United States
                Environmental Protection
                Agency
Air and Radiation
(6202J)
EPA 430-R-00-004
May 2000
www.epa.gov/lmop
&EPA      Florida State Primer
                                                A Primer on
                                                Developing Florida's

                                                Landfill Gas-to-Energy
                                                Potential
                LANDFILL METHANE
                OUTREACH PROGRAM
                   Printed on paper that contains at least
                   30 percent postconsumer fiber.

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Contents
       Introduction	j
       1.   The Goals of This Primer	i
       2.   LFGTE Projects in Fiorida	ii
       3,   About the Landfil! Methane Outreach Program	iv
       4,   Where to Go for More Information 	iv
                1:
       1.   Overview of Federal  Regulations and Permits  	1
           1.1   Clean Air Act (CAA)  	1
           1,2   Resource Conservation and Recovery Act Subtitle D 	4
           1,3   National  Pollutant Discharge Elimination System Permit (NPDES)  	5
           1.4   Clean Water Act, Section 401  	5
           1,5   Other Federal  Permit Programs 	6
       2.   State Regulations and Permits	6
       3,   Overview of Local Regulations and Permits	15
       Part 2: Incentiwe Programs
       1.   Overview of Federal  Incentive Programs 	17
           1.1   Renewable Energy Production Incentive (REPI)  	17
           1.2   Qualifying Facilities Certification	17
           1,3   Section 29 Tax Credit 	18
       2.   State Incentive Programs	18
       3,   Electricity Restructuring and LFGTE	18
       Tables
       Table A  Candidate Landfills for LFGTE Projects in Florida	ill
       Table 2.1  Summary Table of State Regulations/Permits 	8
       Table 2.2 Permit Approval Timeline	9
       Table 2,3 Summary of Landfill Gas Systems Criteria 	10
       Table 2,4 Air Quality Construction and Operating Permits	12
       Table 2.5 Solid Waste Permits	14
       Table 3,1  Local Regulations and Permits	16
       Appendix A
       State Contacts	20

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 Introduction
Q     The Goals of This Primer
 Throughout the country, the number of landfill gas-to-energy (LFGTE) projects is growing. Recovering methane
 gas at solid waste landfills provides significant environmental and economic benefits by eliminating methane
 emissions while capturing the emissions' energy value. The methane captured from landfills can be transformed
 into a cost-effective fuel source for generating electricity and heat, firing boilers, or even powering vehicles.

 Permits, incentive programs, and policies for LFGTE project development vary greatly from state to state. To
 guide LFGTE project developers through the state permitting process and to  help them to take advantage of
 state incentive programs, the U.S. Environmental Protection Agency's (EPA's)  Landfill  Methane Outreach Program
 (LMOP) has worked with state agencies to develop individual primers for states participating in the State Ally
 Program. By presenting the latest information on federal and state regulations and incentives affecting LFGTE
 projects in this primer, the LMOP and Florida state officials hope to facilitate development of many of the landfills
 listed in Table A.

 To develop this primer, the state of Florida identified all the permits and funding programs that could apply to LFGTE
 projects developed in Florida. It should be noted, however, that the regulations,  agencies, and policies described are
 subject to change. Changes are likely to occur whenever a state legislature meets, or when the federal government
 imposes new directions on state and local governments. LFGTE  project developers should verify  and continuously
 monitor the status of laws and rules that might affect their plans  or the operations of their projects.

 Who Should Read This Primer?
 This primer is designed to help  realize the potential of  landfill gas recovery in the state of Florida. It provides infor-
 mation for developers of  LFGTE projects, as well as all  other participants in such projects:

     • Landfill operators                       • State regulators

     • Utility companies                       • Engineers

     • Independent power producers           • Equipment vendors

     • Utility regulators

 What Information Does This Primer Contain?
 If you are interested in taking advantage  of the economic and environmental opportunities in LFGTE  recovery in
 Florida, you will need to know the regulatory requirements that apply. You will also need to know what economic
 incentives are available to help make these projects more economically viable.

 To address these needs,  this primer covers the following topics:

     • Federal Regulations and  Permits. This section provides information on federal regulations that  may pertain
       to LFGTE projects, including solid  waste, air quality, and  water quality regulations.

     • State Regulations and Permits. This section provides information on state permits that apply to landfill gas
       recovery projects in Florida.
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    • Local Regulations and Permits. Local permit approval will often be needed for LFGTE projects. This
      section offers a step-by-step process you can follow to secure this approval.

    • Federal Incentive Programs. This section presents information on federal incentives that may apply to
      LFGTE projects.

    • State Incentive Programs. This section presents information about environmental infrastructure financing
      opportunities in  the state of Florida.

    • Electricity Restructuring. This section discusses how renewable energy provisions in state electricity
      restructuring regulations might apply to LFGTE projects.
       LFGTE Projects in Florida
The Florida Department of Environmental Protection is a member of the LMOP State Ally Program, which
encourages cooperation between EPA and state energy and environmental agencies to promote the develop-
ment of LFGTE resources. Florida's Landfill Gas Recovery Program focuses on developing consensus among
landfill operators, utility companies, independent power producers, project developers, utility regulators, and the
state's regulators so they can work together to promote new energy and environmental opportunities from which
all Florida residents will benefit.

Nine LFGTE projects were operating in Florida as of June 1999. According to EPA and the state of Florida,
22 landfills have the potential to support economically viable gas-to-energy products. The following table
describes Florida's 22  candidate landfills.
       Landfill Gas Projects in Florida

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Table A
Candidate Landfills
Landfill Name
Base Line LF Class 1
Bee Ridge LF
Citrus Central SLF
Groom SLF High Corner Road
Gulf Coast LF
Indian River County LF Class 1
Majette North SLF
Medley LF Expansion
Naples SLF Cell #6 Collier County
North Polk Central LF Site 201
Osceola Road LF
Palm Beach County LF #3 Dyer Road
Putnam County Central SLF
Saint Lucie County SLF Phase I
South Dade Dump
South Dade Shredded Waste LF
Southport Road SLF Phase I & II
Springhill Regional LF
Taylor County Central LF
Trail Ridge LF
U.S. 27 South LF
Wright LF
County
Marion
Sarasota
Citrus
Hernando
Lee
Indian River
Bay
Dade
Collier
Polk
Seminole
Palm Beach
Putnam
St. Lucie
Dade
Dade
Osceola
Jackson
Taylor
Duval
Leon
Okaloosa
Operational Status
Open
Closed
Open
Closed
Open
Open
Closed
Open
Open
Open
Open
Closed
Closed
Open
Open
Open
Open
Open
Closed
Open
Open
Closed
Source: EPA's Opportunities for Landfill Gas Energy Recovery in Florida: Draft Profiles of Candidate Landfills and Current Projects
and information provided by the state of Florida.
                                         A Primer on Developing Florida's Landfill Gas-to-Energy Potential
                                                                                              MI

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       About the Landfill  Methane Outreach  Program
To promote the use of landfill gas as an energy source, EPA has established the Landfill Methane Outreach
Program (LMOP). The goals of LMOP are to reduce methane emissions from landfills by:
    • Encouraging environmentally and economically beneficial LFGTE development
    • Removing barriers to developing LFGTE projects
To achieve these goals, EPA establishes alliances with four key constituencies:
    • State environmental and energy agencies
    • Energy users/providers (including investor-owned, municipal and other public power utilities, cooperatives,
      direct end users, and power marketers)
    • Industry (including developers,  engineers, and equipment vendors)
    • Community partners (municipal and small private landfill owners and operators; cities, counties, and other
      local governments; and community groups)
EPA establishes these alliances through a Memorandum of Understanding (MOU).  By signing the MOU, each ally
and partner acknowledges a shared commitment to promoting landfill gas energy recovery at solid waste land-
fills, recognizes that the widespread use of landfill gas as an energy resource will reduce methane and other air
emissions, and  commits to certain activities that enhance the development of this resource.
As of September 1999, more than 270 landfill methane recovery projects were operating in the United States.
EPA estimates that up to 750 landfills could install economically viable landfill energy projects by the year 2000.
       Where To Go For More Information
       Richard Tedder
       Florida State Ally Contact
       Department of Environmental Protection
       2600 Blair Stone Road
       Tallahassee, FL 32399-2400
       Tel: (850) 488-0300
       Fax: (850) 414-0414

       Lisa Martin
       Florida State Ally Contact
       Department of Environmental Protection
       2600 Blair Stone Road
       Tallahassee, FL 32399-2400
       Tel: (850) 921-9237
                                                  U.S. Environmental Protection Agency
                                                  Landfill Methane Outreach Program
                                                  Mail Code 6202J
                                                  1200 Pennsylvania Avenue, N.W.
                                                  Washington, DC 20460
                                                  Phone: (888) STAR-YES (782-7937)
                                                  Fax: (202) 565-2077
                                                  http://www.epa.gov/lmop
IV
Landfill Gas Projects in Florida

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   Part 1: Regulations and  Permit
QOverview Of Federal  Regulations And Permits
        The following section discusses federal regulations that may pertain to LFGTE projects. LFGTE projects
        can be subject to solid waste, air quality, and water quality regulations. The federal regulations are pre-
        sented in general terms, because individual state/local governments generally develop their own regula-
        tions for carrying out the federal mandates. Specific requirements may therefore differ among states.
        Project developers will have to contact relevant federal agencies and, in some cases, state agencies for
        more detailed information and applications. The discussion of each key federal  regulation/permit
        contains three components:

            • Importance of the regulation/permit to LFGTE project developers

            • Applicability to LFGTE projects

            • Description of each regulation/permit


 1.1    Clean Air Act (CAA)
        The CAA regulates emissions of pollutants to ensure that air quality meets specified health and welfare
        standards. The CAA contains two provisions that may affect LFGTE projects: New Source Performance
        Standards (NSPS) and New Source Review (NSR). Facilities that are planning to construct a new LFGTE
        system or that plan to modify a landfill operation to incorporate a LFGTE system must obtain an
        Authority to Construct (ATC) permit from  the responsible air regulatory agency if emissions from the pro-
        ject exceed the major facility emission thresholds. The ATC permit specifies the NSPS and NSR  require-
        ments that the project must meet. Once construction is complete, the facility must obtain an operating
        permit that meets the requirements defined in Title V of the 1990 CAA Amendments. The general
        requirements of  NSPS, NSR, and Title Vfor LFGTE projects are discussed below.

        New Source  Performance Standards (NSPS) and Emissions Guidelines
        for MSW Landfills

            Importance   LFGTE projects can be part of a compliance strategy to meet EPA's new emissions
                          standards for landfill  gas.

            Applicability  Landfills meeting certain design capacity, age, and emissions criteria are required to
                          collect LFG and to either flare it or use it for energy.

            Description   EPA final regulations  under Title I of the CAA Amendments require affected landfills to
                          collect and control LFG. Specifically, the CAA targets reductions in the emissions of
                          non-methane organic compounds (NMOCs) found in LFG, such as benzene, carbon
                          tetrachloride, and chloroform, because they contribute to local smog formation. For
                          landfills that received  waste after November 8, 1987 ("existing landfills"), the standards
                          are "Emissions Guidelines"  (EG), and for landfills that commenced  construction,
                          reconstruction, modification, or began accepting waste on or after May 30, 1991 ("new
                          landfills"), the standards are "New Source Performance Standards" (NSPS). The final
                          regulations can be found in the Federal Register, March 12, 1996, Vol. 61,  No. 49, pgs.
                          9907-9944.

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                   The basic requirements are the same for both existing and new landfills.
                   Landfills that meet both of the following criteria  must comply with the regulations.

                   •   Capacity—maximum design capacity greater than or equal to 2.5 million Mg (or
                      2.5 million cubic meters, about 2.75 million tons).1

                   •   Emissions—annual  NMOC emission rate is greater than 50 Mg (about 55 tons).

Air Emissions:  New Source Review (NSR) Permitting Process

    Importance   New LFGTE projects may be required to obtain construction permits under New
                   Source Review (NSR). Depending  on the area in which the project is located, obtain-
                   ing these permits may be the most critical aspect of project approval.

    Applicability  The combustion of LFG results in emissions of carbon monoxide and oxides of nitro-
                   gen. Requirements vary for control of these emissions depending on local  air quality.
                   The relevant standards for a particular area will be discussed in Section 2,  State
                   Standards and Permits. Applicability of these standards to LFGTE projects  will
                   depend on the level of emissions  resulting from the technology used in the project
                   and the project's location  (i.e., attainment or non-attainment area).

    Description   CAA regulations require new stationary sources and modifications to existing
                   sources of certain air emissions to undergo NSR before they can operate.  The pur-
                   pose of these regulations  is to ensure that sources meet the applicable air  quality
                   standards for the area in which they are located. Because these regulations are com-
                   plex, a landfill owner or operator may want to consult an attorney or expert familiar
                   with NSR for more information about permit requirements in a particular area.

The existing CAA regulations for attainment and maintenance of ambient air quality standards  regulate
six criteria pollutants — ozone, nitrogen dioxide (NO2), carbon monoxide (CO), particulate matter (PM-10),
sulfur dioxide (SO2), and lead. The CAA authorizes the EPA to set both health and public welfare-based
national ambient air quality standards (NAAQS) for each criteria pollutant. Areas that meet the  NAAQS
for a particular air pollutant are  classified as being in "attainment" for that pollutant and those that do not
are in "non-attainment."  Because each state  is required to develop  an air quality implementation plan
(called a State Implementation Plan or SIP)  to  attain and maintain compliance with the NAAQS in each
Air Quality Control Region  within the state, specific permit requirements will vary by state. (See  40 CFR
51.160-51.166 for more information.)

The location of the LFGTE project will dictate what kind of construction and operating permits  are
required. If the landfill  is located in an area that is in attainment for a particular pollutant, the  LFGTE pro-
ject must undergo Prevention of Significant Deterioration permitting. Nonattainment Area permitting is
required for those landfills that are located in areas that do not meet the NAAQS for a particular air pollu-
tant. Furthermore, the  level of emissions from the project determines whether the project must  undergo
major NSR or minor NSR. The requirements of major NSR permitting are greater than those  for minor
NSR. The following  provides more detail on new source permits:

Prevention of Significant Deterioration Permitting
Prevention of Significant Deterioration (PSD)  review is used in attainment areas to determine
whether a new or modified emissions source will cause significant  deterioration of local air quality. The
State air office can  assist LFG project developers in determining whether a proposed project requires
PSD approval.

1 Landfills with less than 2.5 million Mg are required to file a design capacity report.

Landfill Gas Projects in Florida

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All areas are governed to some extent by PSD regulations because no location is in nonattainment for all
criteria pollutants. Applicants must determine PSD applicability for each individual pollutant. For gas-fired
sources, PSD major NSR is required if the new source will emit or has the potential to emit any criteria
pollutant at a level greater than 250 tons per year.

For each pollutant for which the source is considered major, the PSD major NSR permitting process
requires that the applicants determine the maximum degree of reduction achievable through the applica-
tion of available control technologies. Specifically, major sources may have to  undergo any or all of the
following four PSD steps:

    • Best Available Control Technology (BACT)  analysis

    • Monitoring of local air quality

    • Source impact analysis/modeling

    • Additional impact analysis/modeling (i.e., impact on vegetation, visibility, and Class areas)2

Minor sources and modifications (i.e., below 250 tons per year) are exempt from this process, but these
sources must still obtain construction and operating air permits (see CFR. 40 CFR 52.21 for more infor-
mation on PSD).

Nonattainment Air Permitting
An area that does not meet the NAAQS for one  or more of the six criteria  pollutants is classified as
being in "nonattainment" for that pollutant. Ozone is the most pervasive nonattainment pollutant, and
the one most likely to affect LFGTE projects. A proposed new emissions source or modification of an
existing source located in a nonattainment area  must undergo nonattainment major NSR if the new
source or  the modification is classified as major  (i.e., if the new or modified source exceeds specified
emissions thresholds). To obtain a nonattainment NSR  permit for criteria pollutants, a project must
meet two  requirements:

    • Must use technology that achieves the  Lowest Achievable Emissions Rate (LAER) for the nonat-
      tainment pollutant

    • Must arrange for an  emissions reduction at an existing combustion source that offsets the emis-
      sions from the  new project at specific ratios

Potential Exemptions
EPA recently furnished  a guidance document to  state and regional permitting authorities that provides
an exemption from major NSR  permitting  requirements for landfill projects that qualify as "pollution con-
trol projects." An existing landfill that plans to install a LFGTE recovery project may qualify as a pollution
control project as long as it reduces non-methane organic compounds (NMOC) at the site. Under the
guidance,  the permitting authority may exempt the project from major NSR, provided it meets all other
requirements under the CAA and the state, including minor source requirements. In nonattainment
areas, offsets will still be required,  but need not exceed a 1:1  ratio. States have discretion to exercise the
increased  flexibility allowed by the  guidance on a case-by-case basis.
    2Class I areas are specified under the Clean Air Act and include national parks. Projects situated within a certain
    distance from Class I areas are subject to more stringent criteria for emissions levels.
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       Title V Operating Permit

           Importance   Many LFGTE projects must obtain operating permits that satisfy Title V of the 1990
                         CAA Amendments.

           Applicability Any LFGTE plant that is a major source, as defined  by the Title V regulation (40 CFR
                         Part 70), must  obtain an operating  permit.

           Description   Title V of the CAA requires that all  major sources obtain new federally enforceable
                         operating permits. Title V is modeled after a similar program established under the
                         National Pollution Discharge Elimination System (NPDES). Each major source must
                         submit an application for an operating permit that meets guidelines spelled out in
                         individual state Title V programs. The operating permit describes the emission limits
                         and operating  conditions that a facility must satisfy, and specifies the reporting
                         requirements that a facility must meet to show compliance with the air pollution regu-
                         lations. A Title  V operating permit must be renewed every 5 years.


1.2    Resource Conservation and  Recovery Act Subtitle D
           Importance   Before a LFGTE project can be developed, all  Resource Conservation and Recovery
                         Act (RCRA) Subtitle D requirements (i.e., requirements for non-hazardous waste man-
                         agement) must be satisfied.

           Applicability Methane is explosive in certain concentrations and  poses a hazard if it migrates
                         beyond the landfill facility boundary. Landfill gas collection systems must meet
                         RCRA Subtitle D standards for gas control.

           Description   Since October 1979, federal regulations promulgated under Subtitle D of RCRA
                         required controls on migration of landfill gas. In 1991, EPA promulgated landfill
                         design and performance standards; the newer standards apply to municipal solid
                         waste landfills that were active on or after October 9, 1993. Specifically, the stan-
                         dards require monitoring of  LFG and establish performance standards for com-
                         bustible gas migration control. Monitoring requirements must  be  met at  landfills not
                         only during their operation, but also for a  period of 30 years after closure.

       Landfills affected by RCRA Subtitle D are required to control gas by establishing a  program to periodically
       check for methane emissions and prevent offsite migration. Landfill owners and operators must ensure
       that the concentration of methane gas does not exceed:

           • 25 percent of the lower explosive limit for methane in facilities' structures

           • The lower explosive limit for  methane at the facility boundary

       Permitted limits on methane levels reflect the fact that methane is explosive within the range of 5 to 15
       percent concentration in air. If methane emissions exceed permitted limits,  corrective action  (i.e., installa-
       tion of a LFG collection system) must be taken. Subtitle D may provide an impetus for some landfills to
       install energy recovery projects in cases where a gas collection system is required for compliance (see 40
       CFR Part 258 for more information).
       Landfill Gas Projects in Florida

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1.3    National Pollutant Discharge Elimination System (NPDES) Permit
           Importance   LFGTE projects may need to obtain NPDES permits for discharging wastewater that
                         is generated during the energy recovery process.

           Applicability  LFG condensate forms when water and other vapors condense out of the gas
                         stream due to temperature and pressure changes within the collection system. This
                         wastewater must be removed from the collection system. In addition,  LFGTE projects
                         may generate wastewater from system maintenance and cooling tower blowdown.

           Description   NPDES permits regulate discharges of pollutants to surface waters. The authority to
                         issue these permits is delegated to  state governments by EPA. The permits, which
                         typically last five years, limit the quantity and concentration of pollutants that may be
                         discharged. To ensure compliance with the limits, permits require wastewater treat-
                         ment or impose other operation conditions. The state water offices or EPA regional
                         office can provide further information on these permits.

       The permits are required for three categories of sources and can be issued  as individual or general  per-
       mits. A LFGTE project would be included in the "wastewater discharges to surface water from industrial
       facilities" category and would require an individual permit. An individual permit application for waste-
       water discharges typically requires information  on:

           • Water supply volumes                      • Storm water treatment

           • Water utilization                            • Plant operation

           • Wastewater flow                           • Materials and chemicals used

           • Characteristics and disposal methods        • Production

           • Planned improvements                     • Other relevant information


1.4    Clean Water Act, Section 401
           Importance   LFGTE projects may need CWA Section 401  certification for constructing  pipelines
                         that cross streams or wetlands.

           Applicability  LFG recovery collection  pipes or distribution pipes from the landfill to a nearby gas
                         user may cross streams or wetlands. When construction or operation of such pipes
                         causes any discharge of dredge into streams or wetlands, the project may require
                         Section 401 certification.

           Description   If the construction  or operation of facilities results in any discharge into streams or
                         wetlands, such construction is regulated under Section  401. This requirement may
                         affect the construction of LFGTE project facilities or pipelines to transport LFG.

       The applicant must obtain a water quality certification from the State in which  the discharge will origi-
       nate. The certification should then be sent to the U.S. Army Corps of Engineers. The certification  indi-
       cates that such discharge will comply with the applicable provisions of Sections 301, 302, 303, 306, and
       307 of the Clean Water Act (CWA).
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 1.5   Other Federal Permit Programs
        The following are brief descriptions of how ofher federal permifs could apply fo LFGTE project developmenf.
            • RCRA Subfifle C could apply fo a LFG project if it produces hazardous waste. While some LFG
              projects can return condensate to the landfill, many dispose of it through the public sewage system
              after some form of on-site treatment. In some cases, the condensate may contain high enough
              concentrations of heavy metals and organic chemicals for it to be classified  as a hazardous waste,
              thus triggering federal regulation.
            • The Historic Preservation Act of 1966 or the Endangered Species Act could  apply if power lines or
              gas pipelines associated with a project infringe upon an historic site or an area that provides habi-
              tat for endangered species.
Ill    State Regulations and  Permits
        This section provides information on permits required by the State of Florida for the development of a
        LFGTE project.3  Information provided on each permit includes:

             • How the permit is applicable to  LFGTE projects

             • The appropriate agency contact

             • A description of the permit

             • The statute/regulation

             • Information required and suggestions for a successful application

             • The application and review process

             • The review/approval period.

             • Any fees required.

        For an overview of required permits, contact information, and length of the review period, see Tables 2.1
        and  2.2. The criteria for LFG collection and LFGTE systems are provided in Table 2.3.


 Summary of Permits
        The  principal permits required for LFGTE projects in Florida are related to air quality and solid waste
        issues and are regulated by the State of  Florida Department of Environmental  Protection (DEP). The para-
        graphs below summarize the permits required by DEP for a LFGTE project.

        Air-Related: Because the NSPS landfill requirements of 40 CFR 60 Subpart WWW cannot be divided
        into two or more Title V operation permits, one Title V application  must be submitted by one entity
        (the  landfill, the LFGTE company, or a partnership of the two) to cover all of the elements of the NSPS
        subpart such as landfill monitoring, gas collection, and gas control. Air construction permit applications
        will no longer be required for landfills unless a PSD review is required. The air permit conditions for
        construction will  be included in the solid waste construction permit for  a landfill. DEP has developed
        the Application for Air Permit-Long Form to provide a standard form for use by all Title V applicants.
        The  form and instructions are adopted under Florida Administrative Code Rule 62-210.900(1).


 3 The permits contained in this handbook were suggested by state permitting agencies.

 6      Landfill Gas Projects in Florida

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The form is available from DEP as a hard-copy document or executable diskette. The diskette version,
referred to as ELSA (for Electronic Submission of Application), contains both the form and instructions
and is designed for use with Microsoft Windows. ELSA may be obtained from the Division of Air Resources
Management in Tallahassee by calling the ELSA Help Line, (904) 921-0771. The ELSA product may also be
downloaded from the Internet at http://www.matrixis.com/elsa

DEP will accept hard copies, accurate hard-copy faxes, or read-only data diskettes of the Application for
Air Permit, created by applicants or consultants. An applicant who submits the air application on diskette
must format the application in a manner prescribed by DEP. The applicant must also submit four hard
copies of Section I of the form, containing the applicant's signature and, where required, the professional
engineer's signature and seal.

Solid Waste-Related: A solid waste permit is required for all construction, development, or modifications
to a municipal  solid waste landfill permit.

Permits issued by departments other than DEP are not discussed in this handbook. Project developers
should contact state and local agencies for a complete list of applicable permits (see Section 3 for a dis-
cussion of potential local permit requirements).

Permitting Assistance
The Department of Environmental Protection has established a small-business technical and environmental
compliance assistance program in the Division of Air Resources Management. The program has responsibil-
ity to assist small-business stationary sources of air pollution in determining applicable permit requirements,
collect  and disseminate information concerning compliance methods and technologies, and provide infor-
mation regarding pollution prevention and accidental release detection and prevention. Small businesses
requiring assistance may contact the program office by calling 1-800-SBAP-HLP (1-800-722-7457) or visiting
http://www.dep.state.fl.us/air/outreach/sbap/indexhtm
3The permits contained in this handbook were suggested by state permitting agencies.

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Table 2.1
Summary Table of State Regulations/Permits
Standard
       Permit
Agency/Contact
Appropriate
Review Period
Air
       Construction Permit
State of Florida
Department of Environmental Protection
Division of Air Resources Management
(For contact information see
Appendix A)
3 to 6 months
                    Operating Permit
                           State of Florida
                           Department of Environmental Protection
                           Division of Air Resources Management
                           (For contact information see
                           Appendix A)
                                    varies
Solid Waste
       Permit to Construct
       or Modify
 State of Florida
 Department of Environmental Protection
 Division of Waste Management
 (For contact information see
 Appendix A)
 3 to 6 months
       Landfill Gas Projects in Florida

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Table 2.2
Permit Approval Timeline
                   024
                   Months
                                 8     10     12
                    Notes
                    Solid black band denotes the minimum review/approval
                    period; gray band the typical.
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Table 2.3
       Summary of Landfill Gas Systems Criteria
Type of Project
                  Specific Criteria
Landfill Gas Collection
and Energy System
                  Landfill Gas Collection and Energy System Landfills that receive biodegradable
                  wastes must have a gas monitoring and control system designed to prevent explo-
                  sions and fires, and to minimize offsite odors and damage to vegetation. Chapter 62-
                  701.600 landfill gas control systems must:

                      •  Be designed to prevent the concentration of  methane and other gases generat-
                        ed by the landfill from:

                         1.   Exceeding 25% of the lower explosive limit (LEL) for gases in structures
                             on or off site, excluding gas control or  recovery components.

                         2.   Exceeding the LEL for gases at or beyond the landfill property boundary.

                         3.   Causing objectionable odors at or beyond the landfill property boundary.

                      •  Be designed for site-specific conditions and  be installed in each section of the
                        landfill that has been filled to design dimensions.

                      •  Be designed to reduce gas pressure in the interior of the landfill by collecting
                       the gases to prevent them from moving laterally. Collection pipes, pathways,  or
                       vents must collect gas from at least the uppermost two thirds of the filled waste
                        or where the more anaerobic conditions exist. Air must not be forced into the
                        collection system. Passive venting or suction  must be used to extract gas.

                      •  Not interfere with  or cause failure of the liner or leachate control systems.

                  Flaring of landfill gases may be used as a method of gas control, particularly control
                  of objectionable odors, in accordance with the permitting requirements of Chapter
                  62-296, F.A.C.

                  Owners or operators of solid waste disposal  units that have received biodegradable
                  waste  must implement a routine gas monitoring program to ensure that the stan-
                  dards  of paragraph (10)  (a) of Chapter 62-701.400,  F.A.C. are met.

                      •  The location of monitoring points and frequency of monitoring must be deter-
                        mined by the following factors:

                         1.   Soil conditions.

                         2.   The hydrogeologic conditions surrounding the facility.

                         3.   The hydraulic conditions surrounding the facility.

                         4.   The location of facility structures and property boundaries.

                      • All monitoring points must be sampled quarterly and the results reported to
                       the Department of Environmental Protection.

                  Landfills using piping or a similar conduit to  convey gas must be furnished with a
                  positive means of gas condensate collection and disposal at each low point in the
                  conveyance system.
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Type of Project        Specific Criteria
Landfill Gas Collection    Landfill gas recovery facilities are considered solid wasfe managemenf facilifies and
and Energy System,       musf be constructed and operated only in accordance with a Department of
continued                Environmental Protection permit.  If a gas recovery facility is included in the approved
                          closure plan or closure permit of the landfill, no separate permit for the facility is
                          required, provided that the facility must meet all of the following requirements:

                              • The application must  be on Form 62-701.900(1) and must contain at least the
                               following:

                                  1.   The information contained in Rules 62-701.320(7) and 62-701.330(4),
                                     FAC.

                                 2.   Where relevant and practical, the information required in Rule 62-
                                     701.600(4), F.A.C.

                                 3.   An estimate of the quantities of gas condensate currently collected or
                                     expected to be collected, and a description of how the  condensate is or
                                     will be disposed of.

                                 4.   A description of the procedures for sampling, analyzing, and reporting
                                     data from the condensate sampling.

                                 5.   A closure plan that must include methods to control landfill gases after
                                     operation of the recovery facility ceases and any other requirements con-
                                     tained in Rule 62-701.400(10), F.A.C.

                              • The owner or operator of a gas recovery facility must post a performance bond
                               to cover the estimated costs of closing the facility. If the gas recovery facility is
                               included in the approved closure plan or closure permit of the landfill, and if
                               the closure costs are included in the landfill closure cost estimates for which
                               financial responsibility is required by Rule 62-701.630, F.A.C., then no separate
                               proof of financial responsibility is required.
                                      A Primer on Developing Florida's Landfill Gas-to-Energy Potential      11

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Table 2.4
       Air Quality Construction and Operation Permits
       (Permits to Construct, Modify, and Operate)
Applicability to
Landfill Gas Projects
                  The construction, expansion, or modification of gas recovery systems at a landfill are
                  subject to air quality permit regulations. Emissions from equipment used at LFGTE
                  facilities,  such as internal combustion engines, are also subject to state air regula-
                  tions. However,  LFGTE projects may be exempt from some air permits because they
                  emit less than the de minimis regulated level. The  need for some air permits may
                  vary depending on the district in which the LFGTE project is located.
Agency Contact
                  State of Florida
                  Department of Environmental  Protection
                  Division of Air Resources Management
                  (See Appendix A for full  addresses for DEP/DARM district offices.]
Description
                  Construction
                  An air construction permit must be obtained by the owner or operator of any pro-
                  posed new or modified facility or emissions unit prior to the beginning of construction
                  or modification of the facility or emissions unit. Each applicant for an air construction
                  permit for an emissions unit subject to Rule 62-210.300(1), F.A.C. must provide to
                  DEP, at a minimum, the following  information:

                      • The nature and  amounts of emissions from the emissions unit.

                      • The location, design, construction, and  operation of the emissions unit to the
                       extent necessary to allow DEP to determine whether construction or modifica-
                       tion of the emissions unit would  result in violations of any applicable provisions
                       of Chapter 403, Florida Statutes, or DEP air pollution rules, or whether the con-
                       struction or modification  would interfere with the attainment and maintenance
                       of any state or national ambient air quality standard.

                  Operation
                  An air operation  permit must be obtained by the owner or operator of any new or
                  modified facility or emissions unit subsequent to construction or modification of the
                  facility or emissions unit and after demonstrating compliance in accordance with the
                  terms and conditions of the construction permit, except as provided in Rules 62-
                  210.360(4) and 62-213.412, F.A.C. The air operation permit has a duration of 5 years.

                  Only one Application for Air Permit, addressing all  construction and operation permit
                  application requirements, need be submitted for facilities classified as Title V sources.
Statute/Regulation
                  Regulations: Rule 62-210.300, F.A.C.
Information
Required/Suggestions
                  In some cases, the applicant may need to supplement the application form with other
                  information requested on the form or otherwise required by rule or statute. Examples of
                  other such information are plot plans, flow diagrams, control equipment design details,
                  stack test reports, operation and maintenance plans, and air quality monitoring reports.
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Landfill Gas Projects in Florida

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Application Process
Review Process
The Application for Air Permit - Long Form can be submitted to the DEP or local air
pollution control agency to which the Department has delegated permitting authority.
All air construction permit applications subject to review under Rule 62-212.400,  F.A.C.,
(prevention of significant deterioration preconstruction review) or Rule 62-212.500,
F.A.C., (nonattainment area preconstruction review) must be submitted to the Bureau
of Air Regulation in Tallahassee. Information on the division of permitting responsibili-
ties among DEP and local  air program offices for other types of applications may be
obtained from the Bureau of Air Regulation or any DEP district air section.

The application form is available as a hard-copy document or a diskette (ELSA:
for electronic Submission of Application). The hard copy of the Application for
Air Permit and all  required supplemental information  must be filed with the
Department in quadruplicate and in accordance with all other applicable
provisions of Chapter 62-4, F.A.C. The ELSA product may be downloaded from
the Internet at http://www.dep.state.fl.us/air/arm.html, or received on disk by
calling the  ELSA hotline at (904) 921-0771.

The Department will also accept accurate hard-copy faxes of the Application for Air
Permit or read-only data diskettes created by applicants or consultants; provided,
however, that any diskette  must be formatted in a manner prescribed by the
Department and be accompanied by four hard copies of the Application Information
Section of the form  (Section I), including all signature pages.

A notice of proposed agency action on  the permit application, where the proposed
agency is to issue the permit, must be published by any applicant for a construction
permit for any proposed new or modified facility or emissions unit.

For units subject to  Prevention of Significant Deterioration (PSD) or Nonattainment-
Area Preconstruction Review,  DEP must notify the public of the opportunity to submit
comments  and to request  a public hearing.

Applications are reviewed  by the Division of Air Resources or Division of Waste
Management Bureau of Solid  & Hazardous Waste, FDEP Within 30 days of receiving
an application, the permitting authority  must determine whether the application is
complete. Within 60 days  of receiving a complete application, the permitting authori-
ty must take final action.
Review/Approval
Period
3 to 6 months for the construction permit; variable for the Title V operating permit
Fees
No processing fee is required in the case of an application for an air operation permit.
An application fee is required for an air construction permit ($2,000).
                                      A Primer on Developing Florida's Landfill Gas-to-Energy Potential
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 Table 2.5
       Solid Waste Permits (Permits to Modify)
Applicability to
Landfill Gas Projects
                  LFGTE projects are part of the engineering controls associated with solid waste land-
                  fills; LFGTE projects involve extraction wells or horizontally placed collection layers in the
                  solid waste and the need to engineer or redesign the final cap and the runoff system.
Agency Contact
                  State of Florida
                  Department of Environmental Protection
                  Waste Management Division
                  (See Appendix A for full addresses for DEP district offices.)
Description
                  A permit is required for any construction or excavation activity on or in a closed
                  existing solid waste land disposal
or
                                                        area.
Statute/Regulation
                  Statutory Authority: Chapter 403.707, F.A.C
Information
Required/Suggestions
                  An applicant for a permit to modify a solid waste management facility must publish
                  and provide proof of publication in a newspaper of general circulation in the area
                  where the facility is  located.
Application Process
                  Applications should be submitted to the Department district office where the facility
                  is located.  DEP has 30 days in which to ask questions regarding the permit and then
                  60 days thereafter to issue or deny the permit.
Review Process
                  Complete permit applications for modification of existing facilities are evaluated by
                  the respective Department district office in accordance with Chapters 62-4 and 62-
                  701, F.A.C. Applications are reviewed by the Division of Air Resources or Division of
                  Waste Management, Bureau of Solid & Hazardous Waste, FDEP Within 30 days of
                  receiving an application, the permitting authority must determine whether the appli-
                  cation is complete. Within 60 days of receiving a complete application, the permitting
                  authority must take final action.
Review/Approval
Period
                  Typically 3 to 6 months
Fees
                 The fee for a permit can range from $0 to $10,000, depending on the permit type
                 (modification of existing operations, construction, or closure).
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Q    Overview of Local  Regulations and  Permits
        Within the framework of federal and state regulation, local governments will have some jurisdiction over
        LFGTE development in nearly all cases. Typically, local permits address issues that affect the surrounding
        community. These permits generally fall under the categories of construction, environment and health,
        land use, and water quality/use.  Local governments are also responsible for administering some permits
        for federal and state regulations in addition to their own. For example, many local governments are
        responsible for ensuring compliance with federal air quality regulations. It should be noted, however, that
        some local standards and regulations are more strict than state or federal regulations.

        Steps to Successful Local Permits Approval:
        The following 6 steps will assist LFGTE project developers to achieve successful local permits  approval:

            Step 1.     Determine which local authorities  have jurisdiction over the project site.

            Step 2.     Contact local, city, and/or county planning  and public works departments to obtain infor-
                       mation about applicable permits and to discuss your plans. Meeting with agency staff to
                       discuss the LFG project and required permits often helps to expedite the permitting
                       process.

            Step 3.     Obtain essential information regarding each permit, including:

                       • What information is required

                       • The permitting process that should be followed

                       • Time frames (including submittal, hearing, and decision dates)

            Step 4.     Obtain copies of the regulations to compare and verify what is required in the  permit
                       applications. If they differ, contact the appropriate permitting agency.

            Step 5.     Submit a complete application. Incomplete applications typically result in processing delays.

            Step 6.     Attend meetings or hearing(s) where the application will be discussed to respond to any
                       questions that are raised. Failure to do  so could result in  delays

        Typical Local Permits
        Table 3.1 lists typical local permits and approvals for LFGTE projects.
                                      A Primer on Developing Florida's Landfill Gas-to-Energy Potential     15

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Table 3.1
       Local Regulations and Permits
Permit
                  Description
Building Permit
                  Most county/local governments require building permits for construction, which entail
                  compliance with several types of building codes, such as plumbing and electrical. A
                  typical building  permit application may require detailed final plans for structures,
                  including electrical and plumbing plans, floor layout, sewage facilities, storm water
                  drainage plan, size and shape of lot and buildings, setback of buildings from proper-
                  ty lines and drain field, access, size and shape of foundation walls, air vents, window
                  access, and heating  or cooling plants (if included in the design).
Zoning/Land Use
                  Most communities have a zoning and land use plan that identifies where different
                  types of development are allowed (i.e., residential, commercial, and industrial). The
                  local zoning board determines whether a particular project meets local land use
                  criteria and can grant variances if conditions warrant. A landfill gas project may
                  require an industrial zoning classification.
Storm Water
Management
                  Some local public works departments require a permit for discharges during con-
                  struction and operation of a LFGTE project. Good facility design that maintains the
                  pre-development runoff characteristics of the site will typically enable the project to
                  meet permitting requirements easily.
Solid Waste Disposal
                  A LFGTE project may generate solid wastes, such as packaging material, cleaning
                  solvents, and equipment fluids. If the landfill is closed, disposal of these solid wastes
                  may be subject to review by a local authority.
Wastewater
                  The primary types of wastewater likely to be generated by a LFGTE project include
                  maintenance wastewater and cooling tower blowdown. The city engineer's office
                  should be contacted to provide information about available wastewater handling
                  capacity and any unique condensate treatment requirements or permits for landfills.
Fire Hazards
and Precautions
                  The mix of gases in landfill gas has a moderate to high explosion potential; methane
                  is explosive in concentrations of 5 to 15 percent in air. Because methane has the
                  potential to migrate from the landfill to onsite or offsite structures, it poses a significant
                  public safety hazard. EPA requires that methane concentrations be less than
                  5 percent at a landfill property line, and less than 2.5 percent of the lower explosive
                  limit (LEL) in a facility's structures. County regulations may call for even stricter stan-
                  dards to be observed at the landfill.
Noise
                  Most local zoning ordinances stipulate the maximum allowable decibel levels from
                  noise sources. These levels vary depending on the location of the site. For example,
                  LFGTE recovery projects located near residential areas will likely have to comply with
                  stricter noise level standards than  projects located in non-populated areas.
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Landfill Gas Projects in Florida

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 Part  2:  Incentive Programs
Q    Overview of Federal Incentive Programs
        There are three federal incentive programs that may apply to LFGTE projects: the Section 29 Tax Credit,
        the Renewable Energy Production Incentive (REPI), and the Qualifying Facilities (QF) Certification. Each
        program is described below.
 1.1   Renewable Energy Production Incentive (REPI)
        The Renewable Energy Production Incentive (REPI), mandated under the Energy Policy Act of 1992, may
        provide a cash subsidy of up to 1.5 cents per kilowatt hour to owners and operators of qualified  renew-
        able energy sources, such as landfills, that began operation between October 1993 and September
        2003.4 Private sector entities may qualify to earn tax incentives based on a tier system. Tier 1 facilities
        (solar, wind, geothermal, or closed loop biomass) receive full payments or pro rata payments if funds are
        too minimal to match all  requests. Any remaining funds fall to Tier 2 which includes landfill gas facilities.
        If there are insufficient funds to cover Tier 2 applicants, a pro-rata system is implemented. The
        Department of Energy (DOE) will make incentive payments for 10 fiscal years, beginning with the fiscal
        year in which application for payment for electricity generated  by the facility is first made  and the facility
        is determined by DOE to be eligible for receipt of an  incentive  payment. The period for payment under
        this program ends in fiscal year 2013. REPI payments are subject to adjustment because  they are appro-
        priated by Congress each year.
        For further information, contact:

        U.S. Department of Energy
        National Renewable Energy Laboratory
        Golden Field Office
        Golden, Colorado 80403
        (303) 275-4795
U.S. Department of Energy
Efficiency and Renewable Energy
Forrestal Building, Mail Station EE-10
1000 Independence Avenue, S.W.
Washington, DC 20585
Phone: (202) 586-2206
 1.2   Qualifying Facilities Certification
        LFGTE projects that generate electricity will benefit from Qualifying Facilities (QF) certification, which is
        granted through the Federal Energy Regulatory Commission (FERC). The following describes the bene-
        fits of QF status and the steps for applying for such status.

        The Public Utility Regulatory Policies Act (PURPA) — one of five parts of the National Energy Act of 1978
        — was designed to promote conservation of energy and energy security by removing barriers to the
        development of cogeneration facilities and facilities that employ waste or renewable fuels. Such facilities
        are called Qualifying Facilities, or QFs. Under PURPA, utilities are required to purchase electricity from
        QFs at each utility's avoided cost of generating power. PURPA provides that a small power production
        facility, such as a LFGTE project that meets FERC standards, can become a QF.
       4 Final Rule Making, 10 Federal Register Part 451, July 19, 1995, Vol. 60, No. 138.
                                     A Primer on Developing Florida's Landfill Gas-to-Energy Potential
                                           17

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        In order to apply for QF status, applicants must prepare either (1) a Notice of Self-Certification, which
        asserts compliance with the FERC's technical and ownership criteria, or (2) an Application for
        Commission Certification of Qualifying Status, which requires a draft Federal  Register notice and which
        provides actual FERC approval of QF status. In either case, the applicant must also file Form 565, which
        is a list of questions about the project, and  must pay any filing fees associated with certifications, exemp-
        tions, and other activities. FERC will provide the QF "Info Packet" that describes the necessary steps,
        requirements, and  background information. After submittal of the initial application, further justifications
        and submittal of information may be required.

        For the QF Info Packet and applications, contact:

        Federal Energy Regulatory Commission
        Qualifying Facilities Division
        825 North Capitol Street, N.E.
        Washington, DC 20426
        Phone: (202) 208-0577
        http://www.ferc.fed.us


1.3    Section 29 Tax Credit
        Developers of LFGTE projects who sell LFG to an unrelated third party may qualify for a tax credit under
        Section 29 of the Internal Revenue Service  (IRS) tax code. In order to take advantage of the credits, pro-
        ject developers may bring in an outside party when developing power projects. The Section 29 tax credit
        was established in  1979 to encourage development of unconventional gas resources, such as landfill gas.
        Section 29 tax credits are available through 2007 to LFG projects that have a  gas sales agreement in
        place by December 31, 1996 and  are placed in service by June 30, 1998. The credit has been extended
        several times by the U.S. Congress,  and currently it is discontinued.
       State Incentive Programs
       The State of Florida does not currently provide tax incentives for LFGTE projects. However, as a State
       Ally in the Landfill Methane Outreach  Program, the  Florida Department of Environmental Protection will
       continue to evaluate the creation of further incentives within  Florida for this purpose.
       Electricity Restructuring and  LFGTE
What Is Electricity Restructuring?
Electricity restructuring refers to the introduction of competition into both the wholesale and retail electricity mar-
kets. Until now, electric utilities operated as monopolies authorized by federal and state regulatory authorities as
the sole provider of electric service to consumers within a specific service territory. Under restructuring, utilities
will lose these monopolies, enabling other energy providers to compete for their customers. The result may be
more energy options for consumers, lower energy prices,  and greater use of renewable energy sources.

Efforts to restructure the electric utility industry began in 1978 with passage of the Public Utilities Regulatory Policies
Act (PURPA), which required utilities to buy a portion of their power from unregulated power generators in an effort
to encourage the development of smaller generating facilities, new technologies, and renewable energy sources.
The National Energy Policy Act of 1992 (EPACT) expanded on PURPA, allowing more types of unregulated compa-
18     Landfill Gas Projects in Florida

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nies to generate and sell electricity, effectively creating a competitive wholesale market for electric power.

Restructuring at the retail level has been a hot issue in many states since the passage of EPACT, which delegated
states the authority to introduce competition among electric utilities within their borders. As of January 1999,
22 states have enacted some form of restructuring legislation, while the remaining 28 are considering such legislation.

How Do These Changes Affect Landfill Gas Recovery?
Many states are including  renewable energy provisions in their restructuring legislation. Such  provisions mandate
utilities to include a certain percentage of electricity generated from renewable, or "green energy," sources into
their energy mixes.  LFGTE is one such green energy source.

In March 1998, the  Clinton Administration unveiled its "Comprehensive Electricity Competition Plan" to restruc-
ture the electricity industry nationwide. Contained in that  proposal is a Renewable Portfolio Standard (RPS) that
would guarantee that a minimum percentage of the nation's electricity be powered by green  energy. Energy ser-
vice providers would be required to cover a percentage of their electricity sales with generation from non-hydro-
electric renewable sources such as wind, solar, geothermal, and biomass (which includes LFGTE).

Marketing Landfill Gas Recovery as  Green Power
One  of the emerging areas and most promising mechanisms to encourage utilities and other energy marketers
to participate in LFGTE projects is the development of green marketing programs. Green marketing programs
are designed to enable energy marketers to position renewable energy products (including LFGTE) as premium
products, and therefore, collect a premium price from  their customers. In addition, green marketing allows energy
marketers in competitive marketplaces to  differentiate their energy product, and allows utilities in  non-restruc-
tured marketplaces to gain critical product marketing experience  in preparation for competition. However, the
general public  is less familiar with LFGTE than other sources of renewable energy; support from the LMOP can
help  ensure the success of early LFGTE green marketing efforts.

Get the Latest Information on Electricity Restructuring in Your State
For up-to-date information on electricity restructuring in Florida, visit the National Conference  of State Legislatures
Web site at: http://www.ncsl.org/programs/esnr/restru.htm. This  site contains a glossary of terms related to
restructuring, as well as links to the full text of restructuring legislation passed by states.
                                     A Primer on Developing Florida's Landfill Gas-to-Energy Potential     19

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Appendix A: State Contacts
State of Florida
Department of Environmental
Protection
Mary Jean Yon
Solid Waste Section (MS #4565)
State of Florida  Department of
Environmental Protection
600 Blair Stone Road
Tallahassee, FL  32399-2400
Tel:  (850) 488-0300
Fax: (850) 414-0414
Central District
(Brevard, Indian River, Lake,
Marion, Orange, Osceloa,
Seminole and Volusia)
Vivian F. Garfein, Director
3319 Maguire Boulevard, Suite 232
Orlando, FL 32803-3767
Tel: (407) 894-7555
Fax: (407) 897-2966

Air Resources Program
Administrator- Len Kozlov
Waste Program Administrator-
Bill Bostwick

Central District Satellite Office
Debra Valin
13 East  Melbourne Avenue
Melbourne, FL 32901
Tel: (407) 984-4800
Fax: (407) 984-4809


Northwest District
(Bay, Calhoun, Escambia, Franklin,
Gadsden, Gulf, Holmes, Jackson,
Jefferson, Leon, Liberty, Okaloosa,
Santa Rosa, Wakulla, Walton and
Washington)
Bob Cooley, Director
160 Governmental Center
Pensacola, FL 32501-5794
Tel: (850) 444-8300
Fax: (850) 444-8417

Air Resources Program
Administrator-
Ed Middleswart
Waste Program Administrator-
Tom Moody
Northwest District
Branch Office
Gary Shaffer
2353 Jenks Avenue
Panama City,  FL 32405
Tel: (850) 872-4375

Northwest District
Branch Office
Gerry Neubauer
2815 Remington Green Circle,
Suite A
Tallahassee, FL 32308
Tel: (850) 488-3704
Northeast District
(Alachua, Baker, Bradford, Clay,
Columbia, Dixie, Duval, Flagler,
Gilchrist, Hamilton, Jefferson,
Lafayette, Levy, Madison, Nassau,
Putnam, St. Johns, Suwannee,
Taylor and Union)
Ernest E. Frye, Director (x 201)
7825 Baymeadows Way,
Suite 200B
Jacksonville, FL 32256-7590
Tel: (850) 448-4300
Fax: (850) 448-4363

Air Resources Program
Administrator-Chris Kirts
Waste Program Administrator-
Mike Fitzsimmons

Northeast District Branch Office
Patricia  Reynolds
5700 Southwest 34 Street,
Suite 1204
Gainesville, FL 32608
Tel: (352) 955-2095
Fax: (352) 377-5671
South District
(Charlotte, Collier, Glades, Hendry,
Highlands, Lee and Monroe)
Peter Ware, Director
2295 Victoria Avenue, Suite 364
Fort Myers, FL 33901
Tel: (941)332-6975
Fax: (941) 332-6969
Air Resources Program
Administrator- David Knowles
Waste Program Administrator-
Phil Barbaccia

South District Satellite Office
Ron McGregor
7451 Gold Course Boulevard
Punta Gorda, FL 33982-9359
Tel: (941) 693-4697

South District Branch Office
R.J. Hebling
2796 Overseas Highway, Suite  221
Marathon, FL 33050
Tel: (305) 289-2310
Southeast District
(Broward, Dade, Martin,
Okeechobee, Palm Beach and
St. Lucie)
Carlos Rivero de Aguilar, Director
400 North Congress Avenue
West Palm Beach, FL 33401
P.O. Box 15425
West Palm Beach, FL 33416-5425
Tel: (407) 681-6600
Fax: (407) 681-6755

Air Resources Program
Administrator- Isidore Goldman
Waste Program Administrator-
Vic Kamath

Southeast District Branch Office
John Moulton
1801  Southeast Hillmoor Drive,
Suite 204
Port St.  Lucie, FL 34952
Tel: (407) 871-7662
Fax: (407) 871-7666

Southwest District
(Citrus, Desoto, Hardee, Hemando,
Hillsborough, Levy, Manatee,
Marion,  Pasco, Polk, Pinellas,
Sarasota, Sumter)
Dr. Richard D. Garrity, Director
3804 Coconut Palm Drive
Tampa,  FL 33619-8218
Tel: (813) 744-6100 (x 352)
Fax: (813) 744-6084
20     Landfill Gas Projects in Florida

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Air Resources Program
Administrator-
Bill Thomas
Waste Program Administrator-
Bill Kutash

Southwest District
Satellite Office
Steve Thompson
170 Century Boulevard
Bartow, FL 33830-7700
Tel: (941) 534-1448

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