Complementary Policies
Keeping Waste Out of Landfills
In addition to strengthening emissions standards for landfills to mitigate the pollution we are stuck with, we must move away from our take/make/waste economy and toward a regenerative circular one that keeps people at the center. More food in landfills means less food for people to eat. Every year, more than 24 million tons of edible food are dumped in landfills to decompose into harmful gases. Meanwhile, more than 48 million people across the country experience food insecurity or hunger. A waste management system where the go-to move is burying food in landfills means that everyone loses — including our wallets. Altogether, food waste costs the U.S. economy an estimated $328 billion annually in lost resources that could have nourished people instead of polluting the planet.
Local Economic Opportunities
We create more jobs and spur economic development when a community does more than use something and trash it. Organic waste must be hauled, facilities must be built, aluminum cans must be recycled, and farms need compost. Each of these products and services creates new family-supporting jobs. GAIA’s 2021 report, Zero Waste and Economic Recovery: The Job Creation Potential of Zero Waste Solutions, studied jobs data from 16 countries and found that composting and recycling create many more jobs than burning or burying waste:
Landfilling/incineration creates 1.8 average jobs per year per 10,000 tons of material.
Composting creates 6.6 average jobs per year per 10,000 tons of material.
Semi-mechanized recycling creates an average of 321 jobs per year per 10,000 tons of material.
Job growth is just one benefit of waste diversion. By implementing food waste reduction solutions, including organic waste diversion, ReFED estimates that there is the potential to generate $73 billion in annual net financial benefit, recover the equivalent of 4 billion meals for food insecure individuals every year, and create 51,000 jobs over ten years.
Stopping Methane Before It Starts
Organic waste, including food scraps, yard trimmings, and paper products, makes up a significant portion of landfill contents and is a primary source of methane emissions when decomposed anaerobically. Diverting these materials to alternative treatments such as composting and animal feed can drastically reduce new methane production in the long-term, and must be pursued alongside other reduction and control measures. Studies have shown that reducing organic waste disposal in landfills has a vital role to play in preventing new methane generation. The EPA highlights that diverting 75% of food waste to composting facilities or anaerobic digesters can reduce methane emissions by 80–90% over the waste’s lifetime compared to landfilling. To achieve long-term reductions in methane emissions, it is essential to integrate organics diversion with improved waste-in-place methane mitigation regulations.
Sanctuary Farms is a Detroit-based urban farm and nonprofit committed to closing the food loop and advancing environmental justice through community-rooted solutions. At the heart of their work is a robust composting initiative that diverts organic waste from landfills and transforms it into nutrient-rich soil to support regenerative farming practices. In partnership with their sister organization, Sacred Spaces, they support a decentralized composting network in Detroit.
Key Policy Measures
Many state and local governments have taken action:
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Several states and cities now require reductions in organic waste disposal while expanding alternatives like waste prevention, food donation, composting, and anaerobic digestion. Washington’s law builds and improves upon California's model by requiring diversion, while Vermont requires generators to separate food scraps and send them to approved facilities. Successful policies typically phase in requirements, apply to all generators, invest in outreach and infrastructure, and include provisions to ensure edible food is donated. Mandatory reporting—especially for large generators—can also improve compliance and track progress.
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States can reduce food waste by clarifying date labels, offering tax incentives for food donation, and providing clear food safety guidance. Local governments can support food rescue and waste prevention through rebates, public awareness campaigns, and school programs. Economic incentives — like higher landfill tipping fees or pay-as-you-throw pricing — can also encourage waste reduction and donation.
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Local governments can provide curbside collection or drop-off programs for food scraps, while states can fund composting and anaerobic digestion infrastructure. Permitting and zoning reforms can help accelerate facility development, and programs can support recycling food scraps into animal feed. Nearly 400 food scrap collection programs already operate across the U.S., including in Prince George’s County, MD, Hennepin County, MN, and State College, PA.
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Thankfully, the Zero Food Waste Coalition — a partnership led by NRDC, WWF, and ReFED — is helping states and communities turn food waste into climate action. Their Zero Food Waste Toolkit showcases a growing menu of state practical policies that prevent food from going to waste, expand donation programs, and build composting and anaerobic digestion infrastructure. From model legislation to implementation guides, the toolkit provides policymakers with practical, tested strategies to reduce methane emissions and strengthen local economies. These state-level efforts show how coordinated policy action can cut organic waste, feed people instead of landfills, and deliver cleaner air for all. From Ohio to Arizona, communities are seeing the real benefits.
Mitigating emissions from MSW landfills will require a full-circle approach. Policy solutions to reduce and divert organic waste have a vital role to play in limiting future new emissions; however, waste diversion and prevention only address new emissions. To mitigate emissions from previously landfilled waste, strong, effective and comprehensive emissions regulations for MSW landfills are vital.
Leachate: Beyond the Scope, but Critical to Address
Toxic leachate from landfills contaminates water
Leachate is one of the primary ways landfill pollution moves beyond the landfill boundary, carrying contaminants into surrounding soil, groundwater, and surface waters. As waste decomposes, liquids percolate through the landfill and pick up a complex mixture of pollutants, including toxic chemicals and byproducts of decomposition. In fact, leachate from landfills is a major pathway for toxic contamination including substances like PFAS (“forever chemicals”), which pose significant risks to water bodies and communities, meaning they could flow hundreds of miles from the original site of contamination. Landfill leachate contains a wide range of toxic contaminants—including industrial chemicals, plastics, pharmaceuticals, pesticides, and PFAS. Even at very low concentrations, these pollutants can still cause serious harm to ecosystems, human health, and the economy.
Landfills in wetter climates generate far more leachate and therefore more PFAS and other toxic pollution. Research shows that although landfills in high-rainfall regions make up less than half of total waste placed in landfills, they produce the vast majority of leachate.
Conventional municipal wastewater treatment plants aren’t equipped to deal with the many toxics in leachate or PFAS. Sending leachate to one of these facilities can actually make the problem worse. Standard treatment processes break down some of the other pollutants but don’t remove PFAS, and can even convert precursor chemicals into more persistent forms. In some cases, this results in higher PFAS levels coming out of the plant than going in, including the creation of short-chain PFAS, which are especially mobile and difficult to control. Many of the toxic pollutants from leachate that is processed through a municipal wastewater plant end up in the solids or sludge. That material is typically either land applied or sent to a landfill for disposal.
Leachate management is a critical part of landfill operations, but it is primarily governed under the Clean Water Act regulatory framework, not air quality rules like the landfill methane regulations discussed here. As a result, it sits outside the core expertise and scope of this brief. That said, research makes clear that leachate is closely connected to landfill gas behavior and emissions outcomes. For example, liquid accumulation in landfills can impede gas collection, alter gas composition, and contribute to operational problems that affect methane control . Elevated moisture conditions can also influence subsurface reactions and increase risks like heat buildup or system inefficiencies, which in turn can worsen emissions if not properly managed.
Landfill leachate management presents serious and distinct environmental and public health risks. Leachate disposal at municipal wastewater treatment plants, where conventional treatment processes are often not designed to remove PFAS, ammonia, heavy metals, and other contaminants, can result in downstream surface water contamination and potential impacts to drinking water supplies. In addition, inadequate monitoring, well placement and insufficient groundwater monitoring can leave rural well-dependent communities particularly vulnerable to undetected contamination. Surface water withdrawals downstream of leachate discharge points present another exposure pathway of concern.
Because leachate regulation falls largely outside the air quality context of these model rules, we do not attempt to prescribe detailed requirements here. At a high level, effective approaches include:
Ensuring liquid levels are properly monitored and controlled to prevent interference with gas collection systems;
Avoiding conditions where liquid buildup contributes to system failures, heat generation, or emissions increases;
Aligning landfill methane rules with existing Clean Water Act regulations to ensure operators cannot manage gas and liquids in isolation;
Reducing the generation of leachate and landfill gas in the first place by diverting waste and limiting the amount of material landfilled;
Recognizing that wastewater treatment plants do not effectively remove contaminants like PFAS, and therefore should not be relied on as a solution;
Requiring that leachate be managed and treated as its own waste stream, including on-site treatment where necessary, rather than being discharged to municipal systems that are not designed to handle these pollutants;
Ensuring landfill operators are responsible for managing and treating leachate pollution at the source, instead of shifting the burden onto local governments and wastewater infrastructure.
Example: A recent enforcement action in North Carolina illustrates both the scale of the problem and what strong intervention can achieve. At the Sampson County Landfill, the operator had been discharging approximately 1,000 parts per trillion (ppt) of PFOA (a type of PFAS) into a nearby waterway (Bearskin Swamp). Under an agreement with the State:
Discharges must be reduced to 4 ppt (the lowest level laboratories can reliably measure),
The operator must install treatment systems, and
The landfill agreed to stop accepting new PFAS-contaminated waste streams (e.g., from firefighting foams and military sites) until standards are met.
These measures are expected to significantly reduce contamination of a local stream used for fishing and recreation, demonstrating both the seriousness of leachate pollution and the impact of enforceable limits.
For more detailed and technically grounded analysis, we encourage you to consult: