Landfill Gas as a Tier I Resource under AEPS

PWIA members are fighting to protect the classification of landfill gas as a Tier I resource under the Alternative Energy Portfolio Standards Act (AEPS). Without this classification, the continued viability of landfill gas-to-energy projects in Pennsylvania would be at risk.

The classification of landfill gas as a Tier I resource under the AEPS is critical to the continued use of landfill gas to make renewable energy. Municipal solid waste disposed of in landfills decomposes through a natural, anaerobic process that generates landfill gas (approximately 50% methane) and is collected in a series of underground pipes.  Landfill gas used to make electricity is classified as a Tier I resource under the Alternative Energy Portfolio Standards Act (AEPS).

Pennsylvania ranks third in the nation for the number of operating Landfill Gas to Energy (LFGTE) projects operating, with 39 LFGTE projects currently operating. Most of these projects combust landfill gas to generate baseload electricity. Other projects produce a renewable fuel, as defined under Federal law, for supply to pipelines, manufacturing and other end-users. The most recent Climate Change Action Plan Update published by PA DEP in August 2016 indicated that landfills had 275.5 MW of electric generating nameplate capacity, in addition to producing significant quantities of fuel.1

According to US EPA, 56% of landfills across the nation use landfill gas beneficially, whereas that rate jumps to over 80% in PA.2 The White House’s 2014 Climate Action Plan, Strategy to Reduce Methane Emissions cited a Pennsylvania landfill as the national case study on how to reduce GHG emissions from landfills.3

According to calculations performed in 2016 using the United States Environmental Protection Agency’s Landfill Methane Outreach Program’s (US EPA) Benefits Calculator, PA landfills reduce greenhouse gases by 7.23 million metric tons per year, which is the equivalent to the annual greenhouse gas emissions that occur from 1,416,000 passenger cars.4 US EPA also recognizes use of landfill gas as reducing other air pollutants.

Use of landfill gas turns waste into a useful product; without an LFGTE project, the landfill gas is burned in a flare with no energy or economic recovery.

These projects typically generate baseload electricity and have a high annual utilization rate — 95% of nameplate capacity. Baseload electricity provides stability to the electric grid. Electricity generated using landfill gas is universally recognized as renewable energy, including under the PA AEPS.

These projects also supply electricity to critical landfill operations and local infrastructure during power outages and other grid emergencies. In fact, the PA Public Utility Commission recognizes landfills producing electricity as “critical infrastructure” under PA law.5

The overall economic benefits of using landfill gas to make electricity are considerable. A 2004 study, conducted by US EPA and published by PA DEP, found significant job creation, direct spending, revenues and on-going employment as a result of projects at Pennsylvania landfills.

Many of the landfill gas projects operating today rely on the incremental income that they generate under the AEPS as a Tier I resource. Without participation as a Tier I resource, the continued viability of these projects would be questionable and the development of future projects would be chilled. As a result, Pennsylvania would potentially lose the environmental and economic benefits from these projects. Continued support through the AEPS is critical to these projects’ on-going viability as well as the development of and investment in future projects.


1 PA DEP, 2015 Climate Change Action Plan Update, p. 121 (Aug. 2016),‌elibrary/GetDocument?docId=5342&DocName=2015%20CLIMATE%20CHANGE%20ACTION%20PLAN%20UPDATE.PDF%20.

2 US EPA lists 619 operational and 480 candidate landfills nationally for LFGTE projects, with 39 operational and 9 candidate landfills in PA. LMOP, Project and Landfill Data by State, U.S. EPA, (last visited Apr. 11, 2019).

3 Exec. Order No. 13,624, 3 C.F.R. 299 (2013).

4 Presentation, Landfill Gas to Energy (LFGTE), by Mark C. Hammond, on behalf of PWIA, to PA DEP (Feb. 7, 2013) (on file with author).

5 In re Pennsylvania Waste Industries Association, Docket No. P-2017-2637800 (Pa. Pub. Util. Comm’n Apr. 5, 2018),