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Draft Supplemental Environmental Impact Report Page IV.D-27 Forward Inc. Landfill 2018 Revised Project (25,000 metric tons/year of CO2e)16 to the State; and the project size will be compared to the estimated State GHG reduction goal of approximately 169 million metric tons of CO2e per year by 2020. As noted, the 25,000 metric ton annual limit identifies the large stationary point sources in California that make up 94 percent of the stationary emissions. If the project's total emissions are below this limit, the total emissions are equivalent in size to the smaller projects in California that as a group only make up six percent of all stationary emissions. It is assumed that the activities of these smaller projects will not conflict with State's ability to reach overall goals outlined within AB 32. In reaching its goals the CARB will focus upon the largest emitters of GHG emissions. C)Any potential conflicts with an applicable plan,policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. 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 GARB, 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 (SWIGS)site-specific values for collection efficiency, methane oxidation in landfill cover", and methane destruction efficiency in the flare and engines.1, 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 16 The State of California has not provided guidance as to quantitative significance thresholds for assessing the impact of greenhouse gas emissions on climate change and global warming concerns. Nothing in the CEQA Guidelines directly addresses this issue. 17 These rates account for the landfill cover type,results of surface emissions monitoring,and the liner type at the landfill. 11 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.