NWRA Comments on Proposed Greenhouse Gas Assessment Draft Rule in Washington State

NWRA Comments on Proposed Greenhouse Gas Assessment Draft Rule in Washington State

Arlington, VA – The National Waste & Recycling Association (NWRA) filed comments in response to the Washington Department of Ecology’s draft Greenhouse Gas Assessment for Projects (GAP) rule. In its comments, NWRA identified certain areas of concern, notably that while the waste industry has made significant investments that have resulted in substantial reductions in emissions, there is no accepted method for the direct measurement of landfill emissions.

In the comments, NWRA addressed several other areas for consideration:

  1. Requirement for separate reporting for biogenic and anthropogenic emissions
  2. Inclusion of onsite prioritization for mitigation projects
  3. Harmonization with the Environmental Protection Agency’s greenhouse gas reporting methodology

“NWRA appreciates the opportunity to comment on the draft rule from the Washington Department of Ecology. We are hopeful to collaborate with the agency to gain clarity on how the waste sector would implement the GAP rule,” said NWRA President and CEO Darrell Smith. “Our member companies continue to work hard to manage landfills efficiently and support emissions reductions.”

Landfills are highly engineered facilities that comply with stringent local, state and federal regulations. New and expanded landfills must incorporate landfill gas collection and control technologies into their designs and operations.



The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and a variety of other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association