Q121. The applicability tool refers to a 350,000 waste-in-place threshold. Is reporting required if the total waste-in-place is less than 350,000 tons?
A121. The purpose of the applicability tool found on the EPA website is to give potential reporters guidance as to whether they meet the threshold of generating 25,000 tons CO2 equivalent and are therefore required to report under the rule. There is no 350,000 metric ton capacity limit or waste-in-place exclusion in the rule. The 30 year waste-in-place of less than 350,000 metric tons was estimated as the quantity below which a typical landfill, using the bulk waste model, would not exceed the 25,000 ton CO2 equivalent reporting threshold. Some facilities may have much higher methane generation. Please refer to the disclaimer for the use of the applicability tool. Facilities are encouraged to perform generation and emission calculations based on the methods specified in 40 CFR 98, Subpart HH to determine if reporting is required. According to the rule, if a landfill generated more than 25,000 metric tons of CO2 equivalent calculated according to subpart HH, it is required to report emissions.