The Energy Recovery Council filed comments this week on EPA’s notice seeking input on measuring waste generation, recovery, and disposal in the United States. EPA has for years relied upon data generated by the Franklin Institute which estimated the amount of waste generated in the United States based on manufacturing data. Due to inherent flaws in this process which leads to the gross underestimation of waste generation, the ERC has relied upon the data published by BioCycle/Columbia University in its biannual State of the Garbage in America, which relies on data reported by state agencies. ERC’s comments are intended to drive EPA to reporting-based data. In addition, ERC recommends that they begin to track all types of waste, not just traditional municipal solid waste.