezes over, we will require reports only for those who have greenhouse gas emissions more than a billion tons or something — essentially two absurd conditions that nobody meets,” McLaughlin said.

He also noted that landfill owners who participate in other reporting programs, either at the state level or for carbon credits, could miss the “regulatory seal of approval” an agency like EPA can provide.

If reporting requirements are dialed back, McLaughlin said it’s possible landfill operators will use the new flexibility to tinker with their gas collection wells and draw in less gas. But such actions could be complicated by state requirements.

Legal challenges could also thwart the EPA’s plans, three former EPA administrators said on a press call organized by the Environmental Protection Network. 

Still, the speed at which the agency is attempting to slash personnel and budgets may outstrip any legal attempts to prevent regulatory rollbacks, said William Reilly, EPA administrator during the George H.W. Bush administration.

”I fear very much the resources won't be there by the time they get around to it,” he said.

As the waste industry waits for the U.S. EPA to kick off a formal rulemaking on landfill air emission regulations, key voices are providing feedback on a series of white papers released by the agency in 2024.

The 10 papers provided an early glimpse into EPA’s thinking on several variables it could tweak in a future landfill regulation. They covered topics like cover material, aerial and fenceline monitoring, organic waste diversion and gas collection and control systems. The non-regulatory public docket for the white papers initially closed on Jan. 23, but that deadline was extended until May 23.

The agency is overdue to update its New Source Performance Standards and Emissions Guidelines for new and existing MSW landfills. The process is meant to occur every eight years, though the last update in 2016 wasn’t fully implemented until 2021.

The agency acknowledged its tardiness last year, and announced plans to update the rules in 2025. The EPA did not respond to a request for an updated timeline on its rulemaking.

Industry groups including NWRA and SWANA, research groups such as FluxLab and environmental groups like GAIA all provided comments in a public docket. 

Among the commenters, there was a divide between groups who favored mainstreaming the use of new emissions technologies and those who felt measurement technologies like satellites and drones were too new to replace standard surface emissions monitoring (SEM) methods.

NWRA and SWANA issued joint comments on the white papers.

On the whole, the two industry groups favored a status quo approach to regulation. They opposed bans on open landfill gas flares, new biocover requirements for intermediate cover, earlier installation of gas collection and control systems, a reduced working face size and other changes. 

On aerial monitoring technologies like drones, plans and satellites, the groups said "we do not believe that any of these technologies are sufficiently developed or available for mandated use through the Landfill Rules at this time, nor would they be appropriate for every site." 

That said, they encouraged continued evaluation of several technologies and practices, including alternative emissions monitoring methods.

Beyond opinions on the white papers, the NWRA and SWANA also urged the EPA to streamline existing regulations for landfill operators and speed up the review process for gas collection and control systems. 

FluxLab, the research group at St. Francis Xavier University, also submitted comments. It urged the EPA to consider setting up a prescribed certification process for aerial monitoring methods for landfills. It believes the technology is ready for widespread use, especially among larger landfills.

The group noted that its own study, conducted in coordination with the Environmental Research & Education Foundation, found that several forms of aerial testing are 40% to 60% more cost-effective than traditional ground methods of SEM, and can be effective. 

GAIA encouraged the EPA to adopt tactics to reduce harm on neighboring communities, noting longstanding environmental justice issues with the siting of landfills near disadvantaged communities. To mitigate harms, the group said EPA should adopt fenceline monitoring requirements, particularly near the active face of a landfill where emissions are highest. 

GAIA also urged EPA to take a closer look at certain pollutants emitted by landfills, particularly benzene and PFAS. On the latter, the group urged EPA to study the release of per- and polyfluoroalkyl substances via both landfill gas and leachate. The EPA could adopt several measures to reduce leachate generation, including improving cover practices, diverting organics, reducing the size of landfills' active face and mandating biocovers, GAIA wrote. 

EPA included among its white papers an exploration of organic waste diversion as part of landfill regulations. It contemplated a credit or alternative compliance system for landfills that engage in such activities, particularly composting, which produces less methane than landfilling. 

NWRA and SWANA argued the proposal was outside the scope of existing landfill regulations, though some industry players have been open to organics diversion projects. Orange County Waste & Recycling, a public entity which operates three landfills and two composting operations in California, urged EPA to streamline the permitting process for composting facilities on landfills.

Other commenters included LoCI Controls, SCS Engineers and the Institute for Local Self-Reliance. The EPA is expected to weigh feedback before issuing a notice of proposed rulemaking for NSPS and EG rules for MSW landfills, after which it will again examine comments before issuing a final rule.

Waste facilities, and frequently landfills, must contend with federal water permits when they have the potential to impact a "water of the United States." But the definition of that term has long been in contention, and the U.S. EPA is once again taking up the process to devise a new standard.

Determining what qualifies as a water of the United States under the Clean Water Act has been the subject of multiple U.S. Supreme Court cases, most recently in 2023, and every presidential administration this century has grappled with an appropriate definition. If a project affects a body of water covered under WOTUS, it must go through a more rigorous permitting process.

The EPA has made a flurry of moves in recent weeks to potentially loosen pollution rules for owners and developers of industrial facilities, in some cases upending years of precedent. The agency’s announcement on March 12 that it would revisit WOTUS adds another layer of uncertainty to a process already splintered by legal challenges.

“More than anything, clarity and certainty would be the things I really want,” said Drew Silton, an attorney with Beveridge & Diamond. “[If] I'm trying to develop a project, I'm trying to expand a landfill, I want to know definitively which features on a parcel of land are or are not a water of the U.S.”

Currently, 24 states, plus Washington, D.C. and U.S. territories, are implementing a version of the rule released by the Biden administration in 2023. The remaining 26 states are implementing a pre-2015 version of the law while their challenge to the Biden definition continues in court.

The Biden administration’s relatively expansive definition was first announced in January 2023. But the Supreme Court’s decision in Sackett vs. Environmental Protection Agency narrowed the scope of the regulation in May 2023, determining only wetlands that are directly and continuously connected to a body of water are subject to the Clean Water Act. Later that year, the EPA updated its definition of WOTUS to comply with the case without reopening the regulation for comment.

Silton noted the actions the Trump administration is taking today mirror what the president did during his first term, when he moved to restrict a version of the definition first promulgated under President Barack Obama. But the Sackett decision gives them a clearer legal framework to build from.

"Sackett nailed down one question while changing the battlefield we're going to keep playing on," said Silton. 

In a news release explaining the agency’s return to WOTUS, the EPA said it would consider a new, narrower definition to reduce “red tape” and “permitting costs”. The agency plans to schedule listening sessions to learn more about how the regulation impacts industry and slows project development.

“The previous Administration’s definition of ‘waters of the United States’ placed unfair burdens on the American people and drove up the cost of doing business,” EPA Administrator Lee Zeldin said in a statement. “Our goal is to protect America’s water resources consistent with the law of the land while empowering American farmers, landowners, entrepreneurs, and families to help Power the Great American Comeback.” 

The agency also indicated it would solicit input on the definitions of key terms in the regulation and the Sackett decision. EPA plans to examine what it means for a body of water to be “connected to” “relatively permanent” federal waters; what it means for a feature to have a “continuous surface connection” to federal waters; and when ditches should be considered a water of the United States, per a notice.

New language tightening the rule could impact permits landfill developers need to build new cells, said Mike McLaughlin, a senior vice president specializing in landfills at SCS Engineers. In particular, permits for dredging or filling rivers are sometimes needed but are also subject to Clean Water Act rules if they affect a water of the United States. The same is true for wetlands, which are sometimes impacted by landfill development.

It’s still unclear exactly how the WOTUS definition will change following the rulemaking process. But Silton said early indications suggest operators in compliance with the rule will still be in compliance with whatever scaled-back definition comes next.

Landfill operators in the United States have reduced their overall emissions by roughly 45% since regulations first passed in the 1990s, according to U.S. EPA data. But more can be done, vendors and speakers said at the Solid Waste Association of North America's Wastecon show last week.

The event, which featured panel discussions on a range of topics, included a discussion of the human influence on climate change from John Nielsen-Gammon, a climatologist at Texas A&M University and director of the Southern Regional Climate Center. Nielsen-Gammon said the waste industry can play a role in mitigating climate change, but that it will take "a lot of imagination" to advance solutions.

Amy Lestition Burke, the CEO and executive director of SWANA, said the session was a reminder that the waste and recycling industry has a "vital role to play" in impacting climate change. She also said a changing climate will have impacts on operations, equipment, training, budgets and more for its members. 

"We want to be on the offense, and to do that, we need to be prepared with information and data," Burke said in an emailed statement following the event. "These preparations tie into SWANA’s goals to make the industry safer and to be climate champions.”

Landfills represented 71.8% of the waste industry's total emissions in 2022, according to the EPA, and as such represent the biggest target for reductions. Awareness of fugitive emissions has risen at the same time as demand for energy has grown rapidly in the U.S., making capturing landfill gas not only important from a climate perspective but attractive as a revenue driver.

That demand growth is driven in part by the need for data centers, Bryan Black, co-founder and CEO of landfill-gas-to-energy company Nodal Power, said during a panel. He said that while electricity demand has historically grown slowly, the rise of artificial intelligence and other resource-intensive technologies has caused a rapid increase in demand for more energy.

“Ultimately there's a lot of [energy] sources that are going to be required to meet that need,” Black said. Increased energy prices as a result of that market imbalance have made gas capture lucrative.

Qnergy, a company that's fresh off a successful demonstration at a landfill in Weber County, Utah, hopes it can provide emissions abatement at the beginning and end of a landfill's life. 

Isaac Garaway, the company's chief technology officer, said Qnergy's Stirling engine system has worked effectively in the oil and gas sector for years. But the company has found a new use case for the technology — converting landfill methane that's "highly corrosive, wet and pretty much useless for other technology" into energy via a modular, scalable system.

Through a demonstration project in Maryland, Qnergy has fine-tuned its system for landfill gas specifically, creating a version of its technology that is capable of managing the variability of gases arising from landfills. The company plans to launch its standalone system for landfills in 2024, Garaway said.

Garaway said the technology turns something that was formerly a liability for landfill operators — the emissions released before landfill gas collection systems are installed or after the gas from a closed landfill becomes too dirty for traditional systems — into an opportunity to generate revenue via carbon credits. The company is willing to partner with public landfill owners to install a full gas collection system and operate it. It can also sell its technology to private landfill owners who just want to incorporate the technology into their existing systems, depending on each landfill's needs.

Another company, LoCI Controls, is also working to address landfill emissions with more modern technology. The company's monitoring system attaches to landfill gas wells and can adjust to changes in the composition of landfill gases in real-time. That has made the technology particularly useful for companies refining landfill gas into renewable natural gas. Such systems can only tolerate slight changes — less than 1% — in the relative oxygen content of landfill gas as it enters their RNG refining plants. LoCI's systems can detect such changes and adjust the vacuum in individual wellheads that may be sucking up too much oxygen from the landfill, potentially saving downtime for the plant.

Dave Hostetter, a vice president at SCS Engineers, said well monitoring technology can reduce labor costs by removing the need for engineers to investigate faulty wellheads in person. Instead, personnel can be redirected to addressing issues quicker and making gas collection systems as efficient as possible.

“That person that was doing it can now do something more productive,” Hostetter said. “We're trying to really leverage technology to get better results at your facility.”

Two groups have announced plans or launched new satellites in 2024 that can map fugitive landfill gas. The technology is maturing at a critical time for emissions mitigation, as regulators consider tightening restrictions on landfills and deadlines loom for global methane reduction commitments.

In November 2024, GHGSat announced plans to launch nine satellites by the end of 2026, nearly doubling its existing fleet of 12. Carbon Mapper announced the launch of its Tanager-1 satellite in August 2024, and it began reporting data from the satellite in November.

These satellites, which can home in on gases like carbon dioxide and methane, could play an important role in helping nations find and address greenhouse gas emissions, Jean-Francois Gauthier, senior vice president of strategy for GHGSat, said on a recent webinar.

“The bottom line is that in the past year we've detected more emissions than ever before, despite global pledges,” Gauthier said. “It's clear that both industry and governments need better data, as well as detection and monitoring capabilities.”

The expansion of monitoring technologies has earned increasing support from the public sector, as regulators and non-governmental organizations work to tackle plumes of escaped methane, a gas with more than 80 times the global warming potential of carbon dioxide over 20 years and a major component of landfill gas. The private sector, which includes large landfill owners, is also getting on board with the technology to tighten existing gas collection systems.

GHGSat, based in Quebec, is a private company that launched the first commercial satellite to measure greenhouse gas emissions from industrial sources in 2016. The company has worked with regulators like the U.S. EPA and Environment and Climate Change Canada to demonstrate its technology, and it has had its instruments validated by NASA and the European Space Agency.

Gauthier said satellites could play a role in making emissions data for landfills more accurate, something that has drawn the attention of environmentalists who say the industry and federal agencies are undercounting emissions with overly generous models.

He said that phenomenon played out as GHGSat monitored oil and gas wells over the last eight years. New data from satellites and other technologies has allowed scientists to find wells where models predicted emissions levels two or three times lower than real-world conditions, Gauthier said. After demonstrations of satellites’ success with oil and gas monitoring, the EPA has signaled its willingness to accept aerial imaging as a new monitoring technology in the sector.

Gauthier is hoping to repeat that process with landfills. Satellite companies are betting they can convince EPA to recognize satellite monitoring technology as part of a suite of modern technologies used to demonstrate compliance with landfill rules.

"It's a very different environment, because there's been so many advances in the last five, 10 years in all levels of measurements for methane," Gauthier said.

Carbon Mapper recently began updating its publicly available data portal with scans from its Tanager satellite. Though the nonprofit cautions the information is preliminary, it has already begun to identify several methane plumes originating from landfills in the U.S.

The largest such plume appears to be at GFL Environmental's Sampson County Landfill in North Carolina, a facility that has been flagged for emissions issues for years. The facility recently commissioned a system to convert landfill gas to renewable natural gas with Opal Fuels; that came online in October 2024.

Carbon Mapper said in a press release in October that its publicly available data portal can complement existing satellite monitoring efforts like NASA’s own EMIT system. Its scientists also hope the data can be used to inform local advocates near polluting landfills. The nonprofit, backed by major philanthropic donors and support from NASA’s Jet Propulsion Laboratory, plans to launch an additional Tanager satellite to complement the first.

Landfill engineers caution the satellites won’t be able to replace other methods of detecting landfill emissions. Different forms of advanced emissions monitoring are better for different scenarios, Dave Hostetter, a vice president at SCS Engineers said at Wastecon in October.

Generally speaking, "the further away you get from the methane, the more difficult it is to pinpoint where it's coming from,” Hostetter said. But satellites, in his view, have the benefit of being able to capture a snapshot of a landfill many times over the course of a relatively long equipment lifespan. 

In one example of this, GHGSat has been able to capture emissions from a landfill in Israel roughly 80 times over the past year and a half, Gauthier said. But he also agrees that satellites are not a one-size-fits-all solution.

“This is not a silver bullet; this is one tool to bring to the table to use in conjunction with measurements on the ground,” Gauthier said.

He also sees GHGSat as coexisting alongside an ecosystem of satellite networks, including those run by Carbon Mapper or agencies like NASA. Gauthier said GHGSat has been following Carbon Mapper for some time and “welcomes” the launch of their satellite, saying there may be room for collaboration in the future.

“It would be a little bit petty to see this as competition, honestly, because there is a need for as many satellites as we can [get] right now,” Gauthier said. “There are way too many emissions to start picking and choosing which instrument is being used for this.”

The U.S. EPA has an opportunity to significantly increase the efficiency of landfill emissions regulations with its anticipated update to Clean Air Act regulations in 2025, research group Industrious Labs argues in a new report.

Industrious looked at the opportunity to reduce emissions by requiring better landfill cover materials and practices. Its researchers also noted how such practices could mesh with the growing capabilities of new monitoring technologies, which are rapidly entering mainstream practices.

The report argues regulations are the best way to ensure the most up-to-date practices are applied across the widest swath of landfills. It found that its recommendations could lead to a 56% reduction in U.S. landfill methane emissions from 2025 to 2050.

The EPA signaled in July it would update its air emissions requirements for new and existing landfills in 2025. The updated New Source Performance Standards for new facilities and Emissions Guidelines for existing facilities would be the first promulgated since 2016. They would be published months later than EPA's legally obligated deadline to update such requirements every eight years.

Environmental groups have long said an update to landfill emissions regulations is overdue, as the Biden administration has made cutting methane emissions a key climate priority. A majority of MSW landfills in the country are currently required to comply with the standard, but getting the 2016 standard to apply to landfills has been a challenge. The regulation stalled under the Trump administration and was revived by the Biden administration. The current standard went into effect in 2021 and extended regulation to an additional 1,590 landfills.

In September 2024, the EPA released its findings from landfill inspections around the country over the last three years. It found "widespread" issues of noncompliance with existing landfill emissions regulations, many of which resulted in methane emissions exceedances.

While enforcement will be needed to tackle the issue of methane emissions compliance, a more comprehensive set of regulations tailored explicitly to methane will deliver the best results, said Katherine Blauvelt, circular economy campaign director at Industrious Labs.

"First and foremost, I think we can get the EPA out of playing the game of whack-a-mole and trying to find where there are issues of noncompliance," Blauvelt said. "Let's use the technology that's available today."

A growing body of evidence has shown the use of drones and satellite imaging can replace current landfill methane monitoring practices — which Blauvelt described as the antiquated, “Windows 2000” approach to tracking emissions. But the new Industrious report modeled the impact of improving methane collection abilities on the ground. They found that updates to landfill cover practices and gas collection and control systems could reduce landfill emissions by 2,922 million metric tons of carbon dioxide equivalent by 2050, cutting more than half of the estimated 5,197 million metric tons of CO2e that Industrious predicts landfills will emit if no changes are made.

“This analysis really simply confirms that dramatically reducing methane emissions from landfill is highly achievable, and that’s really timely,” Blauvelt said.

The report from Industrious found that EPA could extend landfill emissions regulation to cover more landfills and capture their methane emissions. Industrious' researchers propose that landfills with at least 200,000 tons of waste in place or that generate more than 664 tons per year of methane should fall under the regulation.

The EPA should also update what those landfills must do to keep a lid on their methane emissions, the researchers argue. Highlighting the EPA's own findings that 61% of methane from food waste is released from landfills before gas collection systems are installed, Industrious' report proposes that such systems should be installed within one year of waste being placed in a landfill cell. Those systems should also be required to incorporate horizontal gas collection components, integration with leachate management systems and other design improvements if necessary, per the report.

The report also took a look at cover materials required for landfill cells under existing law. Currently, requirements surrounding cover material are regulated by the Resource Conservation and Recovery Act, according to Industrious. Those regulations don't have restrictions around methane, and as such can contribute to methane leaks that are increasingly being detected via satellite imaging.

In certain cases, landfill operators can install better cover systems that oxidize landfill gas and lower the rate of methane generation. Industrious' researchers argued EPA should require landfill operators to take the latest research on such practices into account. 

"I think the main takeaway is how many of these emissions that we can reduce by doing these simple things," said Kim Finlay, senior campaign analyst at Industrious.

The U.S. EPA continues to study methane monitoring and best practices for landfills as part of its National Strategy to Advance an Integrated U.S. Greenhouse Gas Measurement, Monitoring, and Information System. In 2023, it also required the first landfill to use drone monitoring technology to comply with a consent order over fugitive emissions.