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Draft Supplemental Environmental Impact Report Page IV.D-28 Forward Inc.Landfill 2018 Revised Project The Forward Landfill would be required to comply with all applicable State plans, policies and regulations, such as AB 32 regulations and CARB's Scoping Plan(Item A). The Scoping Plan and updates will generally be implemented through mandatory regulation enacted by the CARB, and regulations that address methane emissions from landfills are one of the target GHG emissions that will be regulated. The proposed project would be required to comply with applicable provisions of the recently adopted regulation to reduce methane emissions from municipal solid waste landfills (CCR,Title 17,Subchapter 10, Article 4,Subarticle 6,Sections 95460 to 95476, Methane Emissions from Municipal Solid Waste Landfills [Landfill Methane Rule]).The Landfill Methane Rule contains performance standards for the gas collection and control system, and specifies monitoring requirements to ensure that the system is being maintained and operated in a manner to minimize methane emissions.The Landfill Methane Rule includes a leak standard for gas collection and control system components, a monitoring requirement for wellheads,methane destruction efficiency requirements for most control devices, surface methane emission standards, and reporting requirements. ' Table IV.D-6 shows the net total GHG emissions from the landfill future potential scenarios compared to the current actual and current permitted conditions(Item B). The GHG emissions ' are based on Solid Waste Industry for Climate Solutions(SWICS) site-specific values for collection efficiency,methane oxidation in landfill cover", and methane destruction efficiency in the flare and engines.18 The project's GHG impacts include five components: methane emissions,biogenic CO2 emissions,emission reductions from energy displacement, off-site haul truck mobile emissions and sequestered carbon. The methane emissions are anthropogenic and are considered a GHG emission from the landfill.19 The biogenic CO2 emissions are not attributed to the landfill since CO2 emissions from refuse would normally occur in the natural carbon cycle. The emission reductions from energy displacement are a credit for the landfill as the production of electrical energy is displacing GHG emissions from electrical generation from other sources. The off-site haul truck mobile emissions are on-road emissions from transporting the wastes to Forward Landfill.The carbon sequestration is also a credit for the landfill. However, as a conservative assessment the sequestration is not included in the calculation.20 Thus,the total GHG emissions from Forward Landfill are the sum of the methane emissions plus the stationary combustion ' emissions plus off-site haul truck emissions minus the energy displacement credit. "These rates account for the landfill cover type,results of surface emissions monitoring,and the liner type at the landfill. 1e SCS Engineers,Current MSW Industry Position and State-of-the-Practice on LFG Collection Efficiency,Methane ' Oxidation,and Carbon Sequestration in Landfills,Version 2.2,January 2009. 19 Methane emissions are considered to be anthropogenic because they are caused by the artificially anaerobic conditions in the landfill. 20 Landfills are a place where carbon is stored,removing it from the carbon cycle and preventing its emission as ' carbon dioxide.When waste is placed in a landfill,not all of the carbon decomposes into methane and carbon dioxide.The carbon that does not decompose is sequestered in the landfill.Sequestered carbon is not emitted to the atmosphere as either carbon dioxide or methane,removing it from the carbon cycle resulting in reduced greenhouse gases.The inclusion of carbon storage in a landfill greenhouse gas calculation is not universally accepted,but it is I consistent with USEPA methodologies and inventories.It should be noted that the amount of carbon sequestered is greater than the GHG emissions from the landfill for all scenarios. If carbon storage is included in the GHG total for the project,the Project lowers the GHG emissions because more carbon is sequestered in the landfill where it would not be emitted as either methane or CO2.