By Jeryl L. Olson, Andrew H. Perellis, Kay R. Bonza, Patrick D. Joyce, and Craig B. Simonsen

Book with Environmental Law word on table in a courtroomSeyfarth Synopsis: The EPA’s new “Hazardous Waste Generator Improvements Rule,” while containing some changes that industry welcomes, also contains new requirements that present challenges for the regulated community. We will be publishing a series of blogs on the
Continue Reading Big Changes Coming – EPA Publishes its Hazardous Waste Generator Improvements Rule

By Patrick D. Joyce and Philip L. Comella

Today, the U.S. Environmental Protection Agency issued two proposed rules lowering the threshold at which landfills must control methane gas emissions.

For active landfills, EPA proposes to reduce the threshold from 50 metric tons of non-methane organic compounds annually to 34 metric tons. As a practical matter, this means that roughly 100
Continue Reading EPA Proposes Significant Change to Controlling Landfill Gas Emissions

Ecology Earth concept word collagePhilip Comella, in a recently published article, writes about how everyone in the landfill gas industry knows how contracts are a necessary evil.

The parties understandably focus on the engineering aspects of the design; how many wells and engines to install; how to increase or extend gas production; how the gas production translates into revenue; the status of carbon
Continue Reading Avoiding Disputes Down the Road: The Top Ten Problems With Landfill Gas Contracts

By Patrick D. Joyce, Philip L. Comella, and Craig B. Simonsen

The U.S. Environmental Protection Agency’s struggle to distinguish between a waste and a recyclable material, dating back to its original May 19, 1980 rulemaking under the Resource Conservation and Recovery Act, takes its latest turn in the now-final Definition of Solid Waste rule (DSW rule), signed by Administrator
Continue Reading EPA Publishes Massive Final Definition of Solid Waste Rule

By Patrick D. Joyce

The U.S. Environmental Protection Agency (EPA) today released a proposed rule that would update air standards for new municipal solid waste  landfills (landfills). 79 Fed. Reg. 41796 (July 17, 2014).

The Whitehouse had, earlier this year, issued an update to President Obama’s Climate Action Plan “Strategy to Reduce Methane Emissions.” The update specified that in the
Continue Reading EPA Proposes Updated Methane Limits for New Municipal Landfills and Requests Comment on Whether and How to Update Emissions Guidelines for Existing Landfills