Comment Letter: Proposed EPA Methane Standards for Landfills

October 23, 2023
all in trash 3

Dear Administrator Regan:

We, the undersigned organizations from the America Is All In coalition, thank the U.S. Environmental Protection Agency for its leadership in taking actions to reduce climate and health harming pollution from some of the nation’s largest industrial sources. Building from this record of leadership, we respectfully ask the EPA to take swift action to keep food waste out of our nation’s landfills and reduce planet-warming methane emissions from waste already in place.

America Is All In is the most expansive coalition of leaders ever assembled in support of climate action in the United States. Mobilizing thousands of U.S. cities, states, tribal nations, businesses, schools, and faith, health, and cultural institutions, the coalition is focused on pushing and partnering with the federal government to develop an ambitious, “all-in" national climate strategy that meets the urgency of the climate crisis; scaling climate action around the country to accelerate the transition to a 100 percent clean energy economy; and promoting the leadership of non-federal actors on the world stage.

Subnational actors across the country are already taking steps to keep methane-generating organic waste out of landfills. We have made systems changes to reduce food waste and ensure surplus foods are recovered to feed those in need. Food scraps that remain are diverted by community composting or curbside composting programs, creating valuable soil products. Several states, such as California and Maryland, have gone further, with both source reduction and diversion initiatives and operational requirements for landfills to better control emissions from buried waste. 

However, the pace of current action is not enough. Federal policy is essential to scale methane prevention and mitigation efforts from a few leading localities and organizations to a nationwide, equitable approach. We need fast action from the EPA to deliver the methane reductions urgently needed this decade to avoid the worst consequences of the climate crisis.

Specifically, we ask the EPA to:

  • Develop and implement a roadmap to phase out organic disposal in landfills and incinerators by 2040, while expanding grant funding and technical assistance for subnational efforts to reduce waste, donate edible surplus, convert food scraps to animal feed, and compost, digestion, or otherwise recycle the residual organics. EPA should prioritize alternatives to landfilling and incineration that maximize benefits for the environment, society, and the economy – helping to address food insecurity, reduce dependence on land-intensive feed crops or carbon-intensive fuels, improve soil health, sequester carbon, and create jobs. 
  • Through a rulemaking, update its existing landfill standards, with the goal of better controlling harmful emissions. Strategies are available to better prevent, detect, and mitigate methane leaks from landfills, but EPA standards have not kept up. The EPA should immediately open a rulemaking on municipal solid waste landfill emissions standards that allows for public feedback and the careful evaluation of the cost, benefits, and emissions reductions of the best available technologies and practices.

Through timely federal action on landfills and food waste, the EPA can slash dangerous methane and toxic air pollution, make progress on climate and environmental justice goals, and better protect communities across the country. Curbing methane emissions from the waste sector must be a part of our national climate strategy, and we urge EPA to act now.

Thank you for your consideration.


City of Charlotte
22 Designs
350 Humboldt
350 Corvallis
Amy's Kitchen
Aphra Communications
Architectural Collaborative, LLC
Bridger Bowl Ski Area
Cheryl Heinrichs Architecture
City of Melrose, Massachusetts
Climate Collaborative
Colorado Department of Public Health and Environment
Comeback Farm Organic Produce
Compost Crew
Corvallis Climate Action Alliance
Corvallis Interfaith Climate Justice Committee
Dream in Green
Eldora Mountain Resort
Enduring Green Globe Consulting
Energy Vision
Equiterra Regenerative Design Inc
Fielding Graduate University
Food Rescue US
Fredricks Communications
GAIA (Global Alliance for Incinerator Alternatives)
Green And Profitable
Harvard Law School Food Law and Policy Clinic
Haverford College
Health Care Without Harm
Institute for Local Self-Reliance

Interfaith EarthKeepers
Keep Austin Fed
Mary Morris Consulting
Mass General Brigham
Missouri Organic Recycling, LLC
Moffitt Cancer Center
Namu Baru Inc.
National Co+op Grocers
Natural Resources Defense Council (NRDC)
Piedmont Environmental Alliance
Purevant Living
Regenerative Solutions
Rhode Island General Assembly
Sanderson Sustainable Design
SCR Financial Group
Sierra Nevada Brewing Co
Six Mile Run Reformed Church
Solberg MFG
Sustainable Design Consulting, LLC
Syncro Architecture Studio
Temple Beth Or, Raleigh, NC
Texas Impact
The Nest Climate Campus
The Repurpose Project
United Religions Initiative Volition Project, LLC
We Are Forces of Nature
Wolf & Associates, Inc.
World Wildlife Fund
WR Consulting, Inc.
Zero Food Waste Coalition
Zero Waste Montgomery County