On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide. My posts describing and commenting on the strategies are all available here. This post addresses the Waste Advisory Panel enabling strategy recommendations.
I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Although the presentations all follow the same format the details differ. One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050. Most of the presentations added numbers to the slides so that it was not necessary to try to estimate the numbers. Such is not the case with the Waste panel presentation.
Moreover, there are problems with the data presented.. The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations. According to Part 496 the 1990 Waste greenhouse gas emissions in 1990 by IPCC sector in Global Warming Potential over a twenty-year time frame (GWP20) totaled 52.88 million metric tons (MMt) of carbon dioxide equivalent (CO2e) broken down as 3.03 MMt of CO2, 49.35 MMt of CH4 and 0.5 MMt of N2O. However, in the following graph the total is well above half the range between 50 and 60. Assuming that the wastewater component is not included in Part 496 brings the numbers close. The bigger problem is the claim that waste is 25% of the total in 1990 and 16% of the total in 2018. I guess the waste emissions in 1990 are 57 MMt and I know the 1990 Part 496 total emissions are 409 so that works out to 14%. I guess the waste emissions in 2018 are 55 MMt and I estimated that the sum of emissions from all the sides in the advisory panel presentations total 377 MMt and that works out to 15% for the waste % of total NY emissions. It could be a simple typo but in the absence of numbers in the graphic, readers do not know.
There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050. The projected total reductions emission reduction goals for the Waste Advisory Panel are a 17.6% reduction from 1990 by 2030 and a reduction of 70.5% by 2050.
According to the meeting minutes, the advisory panel proposed the following enabling strategies:
- Reducing methane generating wastes from disposal in landfills and combustors;
- Identifying and reducing fugitive emissions at waste and water resource recovery facilities;
- Reducing the need for new consumer products;
- Ensuring proper end-of-life materials management, with a focus on solid waste management hierarchy;
- Supporting domestic recycling facilities and markets for recovered resources, by emphasizing the highest and best use for recycling end products; and
- No promotion of new fossil fuel energy infrastructure.
The recommendations are available in a slide presentation. I am not going to critique these strategies individually because it would take far too long. Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues.
Clearly landfills have to be the target for reductions because it is the largest source. The plan is to achieve the “aggressive goals of Beyond Waste, the New York State Solid Waste Management Plan (e.g., 90% paper recycling and 65% food waste diversion by 2030)”. This program was adopted 12/27/10 but beyond mentioning that meeting the goals was necessary there was no further mention of the plan in the presentation or recommendations. Under the “Ease of implementation” category for Initiative #1: Organic Waste Reduction and Recycling, there is the following description: “Easy; The technologies exist, the challenges are financial (e.g., investment & end markets), behavioral, and logistical (e.g., siting, etc.)”. During the question-and-answer period of the presentation Anne Reynolds asked about the status of the goals of the over ten year old Beyond Waste Program as a means of assessing how difficult achievement of the recommendations presented today might be and Ms. Rowland noted that “the State is roughly one-third of the way to 90% on the paper recycling and traditional recyclables, with significant work left to do on organics, as only about 2-3% is diverted.” In my opinion, the financial, behavioral, and logistical challenges defined as “easy” are not. Note that many of the recommended initiatives require legislative and regulatory action to make these “easy” changes.
There are folks involved with this process that have convinced themselves, contrary to the text of the law, that the zero-emissions mandate refers to all emissions and not just GHG emissions. I suspect that they are disappointed that the panel projects no reduction projected from existing combustor facilities will be needed to handle municipal solid waste remaining after reduction, reuse, and recycling strategies.
The advisory panel process and the Climate Action Council meetings provide a window into the hopes and dreams of the segment of the population that is driving the concept that the existential crisis of climate change can be solved simply by ending fossil fuel use as quickly as possible. The “no promotion of new fossil fuel energy infrastructure strategy” is the result of their concerns. Many of the most vocal people in this process are as passionate about this cause as they are clueless about the complexity of the energy systems and tradeoffs of their purported solutions. Renewable natural gas is a very good example of the resulting problem.
According to EPA:
Renewable natural gas is a term used to describe biogas that has been upgraded for use in place of fossil natural gas. The biogas used to produce RNG comes from a variety of sources, including municipal solid waste landfills, digesters at water resource recovery facilities (wastewater treatment plants), livestock farms, food production facilities and organic waste management operations.
The ultimate problem replacing fossil fuels with renewable wind and solar energy is providing power during periods when both resources are near zero. In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included the following slide that notes that during these periods “firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits”. In my opinion, those benefits include keeping the lights on.
In light of the critical need for these firm, zero-emissions resources and the fact that the methane emissions from municipal solid waste landfills, digesters at water resource recovery facilities, livestock farms, food production facilities and organic waste management operations are a major percentage of the total emissions, it only seems logical to address both problems by developing those resources. However, there are passionate ideologues that don’t agree. The meeting minutes note “concern regarding renewable natural gas, suggesting that there is a limited opportunity for it to contribute to Climate Act goals and believes that efforts in this area benefit the source without contributing additional environmental benefits”. Another member “expressed his concerns about how to move ahead with biogas if it is combusted as this would clearly increase net co-pollutants locally, and suggested the Council consider applications for biogas that would not be combusted (such as fuel cell technology at wastewater treatment plants)”. Nonetheless the panel’s enabling initiatives included biogas recovery and agency staff argued for its use.
Most of the other strategies proposed identifying leaks and eliminating them. As part of New York’s irrational war on methane the new leak detection technology that has identified many new sources of methane is considered a rationale for eliminating the use of natural gas instead of an opportunity to make the source of energy that enabled most of the observed GHG reductions since 1990 even better. Because the residence time of methane is on the order of 12 years eliminating leaks has much value.
There is another aspect to the leak issue related to the cluelessness of some panel members. One of the other panels has a strategy that includes a public relations campaign to remove the label “natural” from natural gas because they allege that the name was chosen for advertising purposes. They presume that if the public only understood it was not natural then they would not be so likely to use it. The problem with that of course is that it is called natural gas because it is a naturally occurring gas. Wherever a geologic formation that contains natural gas is exposed to the air, natural gas can be released to the atmosphere. For example, western New York’s Eternal Flame Falls has a vent that seeps natural gas, and someone, sometime lit it off. It remains to be seen if this natural vent will be sealed off in the name of climate change mitigation but the bigger issue is what to do about all the other sources of naturally-occurring methane.
There are consistency issues with some of the numbers presented that I could not reconcile. Using the numbers provided, this sector generates under 15% of the total New York GHG emissions but it is notable that the strategies are only expected to reduce emissions 18% in 2030 as opposed to the target of 40% and only 71% in 2050 as opposed to the target of 85%. Clearly, this panel recognizes that there are limits to what can be achieved even though the results are disappointing.
Even though the enabling strategies do not meet the CLCPA targets, the results of the 2010 Beyond Waste, the New York State Solid Waste Management Plan suggest that even these strategies may be too optimistic “as only about 2-3%” of food waste is diverted as opposed to the 65% goal. The concession that no reduction is projected from existing combustor facilities needed to handle municipal solid waste remaining after reduction, reuse, and recycling strategies also suggests these are aspirational strategies.
The ideologues involved in this process hinder rational mitigation approaches. Collecting and using methane wherever possible not only addresses an emissions problem but also helps address a major concern related to reliability. It is scary that irrational concerns about using renewable natural gas were not cut off as untenable at the outset. Another example is not recognizing that natural gas leak detection technology advances are an opportunity to reduce emissions from the resource that has provided most of the recent co-pollutant and CO2 emission reductions rather than a reason to eliminate its use.
 The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.