Colorado on precipice of nation-leading standard to protect communities and climate
Colorado has a unique opportunity to lead the nation in tackling one of the most potent greenhouse gases: methane. With draft updates to state landfill emissions standards imminent, the question is whether the state will meet the moment and propose effective, comprehensive measures and 21st-century technology.
The Methane Challenge
Methane is a super-pollutant with approximately 80 times the global warming potential of carbon dioxide over a 20-year period. Landfills in Colorado emitted more than 6.2 million metric tons of CO2 equivalent methane in 2022, surpassing emissions from coal mining and nearly tripling those from aviation fuels. This staggering figure makes it clear that landfill methane is a major contributor to the state's greenhouse gas inventory. Scientific studies have shown these emissions are understated, as the state itself acknowledges (slide from a recent CDPHE public meeting):
Despite efforts to control landfill emissions, methane escapes through diffuse surface emissions and concentrated plumes. Current monitoring methods rely on quarterly human inspections and are outdated and inadequate. They fail to capture the full scope of emissions, leaving vast areas unmonitored and allowing significant leaks to go undetected.
Solutions for a Better Future: Colorado Asking for Public Feedback this Month on Their Proposal
Colorado has already demonstrated leadership in tackling methane emissions in the oil and gas sector through stringent regulations and comprehensive monitoring efforts. The state is well-positioned to apply similar strategies to landfill methane, leveraging its experience and resources to achieve significant reductions.
The Colorado Department of Public Health and Environment (CDPHE) is in the midst of taking public feedback on what they could include in an update to state landfill methane regulations, marking a critical step toward addressing this pressing issue. In April, CDPHE will present draft rules to the Air Quality Control Commission. At that point, it becomes an official Public engagement, and support will be crucial to ensuring these regulations are robust and effective. CDPHE is holding its last virtual public feedback session on Wednesday, February 26th, 6 - 8 pm mountain time - you must register to attend - please make your voice heard!
The good news is that solutions exist, and they are both effective and readily available. Industrious Labs and Healthy Air Healthy Water Colorado detail the problems and solutions in our recent report, Mountainous Methane. But how does what CDPHE has proposed so far, stack up to what is possible?
Here’s a quick analysis of what the State of Colorado has shared in their two public meetings (check out their slide deck and recording here):
Colorado proposes Necessary Upgrades to Better Find and Fix Methane Leaks
Closes loopholes that allow landfills to slip through the cracks: Most landfills emit methane — but today, only landfills that meet poorly designed criteria are required to take common-sense steps like installing gas collection systems to capture methane gas. These insufficient thresholds mean that many landfills go unregulated and are able to get by without adhering to basic best practices - In Colorado, according to CDPHE, only 10 municipal solid waste landfills - out of over 50 - have to install a gas collection system under the current threshold. Methane doesn’t care about regulatory thresholds. That’s why it’s great news that CDPHE proposes revising thresholds to ensure more methane-generating landfills are held to minimum standards.
Closes loopholes that allow unchecked methane to escape before gas collection is required: A recent EPA report found that “an estimated 61 percent of methane generated by landfilled food waste is not captured by landfill gas collection systems and is released to the atmosphere. Because food waste decays relatively quickly, its emissions often occur before landfill gas collection systems are installed or expanded.” The report further estimates that fifty percent of the carbon in food waste degrades into landfill gas within just 3.6 years. The U.S. EPA further states in their recent white paper that ”Implementing a shorter time between threshold exceedances or landfill expansions and GCCS installation and operation can result in earlier control of LFG emissions versus the current NSPS/EG requirements.” It’s also great to see that CDPHE is considering shortening regulatory timelines to better match the rapid degradation rate of food waste and mitigate methane emissions and installing horizontal collectors and wells in active areas of a landfill, which is a huge source of methane emissions.
Biocovers on closed landfills or landfills without enough gas to operate a flare: Research has found that the type of cover on a landfill is the most significant factor impacting the flux of emission. Yet current air emissions regulations are silent on the type or timing of landfill cover. CDPHE proposes an incremental improvement from the status quo, which would be to deploy biocovers for the interim or final cover at landfills that can’t collect enough landfill gas to dispose of it through destruction, as a way to reduce methane emissions. Biocovers oxidize methane, converting it to water and carbon dioxide.
Requiring finding and fixing big emissions found by remote sensing: CDPHE suggests that they would essentially create a super emitter program, requiring landfills to respond to methane leaks detected by flight or satellite monitoring. This is common sense and would be a game-changer in addressing very large point sources. Even if we embrace current advanced methane detection technology, data is only as good as what we do with it. When large emission sources, sometimes called “super-emitters”, are identified over landfills, landfill operators aren’t currently required to do anything about them. If a fire department received reports of smoke billowing out of windows, there’s no question that they should be required to respond. Why are large plumes of highly potent greenhouse gas treated differently? Colorado regulators should require landfill owners to turn data into action and address major sources of methane leaks once they’re identified.
Missed Opportunities: The state still has the opportunity to include missing upgrades
Colorado still has key opportunities to strengthen its landfill methane draft rules, including requiring fenceline monitoring, better minimizing emissions from the active face, and mandating automated wellhead tuning. Additionally, drone monitoring should be required rather than voluntary, and all emissions data should be made publicly accessible.
Doubles down on a very ineffective manual method to find invisible methane: Unfortunately, CDPHE continues to rely on human-based, infrequent monitoring for methane leaks. These methods are, by definition, spotty, vulnerable to human error, and pose safety threats to landfill inspectors, causing leaks to go undetected. The White House itself, in its national monitoring strategy, acknowledges that human-based surface emissions measurements alone are insufficient. It’s an exciting time to address landfill methane, as advanced methane sensing technology such as sensors and drones are operational, proven, and catching on. They can comprehensively monitor large areas, with greater frequency and accuracy, to provide California landfill operators and regulators with the missing information they need to find and mitigate methane leaks. CDPHE is considering establishing its own process to approve alternative technology for leak screening, which could include more effective advanced monitoring technology - but this more effective technology should be mandatory, not optional. They should also consider ensuring that landfills deploy methane and co-pollutant monitoring, such as fixed sensors, at the landfill boundaries, especially near communities, to detect and fix leaks far more quickly than every 120 days.
No guardrails on largest source of emissions: the size of the active face: A Carbon Mapper and U.S. EPA scientific paper, Investigating Major Sources of Methane Emissions at US Landfills, analyzed findings from 217 open landfills across 17 US states. Across states, they saw large fractions of observed landfills emitting. Landfills with significant work face emissions were consistent across surveyed states, and the largest share of emissions came from the working face. CDPHE can build on its already-proposed upgrade of including gas collection under the active face, by also defining acceptable active face sizes relative to the volume of incoming waste and requiring operational plans to be implemented by the operator.
Continues to rely on “dumb” pipes, missed opportunity to upgrade to continuous monitoring to boost gas collection: CDPHE should ensure the use of monitoring technologies that use wellhead sensors to adjust the gas collection system automatically, particularly for landfills that produce gas-to-energy. Landfills with so-called “renewable natural gas” projects want to maximize the amount of high-quality methane they collect, which can result in drawing less gas where the methane quality might be lower, causing even more fugitive methane emissions to escape. That’s why it’s particularly important for CDPHE to require technology that can provide real-time data on gas composition, flow rates, and pressure, greatly optimizing methane capture and improving gas collection rates. As the U.S. EPA noted in their recent white paper, “Automated wellhead tuning has emerged as a solution to address these challenges by dynamically adjusting system parameters like vacuum pressure and flow rates in response to real-time data … Similarly, automated wellhead tuning can assist in remedying damages to the gas capture and collection systems. Damage to the collection system can occur and remain unnoticed until monthly wellhead parameter checks.” Leveraging this technology allows operators to quickly identify problems and take corrective action, which can significantly enhance methane recovery while addressing leaks, watered-out wells, and vacuum loss in near real-time.
Taking action to reduce landfill methane emissions will provide numerous benefits to Colorado residents, including improved public health, as reducing methane emissions will also cut harmful pollutants like volatile organic compounds (VOCs) that contribute to respiratory illnesses and other health issues. Communities near landfills will experience better air quality and fewer health risks. Reducing landfill methane emissions is not only a climate imperative but also a public health necessity. Methane leaks are often accompanied by other harmful pollutants that can impact air quality and pose health risks to nearby communities. Taking action now will protect public health, improve air quality, and contribute to Colorado's climate goals. Lower methane emissions also contribute to slowing climate change, preserving Colorado's natural landscapes and biodiversity.
Colorado has a chance to lead by example in landfill methane mitigation. By adopting advanced technologies, strengthening regulations, and investing in organic waste diversion, the state can significantly cut emissions and set a national precedent. With the right policies and community support, Colorado can turn its methane challenge into an opportunity for environmental leadership and sustainable progress.
To stay informed and support landfill methane reduction efforts, visit EcoCycle’s action page for updates and opportunities to get involved. And don’t forget to join the state’s last virtual public feedback session on Wednesday, February 26th, 6 - 8 pm mountain time - you must register to attend.
