Greenhouse Gas Reporting Protocols for Landfills

DEQ does not require greenhouse gas reporting from a landfill that does not accept waste during the emissions year if the landfill is not subject to EPA's federal greenhouse gas reporting requirements under 40 CFR Part 98 (e.g. landfills with annual emissions less than 25,000 metric tons of carbon dioxide equivalents).

Pursuant to Oregon rules, landfills are not required to report emissions from categorically insignificant activities defined in ORS 340-200-0020(18) to DEQ. Greenhouse gas emissions are typically difficult to quantify for these activities. The exemption applies to Oregon greenhouse gas reporting; however, if a landfill cannot separate categorically insignificant activities from other activities (such as a facility that has one fuel meter for all activities), it is acceptable for the landfill to report aggregate emissions that include categorically insignificant activities. Landfills reporting emissions to EPA should consult the federal reporting requirements to determine what emissions, if any, are exempt from federal reporting.

DEQ is extending the reporting deadline for the 2011 emissions year for landfills holding an ACDP or Title V permit from March 31st to April 11th. Each landfill must submit its greenhouse gas report to DEQ using DEQ-approved reporting protocols by April 11, 2012 or at the same time the landfill's annual report is due under the landfill's ACDP or Title V operating permit, whichever is later.

DEQ is also extending the deadline for landfills without an ACDP or Title V permit from March 31, 2012 to April 11, 2012.

The greenhouse gas reporting protocols differ depending on whether the landfill holds an Oregon air quality permit and whether the landfill is subject to the federal greenhouse gas reporting requirements, as described below:

• A landfill that does not hold an Oregon air quality permit and which is not subject to the federal greenhouse gas reporting requirements does not need to provide DEQ with any additional information other than what the landfill already submits annually to DEQ in compliance with its solid waste permit. DEQ will use EPA's Landfill Gas Emissions Model (LandGEM) and data associated with the landfill’s solid waste permit to calculate the landfill’s greenhouse gas emissions.
• A landfill that holds an Oregon air quality permit and which is not subject to the federal greenhouse gas reporting requirements is not required to report fugitive emissions from decay of waste at the landfill; DEQ will use data associated with the landfill's solid waste permit to calculate greenhouse gas emissions from the storage of waste at the landfill. However, if the landfill has stationary fuel combustion governed by the facility's air quality permit, such as combustion of captured landfill gas in a flare or for heat or energy, the landfill must report these emissions using EZ-Filer, DEQ's online reporting tool. A landfill combusting captured landfill gas must use the "biogas" fuel type. Captured landfill gas that is sent (e.g. for combustion or storage) at a different facility need not be reported.
• A landfill that is subject to the federal greenhouse gas reporting requirements may satisfy Oregon’s greenhouse gas reporting requirements by providing DEQ with a copy of its EPA report in place of reporting separately to DEQ. Oregon rules authorize DEQ to require the submission of additional information if the copy of the report submitted to EPA is not sufficient to determine all greenhouse gas emissions and related information required by DEQ. Any landfill that reports emissions to EPA solely under Subpart HH of 40 CFR Part 98 and which does not have other emissions subject to Oregon’s greenhouse gas reporting may submit a copy of the federal report to DEQ.

A landfill mailing the greenhouse gas report and documentation to DEQ must use the address below or submit the materials along with the facility's annual report required by the ACDP or Title V permit. A landfill submitting a copy of its federal report to DEQ may email the report.

Mailing address:

Oregon DEQ
Air Quality Division
Attention: GHG Program
811 SW Sixth Ave.
Portland, OR 97204