Regulators consistently allow landfills to operate at unusually high temperatures, records show

More than 5.5 million people live near a landfill with approval to run hot gas wells

Washington, D.C. – Regulators in seventeen states approved hundreds of Higher Operating Value (HOV) requests, allowing landfills to operate gas wells at temperatures as high as 215° F — 70 degrees above the federal threshold. That’s according to analysis of documents obtained by Full Circle Future via public records requests. 

Elevated operating temperatures and higher oxygen levels can significantly increase the risk of subsurface fires or heat reactions, which can cause structural damage to the landfill while devastating the health and safety of nearby communities. Full Circle Future’s new report, Too Hot to Ignore, reveals more than 200 approved HOV approvals for gas wellhead temperatures at or above 170° across 12 landfills, a level at which methane production begins to break down and underground fires become more likely. 

“Imagine if the smoke alarm went off in your kitchen, but when the fire department came, all they did was look at the outside of your house and decide it looked fine,” said Katherine Blauvelt, Executive Director at Full Circle Future. “That sounds ridiculous, but it’s essentially how many state regulators are operating when it comes to higher temperatures at landfills.” 

Once they start, subsurface landfill fires are extremely difficult to control and can smolder underground for decades. One example is Southern California’s Chiquita Canyon Landfill, where an underground chemical reaction has been growing rapidly since 2022, spewing air pollution and causing geysers of toxic leachate to shoot up from the ground. For years, nearby residents have begged policymakers for relief, sometimes traveling hundreds of miles to share their experiences with asthma attacks, nosebleeds, vomiting, miscarriages, and cancer. 

Nationally, more than 5.5 million people live within five miles of a landfill with an approved HOV, more than enough to fill every NFL stadium in the country twice. 

“Seeing these records from around the country is heartbreaking, because it confirms that what our community is experiencing isn’t just a one-off tragedy. It’s a national, structural crisis,” said Jennifer Elkins, resident living near the Chiquita Canyon Landfill. “Regulators have a responsibility to prioritize the health and safety of communities; instead, they’re giving landfills free reign to put us in harm’s way.” 

In order to obtain a higher operating wellhead temperature approval or permission to introduce higher levels of oxygen into the gas well, a landfill operator must submit a request to the appropriate regulatory agency, including proof that the elevated temperature doesn’t indicate dangerous conditions. Yet records show that many state regulators are making consequential decisions without requiring the information needed to understand the risks. For example, regulators often approved higher operating temperatures without requiring landfill operators to investigate why the landfill is overheating in the first place.

Regulators also regularly rely on surface wellhead temperatures, despite the fact that measuring the landfill’s internal temperature is the more reliable way to gauge early warning signs of fires. In one case, the temperature below the surface of the Chiquita Canyon Landfill was found to be more than 100° hotter than at the wellhead. Often, the approval is issued without an end date or additional follow-up requirements, effectively allowing the landfill to operate at potentially dangerous temperatures in perpetuity. 

Records also revealed that requests are largely concentrated among a handful of giant waste corporations. Nearly three-quarters of the records reviewed are tied to landfills operated by WM, Republic Services, Waste Connections, or GFL Environmental. 

While elevated temperatures do not necessarily mean a landfill is on fire, they are warning signs that conditions underground have changed, making regulatory scrutiny critical to determining what is causing the heat and whether it can be safely managed.  Ohio EPA’s guidance to landfill operators underscores the stakes, warning that “failure to properly address elevated temperatures can cause the problem to get worse.” 

The problem is compounded by the fact that even basic information is remarkably difficult for the public to find. There is no comprehensive, searchable national database showing which landfills have been allowed to operate gas wells above federal temperature or oxygen limits. Completing this analysis required Full Circle Future to submit public records requests state by state and spend hundreds of hours and thousands of dollars obtaining, sorting and reviewing records that were often incomplete, inconsistently maintained or difficult to search. 

“The unknown is really the most alarming part,” concluded Blauvelt. “These landfills are literally playing with fire, but the people living nearby probably have no idea. Communities deserve basic information  about potential risks to their health and safety – and they deserve it long before tragedy strikes. Regulators need to proactively monitor these risks, make that information accessible to the public, and act before a warning sign becomes a crisis.”

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