Author: Joshua R. Castigliego
February 2024
On behalf of the Energy Justice Network, Researcher Joshua R. Castigliego provided expert comments in Docket No. EPA-HQ-OLEM-2023-0451 on the U.S. Environmental Protection Agency’s (EPA) Waste Reduction Model (WARM) Version 16 and its supporting documentation. In his comments, Mr. Castigliego reviewed and critiqued WARM’s methodology and assumptions regarding avoided emissions from the displacement of grid electricity through energy recovery at waste incineration facilities. Mr. Castigliego determined that WARM’s current methodology and assumptions are flawed and include errors that together appear to result in an overestimation of net emission reductions from waste incineration facilities.
His assessment highlights that WARM’s assumptions contain a critical error due to its failure to consider the sales of renewable energy credits (RECs), particularly as they relate to state renewable portfolio standards (RPS), in its estimation of emissions displaced by electric generation from waste incinerators. In addition, Mr. Castigliego identified additional critiques of WARM’s current methodology for estimating electric sector emission factors: (1) WARM’s emission factors for the electric sector are too simplistic and a poor proxy for marginal emissions; (2) avoided electric emissions are best estimated using the displacement of the marginal resource; (3) wind regularly serves as the marginal resource in some regions, meaning that emitting resources are not the only ones displaced; and (4) WARM’s regions do not align with the regions that correspond to electric sector operations and dispatch decisions.
Mr. Castigliego concludes that a majority of the flaws in WARM’s grid displacement assumptions center around the misalignment with how these emissions are addressed within the electric sector. To improve the accuracy of estimating avoided emissions from energy recovery in the waste management sector, EPA must better approximate what resources are most likely to be displaced by waste incinerators based on the characteristics of these facilities compared to other resources on the grid.