Gas Capture, Boundary Methane, and Benzene: A Request for Help
by Trisha Kunst · resident less than 3/4 mile from the landfill · submitted November 4, 2026
This is the written comment I submitted to the Washtenaw County Board of Commissioners through the County's Official Public Comment Form, for the packet of its regular meeting on November 4, 2026.
To: Washtenaw County Board of Commissioners
From: Trisha Kunst, resident less than 3/4 mile from the landfill
Re: Gas capture, methane at the boundary probes, and benzene at Arbor Hills; using the County's 2017 Host Community Agreement
Submitted: November 4, 2026, 11:23 AM, Official Public Comment Form (written; Board of Commissioners Meeting, New Business)
Commissioners,
I am asking for your help at Arbor Hills, the current landfill that is south of Six Mile, which operates under this County's solid waste plan.
The landfill is capturing a smaller share of its gas. The gas plants' monthly reports to EGLE show collection averaged about 8,080 cubic feet per minute in January-September 2024, 7,630 in 2025, and 7,570 in 2026. The gas-generation model EGLE uses for the landfill projects more gas each year. By that model, the share captured fell from about 75% to 70% to 69%.
Methane is reaching the boundary probes. GMW-15R2, just east of Napier Road, sits almost directly across the road from where the landfill's underground slurry wall ends. There, methane read 68.4% on June 25, 2026, more than 13 times the legal limit. In every one of the 17 quarterly reports GFL filed under its consent judgment, from April 2022 through June 2026, at least one boundary probe read above that limit. Explosive-range gas could form if it collects in buildings or utility lines.
Benzene is my top concern, and no rule requires anyone to measure it in the air. By ATSDR's rule of thumb, landfill emissions of non-methane organic compounds, which include benzene, double with every 18°F rise in temperature. One Arbor Hills gas well read 177°F in 2025, and EGLE allows it to run up to 180°F through May 1, 2028. I have found no record that anyone measures benzene in the air around the landfill. If you are told there is no benzene problem, ask to see the measurements. An expert with 35 years of landfill regulating and firefighting experience will still help if asked; the County has had his contact since August. Children are close by: Salem Elementary is about 3,200 feet from the waste boundary, and Ridge Wood Elementary about 3,900 feet.
My ask: the County's 2017 Host Community Agreement lets its Board of Public Works:
request copies of every government inspection report (Section 5.02);
receive every notice of violation (including from YCUA) and the owner's response (Section 9.04); and
call a meeting in January on any right or obligation in the agreement, with written notice and a topic list in December (Section 9.07).
Please ask the Board of Public Works to send that notice, with gas capture, the boundary probe readings, and subsurface elevated temperature events on the list, and to request the inspection reports now.
Every figure in this comment traces to a primary record or a field measurement: EGLE filings, the operator's consent judgment quarterly reports, the County's 2017 Host Community Agreement, and ATSDR's Landfill Gas Primer. Wellfield data and EGLE filings are published at Arbor Hills Monitor.
Commissioners,
I am asking for your help at Arbor Hills, the current landfill that is south of Six Mile, which operates under this County's solid waste plan.
My ask: the County's 2017 Host Community Agreement lets its Board of Public Works:
Please ask the Board of Public Works to send that notice, with gas capture, the boundary probe readings, and subsurface elevated temperature events on the list, and to request the inspection reports now.
Please help us.
Trisha Kunst
Resident less than 3/4 mile from the landfill
arborhillsmonitor.org
Every figure in this comment traces to a primary record or a field measurement: EGLE filings, the operator's consent judgment quarterly reports, the County's 2017 Host Community Agreement, and ATSDR's Landfill Gas Primer. Wellfield data and EGLE filings are published at Arbor Hills Monitor.