Proposed Amendments to the Regulation on Methane Emissions from Municipal Solid Waste Landfills

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Comment From: Luz M. Rios

11/20/25 @ 11:44 AM

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Comment From: Heidy Mascoso

11/20/25 @ 11:41 AM

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Comment From: Jaime Calderon

11/20/25 @ 11:38 AM

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Comment From: Maria Elena Gutierrez

11/20/25 @ 11:35 AM

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Comment From: Sunflower Alliance Charles Dav... (Charles Davidson)

11/20/25 @ 11:14 AM

Reducing methane alone is not enough: The urgent need to reduce reactive landfill VOCs, eliminate toxic ozone and better protect air quality and public health

Charles Davidson, Sunflower Alliance and the California Environmental Justice Coalition (C...↓EJC). Nov. 2025

Inside the landfill, heat, pressure, moisture, and metal-catalyzed reactions create a toxic chemical stew. Hydroxyl radicals—generated through photolysis of dissolved organic matter, free-radical-driven reactions involving iron in leachate, ozone-driven oxidation, and ammonium sulfate activation—aggressively attack organic material and convert methane and volatile organic compounds (or VOCs) into formaldehyde and other highly reactive compounds. These pollutants migrate upward and escape through the cover, working face, cracks, piping, and settling waste. Many of these chemicals act as direct toxins, such as formaldehyde, while others interact with nitrogen oxides (NOx) in sunlight to form even more ground-level ozone.

Even if methane emissions are reduced by 75–90%, these chemical reactions do not stop. The landfill remains an active reactor, continuously producing carcinogens, ozone precursors, aerosols, and respiratory irritants. Nearby communities—especially low-income residents, children, and elderly adults—continue to face daily exposure to toxic compounds that drive asthma, cardiovascular stress, and cumulative health disparities.

It is also important to clarify that while landfills do not produce nitrogen oxides through decomposition, landfill operations do. Flaring, landfill-gas-to-energy combustion units, backup generators, heavy equipment, and diesel machinery are significant local sources of NOx. These NOx emissions, though external to the waste mass, combine with landfill VOCs and aerosolized aldehydes —and sunlight––to generate ground level ozone, a potent respiratory irritant and a major contributor to asthma attacks, airway inflammation, heart stress, and premature death.

Stronger monitoring, real-time leak detection, improved landfill covers, aggressive landfill leachate recovery, co-pollutant controls, and modern NOx-minimizing engineering technologies are urgently required. Reducing methane alone is not enough to reduce reactive landfill VOCs, eliminate toxic ozone and better protect air quality and public health.

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Comment From: Kolodji Corporation (Brian Kolodji)

11/20/25 @ 11:10 AM

Landfill Methane Regulations only reference methane emission recovery/sepration technologies that concentrate the methane at a very high and uneconomical cost. Landfill Methane Regulations do not reference recently patented innovations (Inventor Kolo...↓dji, Black Swan, USPatent No. 12,465,884 B2, Issued Novermber 11, 2025) that most economically convert methane emissions from landfills into a high heating value fuel by way of membrane oxygen enrichment. The mature (60 year+) science and commercial practice of Oxygen Enrichment has used concentrated oxygen to locally increase the heating value of fuel streams such as refinery sulfur recovery and steel production for decades and can also be used for dilute methane as produced from landfills. This proven science and technology has been around for over 50 years as summarized and promoted by USDOE, see USDOE Process Heating Energy Tip Sheet #3, Oxygen Enriched Combustion; DOE/GO-102005-2178, September 2005. The practice of separating and producing concentrated nitrogen (from 79% to 90+%) and also producing concentrated oxygen (from 21% to 60 %O2) directly produced from air has been most economically produced and commercially practiced gas separation with membranes for 50+years. Generon (largest manufacturer in California), Membrane Technology and Research Incorporated (also in California), and other manufacturers (Air Products in Missouri is world's largest air separation manufacturer in the world, and Honeywell/UOP ,the world's largest membrane manufacturer for gas separation, and Schlumberger's Cynara, the next largest competitor, both with membrane manufacturing operations in California) have been commercially manufacturing these systems in a circa $100 million dollar industry. California's membrane manufacturer, Generon, has most economically performed membrane air separation with Black Swan's recently patented device that reduces membrane costs and energy consumption by up to 50%, with an up to 10% higher performance than conventional membranes for the past almost five years. I strongly encourage CARB to consider regulations that allow this most economic methane emission conversion to fuel innovation that enables a profit to be made out of methane emission reductions from landfills by making a profit from converting methane emissions to into a valuable fuel.

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Comment From: Laila Sharpe

11/20/25 @ 10:55 AM

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Comment From: Assemblymember Jacqui Irwin

11/20/25 @ 10:00 AM

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Comment From: Representatives Brownly, White...

11/20/25 @ 10:00 AM

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Comment From: Gina McCarthy

11/20/25 @ 10:00 AM

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Comment From: Christine Wolfe

11/11/25 @ 12:34 AM

Please find WM's comments on the 45-Day Package for the Landfill Methane Rule.

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Comment From: Britton Schwartz Intl Hum Rts Clinic, SCU Law

11/10/25 @ 10:21 PM

On behalf of the International Human Rights Clinic at Santa Clara University School of Law, please refer to the attached PDF file for our written comments on the proposed LMR amendments. Thank you very much for the opportunity to provide public comme...↓

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Comment From: Paul burke

11/10/25 @ 8:30 PM

Comments attached

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Comment From: Jennifer Elkins

11/10/25 @ 8:10 PM

Letter attached.

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Comment From: Erica Parker

11/10/25 @ 7:24 PM

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Comment From: Jason Lawler

11/10/25 @ 6:44 PM

Comment on behalf of the San Joaquin Valley Air Pollution Control District

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Comment From: Warisa Niizawa

11/10/25 @ 6:14 PM

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Comment From: Olivia Alves

11/10/25 @ 6:10 PM

RMI & EDF submit the following attachments to the record alongside the public comment titled "RMI EDF Carb LMR Public Comment November 2025". 2/2.

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Comment From: Olivia Alves

11/10/25 @ 6:05 PM

RMI & EDF submit the following attachments to the record alongside the public comment titled "RMI EDF Carb LMR Public Comment November 2025".

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Comment From: Olivia Alves

11/10/25 @ 5:57 PM

RMI & EDF submit the following public comment to CARB on the Proposed Amendments to the Regulation on Methane Emissions for Municipal Solid Waste Landfills. Alongside this comment we submit a series of two attachments for the record.

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Comment From: Dylan Hoffman

11/10/25 @ 5:52 PM

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Comment From: Todd Shibata

11/10/25 @ 5:44 PM

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Comment From: Julia Mangin

11/10/25 @ 5:43 PM

See attached comments on behalf of Recology.

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Comment From: Angela Thompson

11/10/25 @ 5:41 PM

Hello, please see attached comment letter.

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Comment From: Rania Serieh

11/10/25 @ 5:20 PM

Please see the attached file.

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Comment From: Gregory Nudd

11/10/25 @ 5:13 PM

Hello, please see the attached comment letter submitted by the Bay Area Air District.

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Comment From: Christy Pestoni

11/10/25 @ 5:10 PM

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Comment From: Patrick Mathews

11/10/25 @ 4:58 PM

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Comment From: Marc Rodabaugh

11/10/25 @ 4:32 PM

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Comment From: David Barron

11/10/25 @ 4:03 PM

Please see attached LMR Public Comments from Sniffer Robotics.

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Comment From: Kathryn Chapman

11/10/25 @ 3:37 PM

Comments are found in the attached PDF file

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Comment From: John Kennedy RCRC

11/10/25 @ 3:35 PM

Please find attached written comments submitted on behalf of the Rural County Representatives of California.

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Comment From: John Borrego

11/10/25 @ 3:25 PM

The purpose of this letter is to provide comments on the Proposed Amendments to the Regulation on Methane Emissions from Municipal Solid Waste Landfills. We support and appreciate the overarching goals of the LMR. Our feedback targets what we belie...↓

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Comment From: Scott Scholz

11/10/25 @ 3:14 PM

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Comment From: Mahiany Luther

11/10/25 @ 1:39 PM

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Comment From: Jason Aspell

11/10/25 @ 12:54 PM

South Coast AQMD Comment Letter Attached

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Comment From: Haley Lewis

11/10/25 @ 12:43 PM

Please find attached EIP's Comments on CARB's Proposed Amendments to the Regulation on Methane Emissions from Municipal Solid Waste Landfills.

Thank you,

Haley Lewis, Senior Attorney, EIP

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Comment From: Jeffrey Mills

11/10/25 @ 11:57 AM

See Attached Letter.

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Comment From: McKenzie Wilson

11/10/25 @ 11:45 AM

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Comment From: Dylan Hoffman

11/10/25 @ 11:43 AM

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Comment From: Gael Ronnau

11/10/25 @ 11:10 AM

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Comment From: Suparna Chakladar

11/10/25 @ 10:42 AM

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Comment From: Jenna Roper

11/10/25 @ 1:00 AM

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Comment From: David Ramirez

11/10/25 @ 1:00 AM

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Comment From: Jordan Giaconia

11/10/25 @ 1:00 AM

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Comment From: Lucinda Jackson

11/09/25 @ 5:57 PM

I fully support and would like you to support the proposed landfill amendment in California. This is very important and can "move the needle" on landfill methane leaks. In 2010, California mandated that certain landfills install gas collection syste...↓

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Comment From: Ben Silton

11/09/25 @ 1:46 PM

Please see TrelliSense's comments on the Proposed Amendments in the attached PDF.

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Comment From: Waqar Qureshi

11/07/25 @ 9:03 PM

I support this proposed rule and endorse the intent because it strengthens monitoring, requires faster response to problems and requires better collection of methane from landfills.

I would challenge CARB to require greater transparency, more stri...↓

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Comment From: C Corliss

11/07/25 @ 8:34 AM

Attached comment submitted on behalf of OC Waste & Recycling.

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Comment From: Lisa Couch

11/06/25 @ 4:31 PM

I support the proposed landfill methane Amendment Title 17. It goes a long way towards mitigating landfill methane leaks, which is a win for climate.

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Comment From: Kevin Rodgers

11/06/25 @ 12:48 PM

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Comment From: Gavin Bruce

10/28/25 @ 11:33 AM

I am writing with regards to the proposed updates to the landfill methane regulation. While the draft updates to the regulation are a great step forward from our current rules, there are some important issues that need to be addressed.

First, the r...↓

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