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EMISSIONS REDUCTION ASSURANCE COMMITTEE

Landfill Gas Method Crediting Period Review Report

28 March 2018

Contents

1 Executive summary ........................................................................................................... 1

2 Background ....................................................................................................................... 4

2.1 Committee to undertake crediting period extension reviews ....................................... 4

2.2 Approach to the crediting period review of the landfill gas method ............................. 5

3 Findings ............................................................................................................................ 5

3.1 Activity overview ......................................................................................................... 5

3.1.1 The waste industry is large and widely dispersed ................................................ 5

3.1.2 Most waste sector emissions are generated by landfills ...................................... 7

3.1.3 Landfills reduce emissions by capturing and combusting methane...................... 8

3.1.4 Many ERF landfill gas projects were supported by previous Commonwealth and state schemes ................................................................................................................... 9

3.1.5 ACCUs generated and contracted under the method ........................................ 11

3.2 Drivers of landfill gas capture activities ..................................................................... 15

3.2.1 Regulatory requirements for landfill gas capture ................................................ 15

3.2.2 Reputation and social reasons to reduce emissions .......................................... 17

3.2.3 Financial reasons to reduce emissions .............................................................. 18

4 Recommendations .......................................................................................................... 21

ABBREVIATIONS

ACCU Australian Carbon Credit Unit

ERF Emissions Reduction Fund

RET Renewable Energy Target

LGC Large-scale Generation Certificate

GGAS Greenhouse Gas Reduction Scheme

Mt megatonnes (million tonnes)

NGERS National Greenhouse and Energy Reporting

CO2-e carbon dioxide equivalent

CFI Carbon Farming Initiative

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1 EXECUTIVE SUMMARY

The Emissions Reduction Assurance Committee (the Committee) has undertaken a review of the crediting period of the Carbon Credits (Carbon Farming Initiative—Landfill Gas) Methodology Determination 2015 (the landfill gas method). The method allows businesses and others to earn carbon credits by preventing the release of methane generated by the degradation of organic matter in landfill. Existing projects capture the gas and combust it in a flare or internal combustion engine.

The review focussed on whether the period over which projects can earn credits (the ‘crediting period’) should be extended. The current crediting period for landfill gas projects is seven years.

The Committee’s findings and recommendations were informed by the following.

• An analysis of existing projects and industry trends.

• Consultations with industry and interested stakeholders.

- The Committee received 16 submissions on an issues paper made available to the public for four weeks from 13 June to 11 July 2017.

- A meeting of the landfill gas technical working group including waste management and landfill gas companies, waste industry peak bodies, technical experts and state and territory governments.

- Conversations with, and information supplied by, state and territory regulators.

• A study of Australian landfill gas projects undertaken by consultants SMEC.

• A financial assessment of landfill gas projects, undertaken by RM Consulting Group (RMCG) using data provided by industry participants.

• Members of the Committee visited landfills in Queensland and the Australian Capital Territory to see landfill gas projects and discuss operational matters with project managers.

In undertaking the crediting period extension review, the Committee focused on two main issues:

• the extent to which the extension of the crediting period would result in the issuance of credits to existing projects that would have continued in the ordinary course of events; and

• the extent to which the extension of the crediting period would result in new project activities (new projects and extensions of existing projects) that would not occur in the ordinary course of events.

In performing its functions, the Committee seeks to balance environmental integrity with the need to encourage abatement activities. Excessive conservatism in the attempt to ensure environmental integrity will obstruct project uptake and exclude the cheapest forms of abatement. Insufficient conservatism will result in the issuance of credits of questionable

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integrity. While a balance must be struck, where there is uncertainty, the Committee errs on the side of conservatism. This is consistent with the offsets integrity standards, which require all estimates, projections and assumptions in methods to be conservative1.

To inform the review, the Committee sought information on registered projects from landfill gas operators. Information was provided for only 18 projects—eight electricity generation projects and 10 flaring projects. Cost and revenue data for two of the generation projects could not be verified. Where the Committee felt there was insufficient information to make a definitive judgment on a material issue, it adopted a conservative position to avoid the issuance of credits of low environmental integrity.

As a result of its review, the Committee made the following nine findings.

1. There are approximately 665 operating landfills in Australia, which receive around 27 million tonnes of solid waste each year. These landfill sites are widely dispersed across Australia, and sites vary significantly in size, age, design and operational conditions.

2. The landfill gas method has 101 registered projects. The Australian Government has entered into contracts with 87 projects to purchase Australian Carbon Credit Units (ACCUs) representing over 20 million tonnes of abatement. Crediting periods of 95 projects (94 per cent) expire during or after 2021. The Emissions Reduction Fund register shows 76 projects transitioned from the former Carbon Farming Initiative methods. Fifty of these projects had previously transitioned from the former NSW Greenhouse Gas Reduction Scheme (GGAS) or Greenhouse Friendly schemes into the Carbon Farming Initiative.

3. Despite increasing generation of methane from landfill, net emissions from the waste sector have decreased since 1990 largely as a result of landfill gas capture and combustion activities. Landfill gas capture is more prevalent at larger sites.

4. There are three main potential drivers of landfill gas capture activities: state and territory waste regulations; reputational and social factors; and financial returns from the sale of tradeable permits (ACCUs and Large-scale Generation Certificates (LGCs)) and electricity.

5. While most state regulations and guidance for landfills reference mitigation of greenhouse gases, they typically set standards for safety and odour management. Reflecting this, the regulations usually require landfill gas project operators to meet odour and safety standards rather than capture and combust defined quantities of landfill gas. The practical effect of the regulations is that landfill gas usually needs to be captured and combusted to some extent. However, the stringency of the regulatory requirements varies significantly between and within jurisdictions. The method accounts for the regulatory requirements by imposing a discount on calculated abatement. For new projects, the discount is the larger of a calculated amount based on the state and territory regulations that apply to the site or a default of 30 per cent of the methane destroyed in the combustion device, unless the proponent can establish the site is subject to no regulatory requirements (in which case the discount is zero). Different discounts are used for projects that transitioned from other schemes: a 24 per cent discount is applied to projects from the New South Wales

1 See section 133(1)(g) of the Carbon Credits (Carbon Farming Initiative) Act 2011.

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Greenhouse Gas Abatement Scheme (NSW GGAS); and no discount is applied to projects from the Greenhouse Friendly program.

6. There are reputational and social factors that could potentially prompt landfill operators to reduce landfill gas emissions. However, there is no evidence to suggest these factors have had, or are likely to have, a material impact on operators’ decisions to establish or continue landfill gas capture and combustion activities.

7. The primary reasons operators undertake projects are regulatory and financial. Capture and combustion of landfill gas beyond the levels required to meet state and territory regulations is driven largely by the financial returns associated with the sale of ACCUs, LGCs and electricity. The magnitude and timing of the revenues and expenses associated with landfill gas projects differs between the two eligible project types: flaring and electricity generation. The initial capital costs associated with installing a flare and the associated infrastructure are significantly less than those associated with an electricity generation project, as are the operating and maintenance costs. Both project types have to continually install new pipes and other infrastructure to capture landfill gas and transport it to the combustion device as new cells are created at landfills. Both flares and generators also require ongoing maintenance, much of which is attributable to the ‘dirty’ nature of landfill gas. However, unlike flares, electricity generators must undergo expensive overhauls every 4-8 years. While the costs associated with the installation and operation of electricity generation projects are substantially higher than those associated with flaring projects, so too are the revenues. Both types of projects receive revenue from the sale of ACCUs. However, unlike flaring projects, electricity generation projects receive revenue from the sale of electricity and LGCs issued under the Renewable Energy Target (RET).

8. Extending the crediting period for flaring projects is unlikely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events. The only source of revenue from the operation of flaring-only projects is the sale of ACCUs. The capture and combustion of landfill gas with flares involves ongoing capital expenditure for piping infrastructure, and maintenance and operational costs associated with the flares and associated equipment. For existing flaring projects, if they are no longer able to access and sell ACCUs, they are unlikely to be able to cover the costs associated with the operation of the project. As a consequence, in the absence of applicable regulatory obligations, the capture and combustion activities are likely to stop. The same applies to new project activities: extension of the crediting period is unlikely to result in the issuance of ACCUs for emissions reductions that would otherwise occur in the ordinary course of events.

9. Extending the crediting period for electricity generation projects is likely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events. For existing electricity generation projects, in most cases, the revenues from the sale of electricity and LGCs are likely to cover the ongoing capital, operational and maintenance costs of the projects, including engine refurbishment costs. Due to this, it is likely that, in most instances, existing electricity generation projects will continue in the absence of the incentive provided by the Emissions Reduction Fund (ERF). Similarly, the available evidence indicates the extension of the crediting period is unlikely to promote new electricity generation projects that would not have otherwise occurred. The Committee’s ability to reach definitive conclusions on these issues was affected by data

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limitations and uncertainties associated with policy settings and the electricity market. However, on the basis of the available information and having regard to the need for conservativism, the Committee concluded that extending the crediting period for electricity generation projects is likely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events.

On the basis of the above findings, the Committee’s recommendations are as follows.

• The crediting period for flaring-only projects should be extended for no more than five years. Any extension to the crediting period would be in addition to existing crediting periods, which typically run until 2021, but up to 2025 for some recently registered projects. There is a risk that extending crediting periods by more than five years would overlap with future regulations or other mandatory action.

• On balance, and having regard to the need for conservatism, the crediting period for electricity generation projects should not be extended. Extending the crediting period for electricity generation projects carries too great a risk of crediting abatement that is likely to occur in the ordinary course of events.

The Committee is aware that, if the crediting period is extended for flaring-only projects but not for electricity generation projects, it could potentially prompt proponents to switch between the project types. The Committee is also aware that not extending the crediting period for electricity generation projects could undermine the incentive for these projects to capture and combust ‘surplus methane’ (methane unable to be used for electricity generation) through the installation and operation of flares. These issues will be considered in the full review of the method. The Committee will also give further consideration in the full review to the application of the method to small and medium landfills.

2 BACKGROUND

2.1 Committee to undertake crediting period extension reviews

The Committee’s functions include conducting crediting period extension reviews under s255A of the Carbon Credits (Carbon Farming Initiative) Act 2011 (the Act). These reviews require the Committee to advise the Minister for the Environment and Energy whether a method should be varied to extend the period for which emissions reductions projects can earn ACCUs. Crediting period extension reviews are required to be undertaken for each method before an eligible offsets project covered by the determination enters the last 12 months of its crediting period.

The crediting period extension advice provided by the Committee does not automatically lead to changes to the method. It is up to the Minister to decide whether the method is varied to give effect to the Committee’s advice. If the Minister decides to vary the method, the Minister must obtain the Committee’s advice on whether the proposed variation meets the offsets integrity standards. As part of the variation process, the Committee must seek public comment on the proposed variation.

In conducting crediting period extension reviews, the Committee must consider whether the method would still meet the ‘additionality standard’ in paragraph 133(1)(a) of the Act if the

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crediting period was extended 2. The additionality standard requires the application of the relevant methodology determination to result in carbon abatement that is unlikely to occur in the ordinary course of events. While the Committee must consider the additionality standard, it can also have regard to other factors, including the other offsets integrity standards in subsection 133(1) of the Act.

2.2 Approach to the crediting period review of the landfill gas method

In undertaking the crediting period extension review of the landfill gas method, the Committee focused on two main issues:

• the extent to which the extension of the crediting period would result in the issuance of ACCUs to existing projects that would have continued in the ordinary course of events; and

• the extent to which the extension of the crediting period would result in new project activities (new projects and extensions of existing projects) that would not occur in the ordinary course of events.

In analysing these issues, the Committee inquired into the reasons why landfill managers capture and combust landfill gas, including:

• state and territory landfill gas regulations;

• financial costs and revenue from the operation of landfill gas capture and combustion projects; and

• other motivators to undertake landfill gas projects such as reputational benefits.

This report reviews the context for landfill gas projects, including trends in solid waste management and industry activity, then examines in detail the factors that influence decisions to commence new projects and continue existing landfill gas projects.

3 FINDINGS

3.1 Activity overview

3.1.1 The waste industry is large and widely dispersed

There are approximately 665 operating landfills in Australia3, which receive around 27 million tonnes (Mt) of solid waste each year4. This amount equates to around 42 per cent of the estimated total solid waste generated in Australia (64 Mt)5. The remainder of the waste (58 per cent, 37 Mt) is recycled, reprocessed (including biological treatment/composting) or incinerated6. Landfills and other solid waste management facilities are clustered around the large population centres near Australia’s coastline (Figure 1).

2 See subsection 255A(2) of the Act. 3 Department of Environment, Water, Heritage and the Arts (2009), National Waste Overview. 4 Blue Environment (2017), Australian National Waste Report 2016. 5 Blue Environment (2017), Australian National Waste Report 2016. 6 Department of the Environment and Energy (2017), National Inventory Report 2015.

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Figure 1: Locations of waste management facilities, including recycling facilities and transfer stations. Source: Geoscience Australia.

Figure 2 shows a distribution of landfills by size (tonnes of waste received per year) for 498 landfills. The data are from 2008-10. Landfills in the unknown tonnage category are likely to receive less than 20,000 tonnes of waste per year7. Although large landfills represent a relatively small proportion of all sites, the top eight per cent of landfills process over 55 per cent of the total waste received. Almost 90 per cent of landfilled waste is processed by 20 per cent of landfills (133 landfills)8.

7 Blue Environment (2013), Analysis of Landfill Survey Data. 8 Commonwealth of Australia (2016), National Inventory Report 2014 (revised) vol. 2.

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Figure 2: Landfill size distribution. Source: Blue Environment (2013) Analysis of Landfill Survey Data. Data set comprised of 498 landfills responding to surveys in 2008 and 2010. The Australian Bureau of Statistics 2009-10 yearbook found landfills tended to be largely government operated, though the analysis was based on a relatively small sample. Of 349 sampled sites, only 54 were private. More recent data were not available. Many local governments outsource landfill management to private specialists9, and there is a trend towards increased private sector management of landfills, particularly in metropolitan areas and major cities where landfills tend to be larger10.

Finding 1: There are approximately 665 operating landfills in Australia, which receive around 27 million tonnes of solid waste each year. These landfill sites are widely dispersed across Australia, and sites vary significantly in size, age, design and operational conditions.

3.1.2 Most waste sector emissions are generated by landfills

Landfills generate methane, a potent greenhouse gas, when organic waste decays in anaerobic conditions. The anaerobic decomposition of organic matter in a landfill is a complex process that requires several groups of microorganisms to act in a synergistic manner under favourable conditions. Emissions emanate over a long period from deposited waste, typically over 50 years in Australia. Other gases, mostly carbon dioxide, are also produced and the mix of emitted gases is known as landfill gas. Methane typically makes up around half of landfill gas11. Emissions of carbon dioxide generated by the decay of waste and from the secondary combustion of methane are considered to be from biomass sources and are not included in the waste sector inventory12.

In 2015, the waste sector emitted 11.4 Mt of carbon dioxide equivalent (CO2-e) to the atmosphere (net emissions), around 2.2 per cent of Australia’s total emissions (excluding land

9 Department of the Environment, Water Heritage and the Arts, National Waste Reporting 2013. 10 Hyder Consulting (2011). Role and performance of local government: waste and recycling related data and information. 11 Intergovernmental Panel on Climate Change (2000). Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories. 12 Generally, biomass-related CO2 emissions and removals are accounted for in the ‘Land use, land-use change and forestry’ (LULUCF) section of the National Inventory Report.

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use emissions)13. The majority of these emissions were from solid waste disposal in landfills, which contributed 8.4 Mt CO2-e (74 per cent) of waste emissions14.

3.1.3 Landfills reduce emissions by capturing and combusting methane

Landfill emissions can be reduced by capturing and combusting landfill gas. In a landfill gas project, pipes embedded in the landfill collect landfill gas before it escapes to the atmosphere. Landfill gas flows through the pipes to a device which combusts the gas, converting the methane component to carbon dioxide. Emissions are reduced because carbon dioxide is a significantly less potent greenhouse gas than methane. While landfills generated a total of 16.5 Mt CO2-e emissions in 2015, they also captured and combusted methane equivalent to 8.1 Mt CO2-e, reducing emissions to the atmosphere by half (net emissions 8.4 Mt CO2-e)15.

Annual totals of methane capture have increased steadily since 1990, when negligible methane was captured or combusted by landfills. The most recent data available from the National Greenhouse Gas Inventory show that an additional 0.6 Mt CO2-e was captured and combusted in 2015 (8.3 Mt CO2-e) compared to 2014 (7.7 Mt CO2-e)16. The success of landfill gas capture and combustion since 1990 in reducing net landfill emissions is illustrated by National Greenhouse Gas Inventory data, shown in Figure 3.

Figure 3: Emissions from solid waste disposal in landfill. Source: Australian Greenhouse Emissions Information System.

Under the ERF, landfill gas projects can earn ACCUs for every tonne of CO2-e prevented from entering the atmosphere over a seven year period (the ‘crediting period’). ACCUs may be sold to the government through a competitive reverse auction process or in the secondary market.

Projects may be registered under the method as one of four types (Figure 4):

13 Commonwealth of Australia (2016), National Inventory Report 2014 (revised) vol. 2. 14 Commonwealth of Australia (2016), National Inventory Report 2014 (revised) vol. 2. 15 Commonwealth of Australia (2016), National Inventory Report 2014 (revised) vol. 2. 16 Commonwealth of Australia (2016), National Inventory Report 2014 (revised) vol. 2.

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• new projects must have had no gas capture occurring before the beginning of the project. 18 new projects are registered under the ERF, representing 18 per cent of the 101 landfill gas projects currently registered;

• recommencing projects must show that no gas collection system was operating in the three years before the project application was made. No recommencing projects have registered under the ERF;

• upgrade projects must provide records showing evidence of gas capture efficiency before and after the project. Seven upgrade projects are registered under the ERF, representing seven per cent of all projects; and

• transitioning projects moved across to the landfill gas method from methods under the Carbon Farming Initiative. 76 projects—three-quarters of all projects—registered under ERF transitioned from the CFI methods.

Figure 4: Registered landfill gas projects by type.

3.1.4 Many ERF landfill gas projects were supported by previous Commonwealth and state schemes

The existing landfill gas method builds on two earlier, now revoked, methods in operation during the former Carbon Farming Initiative (CFI) scheme:

• Carbon Farming (Capture and Combustion of Methane in Landfill Gas from Legacy Waste) Methodology Determination 2012; and

• Carbon Credits (Carbon Farming Initiative) (Capture and Combustion of Methane in Landfill Gas from Legacy Waste: Upgrade Projects) Methodology Determination 2012.

Projects under the two CFI methods were eligible to transition to the ERF method and commence a new seven year crediting period. A number of projects that transitioned from the CFI to the ERF had commenced under earlier emissions reduction schemes: the Australian Government Greenhouse Friendly scheme (14 projects) and the New South Wales Greenhouse Gas Reduction Scheme (GGAS; 36 projects). The Greenhouse Friendly scheme

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operated from 2001 to 2010 and allowed the creation of carbon credits for approved abatement activities. Greenhouse Friendly carbon credits could be traded in voluntary and international carbon markets. The emissions trading scheme GGAS ran from 1 January 2003 to 30 June 2012.

A full table summarising registered projects is provided at Appendix B. Timing of the various schemes is shown against solid waste emissions data in Figure 5.

Figure 5: Emissions from solid waste disposal (as shown in Figure 3) and timing of operation of various emissions reduction schemes. Source: Australian Greenhouse Emissions Information System.

Projects transitioning from earlier programs were assessed as valid according to the criteria of their original program. Four projects remain registered under a CFI method.

Landfill gas projects are also able to claim Large-scale Generation Certificates (LGCs) under the Renewable Energy Target scheme (RET) for electricity generated from the combustion of methane.

The baseline abatement for a landfill gas project is the abatement that would have occurred in the absence of the project. Baseline abatement is calculated by multiplying the methane combusted by the proportion required to be combusted as a result of state and territory regulations and licence requirements.

Proponents of new projects must calculate the methane required to be combusted as a result of state and territory regulations using one of several methods set out in schedule one of the method. This calculated regulatory proportion is then compared to a default regulatory proportion. The default regulatory proportion is 30 per cent if the site has a regulatory

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requirement to capture landfill gas, or zero if there is no regulatory requirement. The proponent must use the larger of the calculated and default regulatory proportions to calculate the baseline abatement of the project, unless there is no regulatory requirement.

Projects that transitioned from the CFI use the proportion as determined under the former relevant CFI determination. These proportions are as follows.

• For projects registered under the CFI—whichever is the larger of the calculated regulatory baseline or the default regulatory baseline (30 per cent if there are qualitative requirements to manage landfill gas or zero if no regulatory requirements apply).

• For projects transitioning from NSW GGAS—24 per cent.

• For projects transitioning from Greenhouse Friendly—zero per cent.

The net abatement amount for a project under the landfill gas method is calculated as the difference between the baseline abatement and the project abatement for the reporting period. Project abatement is calculated as the amount of methane combusted by the combustion device. The amount of methane combusted by the device is adjusted to account for oxidation of methane that would have occurred if the methane had not been combusted.

3.1.5 ACCUs generated and contracted under the method

The Australian Government has contracted to purchase carbon credits equivalent to 20.4 million tonnes of carbon dioxide abatement from 87 projects. Over 14.4 million ACCUs have already been issued to landfill gas projects. The end date for crediting periods of landfill gas projects ranges between 2017 and 2025, though the crediting period for the majority of projects (72 per cent) will expire in 2021 (Figure 6).

Figure 6: Distribution of crediting period end dates. One proponent registering a project in 2017 elected to delay commencement of the project’s crediting period, resulting in a crediting period end date in 2025.

Landfill gas operators enter into contracts with site owners for the rights to the landfill gas and install and operate the infrastructure necessary for landfill gas capture and combustion. Three-

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quarters of all projects are run by five operators, and one operator runs 40 per cent of all registered projects (Table 1).

Table 1: Operators under the landfill gas method.

Operator Number of registered projects

Number of ACCUs issued

Contracted abatement

LMS Energy 41 7,732,726 9,770,306 EDL LFG 10 2,696,356 3,266,889 AGL Energy 9 941,852 1,037,500 Landfill Gas Industries 9 496,730 1,082,042 Veolia Environmental Services

7 801,346 1,810,051

Suez 2 191,407 336,498 Other 23 1,547,065 3,097,794 Total 101 14,407,482 20,401,080

Source: Clean Energy Regulator, ERF Project Register, 14 December 2017.

Around half of all registered projects (54 projects, or 51 per cent) generate electricity from landfill gas combustion17. Although relatively even in terms of number of projects, electricity generation projects provide 80 per cent of total abatement contracted under the method.

Finding 2: The landfill gas method has 101 registered projects. The Australian Government has entered into contracts with 87 projects to purchase Australian Carbon Credit Units (ACCUs) representing over 20 million tonnes of abatement. Crediting periods of 95 projects (94 per cent) expire during or after 2021. The Emissions Reduction Fund register shows 76 projects transitioned from the former Carbon Farming Initiative methods. Fifty of these projects had previously transitioned from the former NSW Greenhouse Gas Reduction Scheme (GGAS) or Greenhouse Friendly schemes into the former Carbon Farming Initiative.

The amount of gas captured on a site is largely a result of the nature of the waste deposited at the site, its geographic location and design, site management, infrastructure, and stage of development of a site. In a completed cell capped with a membrane or clay of sufficient thickness, a capture rate of over 90 per cent is possible18. Ordinarily, rates are significantly lower than this19.

The National Greenhouse and Energy Reporting Scheme (NGERS) allows a maximum reported capture of 75 per cent of all gas generated by the site. In 2013-14, eight sites reporting under NGERS reported the maximum allowable capture. Four of these sites did not have projects registered under the Carbon Farming Initiative, though all generated electricity from landfill gas. Maximising income from the sale of electricity may have provided the incentive for these projects to maximise their gas capture.

17 Data from the Clean Energy Regulator’s project and contract registers. 18 Barlaz, MA, JP Chanton and RB Green (2009). Controls on Landfill Gas Collection Efficiency: Instantaneous and Lifetime Performance, Journal of the Air and Waste Management Association, 59:12, 1399-1404. DOI: 10.3155/1047-3289.59.12.1399. 19 Powell, JT, TG Townsend and JB Zimmerman (2016). Estimates of solid waste disposal rates and reduction targets for landfill gas emissions. Nature Climate Change, Vol 6, 2016.

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A list of sites operating landfill gas projects during the Carbon Farming Initiative in 2013-14 was generated using a combination of NGERS data and the ERF project registry. Figure 7 shows the gas capture rates of 34 sites during the Carbon Farming Initiative period. Capture rates vary widely across the sites, though the data does not allow any conclusions to be drawn as to why.

Figure 7: Landfill gas capture rates of 34 sites participating in the Carbon Farming Initiative in 2013-14. Source: Department of the Environment and Energy (note: NGERS allows a maximum gas capture rate of 75 per cent). The available data suggest landfill gas capture and combustion is more prevalent at larger sites than small sites. As discussed, NGERS data indicate that more than 90 per cent of sites that received over 100,000 tonnes of waste in 2013-14 captured and destroyed methane. Landfills receiving less than 100,000 tonnes of waste in 2013-14 were less likely to have landfill gas capture and combustion systems. Only 58 per cent of smaller sites had these systems. The proportion of sites with landfill gas capture fell to 48 per cent when looking at sites that received less than 50,000 tonnes of waste. Figure 8 shows the percentage of gas captured within each landfill size category. NGERS data only captures sites emitting more than 25,000 tonnes of carbon dioxide equivalent per year. This result is consistent with a previous report based on Waste Management Association of Australia survey data (2008-2010), which found larger landfills are more likely to capture landfill gas than smaller landfills.20

20 Wright Corporate Strategy Pty Ltd, (2010), Review of the application of landfill standards.

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Figure 8: Gas capture within landfill size categories. Source: NGERS.

There are a number of reasons why large landfills are more likely to capture and combust landfill gas than small landfills, including:

• they have higher revenues from gate fees, which can be used to support investment in relevant infrastructure;

• larger landfills are generally closer to large population centres, hence more risk of odour concerns;

• they produce larger volumes of gas resulting in higher environmental and safety risks;

• larger volumes of gas, and a more consistent rate of gas supply, are ideal for generating electricity; and

• they are likely to have greater access to, and be able to more cost-effectively utilise, the skilled labour necessary to operate projects.

Smaller landfills are often council owned and operated, have limited staff, limited income and generate smaller volumes of methane. Smaller landfills are often located in rural or regional areas and are less likely to pose an odour risk to population centres. Such landfills are also more likely to face high grid connection fees due to distance from suitable infrastructure.

Views expressed in public submissions support this finding. Feedback generally indicated rural landfills do not have the capacity or financing to undertake landfill gas projects in the ordinary course of business. The eligibility to earn ACCU’s can therefore play a role in small rural landfills installing capture and combustion equipment. One confidential submission provided calculations which suggested extending the crediting period would make undertaking flaring projects on small to medium landfills viable.

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An analysis of the licence requirements across a number of landfills did not indicate larger, urban landfills were more likely to have a legal requirement to capture landfill gas and/or capture greater amounts of landfill gas than smaller, rural landfills. Public consultation also did not provide any insight on whether licence requirements differ between landfills of different size or proximity to population centres.

Finding 3: Despite increasing generation of methane from landfill, net emissions from the waste sector have decreased since 1990 largely as a result of landfill gas capture and combustion activities. Landfill gas capture is more prevalent at larger sites.

3.2 Drivers of landfill gas capture activities

There are three main potential drivers of landfill gas capture activities:

• state and territory waste regulations;

• reputational and social factors; and

• financial returns from the sale of tradeable permits (ACCUs and Large-scale Generation Certificates (LGCs)) and electricity.

These are discussed in turn below.

Finding 4: There are three main potential drivers of landfill gas capture activities: state and territory waste regulations; reputational and social factors; and financial returns from the sale of tradeable permits (ACCUs and Large-scale Generation Certificates (LGCs)) and electricity.

3.2.1 Regulatory requirements for landfill gas capture

3.2.1.1 States and territories are responsible for regulation of the waste industry

States and territories are responsible for the regulation of waste management facilities, including landfills. All states and territories maintain regulatory frameworks governing environmental and health impacts of waste management activities. The statutory basis of these frameworks is typically the jurisdiction’s environment protection legislation (or similar), with subordinate policy or regulatory instruments in force in some states (VIC, QLD, SA, TAS).

In addition to laws, the majority of jurisdictions have landfill guidelines (NSW, VIC, QLD, SA, TAS, NT) or are in the process of developing them (WA). ACT has adopted the Victorian guidelines, as they apply to monitoring. Individual landfill sites operate under site-specific licences or authorisations issued under the relevant legislation, and are subject to requirements in relevant legislative instruments and policy documents, including landfill guidelines.

3.2.1.2 State requirements vary

Statutory requirements for landfill operaters to capture and combust landfill gas are generally imposed via licence conditions and/or guidelines. The objects of these requirements is to address odour and safety concerns and in some cases, to abate greenhouse gas emissions.

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Current state and territory guidelines refer to limiting landfill gas emissions to within a specified range, however the range differs between jurisdictions. A summary of state and territory guidelines is provided at Appendix A.

All available guidelines specify allowable surface and/or subsurface methane concentrations for landfills. QLD, NSW, VIC, Tas and SA include minimisation of greenhouse gas emissions as an objective for landfill gas management. If the guidelines translated directly into practice on landfill sites it is likely some abatement of landfill gas would occur in the ordinary course of events.

In at least some cases, the environmental objectives of licences could be satisfied without the installation of a flare or other combustion device. For example, a landfill may find applying a cap of sufficient thickness to prevent migration of landfill gas to the surface satisfies the regulatory requirements.

An analysis of licence requirements found landfill gas management requirements varied between sites, with no discernible pattern based on the size or location of the landfill. Specific examples of licence requirements to combust landfill gas were found. One NSW landfill licence stated:

Except in emergency conditions or short periods of shutdowns the licensee must ensure that landfill gas generated by the disposal of waste and collected at the premises is treated by oxidation to carbon dioxide.

Similar examples were found in all states and territories.

Consultation with states and territories has shown some expectation landfill gas projects would continue in the absence of ACCUs. Victoria and Queensland provided the strongest view the regulatory framework would result in the capture and combustion of methane. Tasmania and New South Wales were of the view at least some landfills would continue to manage methane through flaring or electricity generation in the absence of ACCUs.

The ACT contains only one active landfill, Mugga Lane. Its 2011-2025 waste management strategy commits to ‘continue methane capture’ from the two ACT landfill sites. The authorisation does not contain a requirement to capture landfill gas but does require the Authorisation holder to monitor emissions in accordance with the Victorian landfill guidelines. The authorisation also requires the holder to undertake all practicable steps to minimise the impact of odour. The ACT government has recently released a request for tender for the capture and combustion of landfill gas from Mugga Lane. The initial term is for 15 years.

Feedback from waste industry representatives emphasised the variability of landfill licence requirements across the industry. Preventing odour impacting on sensitive receptors is often a licence requirement, though stakeholders emphasised a landfill may satisfy the requirements without installing a landfill gas collection system.

3.2.1.3 The method currently recognises regulatory requirements to capture gas

The method recognises licence requirements through the inclusion of a regulatory baseline. Proponents of the method are required to subtract at least 30 per cent of the abatement achieved by a project to represent the gas capture required by law. If a proponent is able to

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prove there are no legal obligations to capture landfill gas then this requirement may be waived.

There are 18 landfill gas projects with a zero per cent regulatory baseline:

• 16 projects transitioned from the Greenhouse Friendly program to the Carbon Farming Initiative; and

• two projects registered as new projects during the Carbon Farming Initiative.

The two projects registered as new during the Carbon Farming Initiative are located in Queensland and Western Australia. At the time of registration they were assessed as having no regulatory requirements to capture and combust landfill gas.

At present only Western Australian projects may be eligible for a zero per cent baseline because it is the only state without landfill guidelines. However, all new Western Australian projects registered under the ERF have a 30 per cent regulatory baseline. This indicates these projects have licence requirements requiring the management of landfill gas or odour.

3.2.1.4 Safeguard Mechanism

The ERF Safeguard Mechanism aims to prevent emissions reductions achieved under the Fund being offset by rising emissions in another part of the economy. Under the Safeguard Mechanism, landfills are issued with a baseline derived from their highest level of net emissions over the years 2009-10 to 2013-14. Safeguard provisions apply to large landfills whose emissions from waste deposited after 2017 exceed 100,000 tonnes CO2-e per year. These large landfills must ensure their net covered emissions do not exceed their baseline emissions over their monitoring period. If a large landfill did exceed its baseline, it may be required to surrender carbon credits to offset the excess emissions. To date, fourteen landfills have been issued baselines under the safeguard and none have been exceeded.

Finding 5: While most state regulations and guidance for landfills reference mitigation of greenhouse gases, they typically set standards for safety and odour management. Reflecting this, the regulations usually require landfill gas project operators to meet odour and safety standards rather than capture and combust defined quantities of landfill gas. The practical effect of the regulations is that landfill gas usually needs to be captured and combusted to some extent. However, the stringency of the regulatory requirements varies significantly between and within jurisdictions. The method accounts for the regulatory requirements by imposing a discount on calculated abatement. For new projects, the discount is the larger of a calculated amount based on the state and territory regulations that apply to the site or a default of 30 per cent of the methane destroyed in the combustion device, unless the proponent can establish the site is subject to no regulatory requirements (in which case the discount is zero). Different discounts are used for projects that transitioned from other schemes: a 24 per cent discount is applied to projects from the New South Wales Greenhouse Gas Abatement Scheme (NSW GGAS); and no discount is applied to projects from the Greenhouse Friendly program.

3.2.2 Reputation and social reasons to reduce emissions

The Committee considered the extent to which landfills and landfill gas operators would undertake emissions reduction activities on account of reputation and social factors. These

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reasons may include furthering corporate social responsibility goals or realising a reputational benefit.

Submissions from waste and landfill gas industry representatives generally stated non-financial benefits are not sufficient to outweigh the costs of undertaking a landfill gas project. For example, while the City of Armadale referred to its landfill gas project as, ‘a crucial initiative of the city’s corporate greenhouse action plan’21, it did not consider these reputational benefits to be sufficient to undertake emissions reduction activities in the absence of eligibility for ACCUs. In discussion, council landfill operators expressed uncertainty on whether the reputational benefits of a landfill gas project would be strong enough for constituents to be willing to pay more for their waste services. Several waste industry representatives also pointed out the availability of cheaper and more visible options for generating positive reputational benefits, such as installation of solar photovoltaics or energy efficient lighting.

Recent statements by policy leaders in Australia and globally have shown an increasing awareness of the importance of managing climate risk. Most state and territory governments have climate change strategies in place, and some have goals to reduce emissions. For example, Victoria and New South Wales are aiming for net zero emissions by 2050. These developments are likely to have implications for private landfill operators. In aiming for a zero emissions target a state may decide to restrict methane emissions from landfill—this is currently the case in the ACT. The prospect of future regulation or other statutory liabilities may prompt landfill gas operators to capture and combust landfill gas or increase the extent to which they are doing so. However, there is currently no evidence to suggest this potential background threat of regulation is a significant driver of capture and combustion activities at Australian landfills.

Finding 6: There are reputational and social factors that could potentially prompt landfill operators to reduce landfill gas emissions. However, there is no evidence to suggest these factors have had, or are likely to have, a material impact on operators’ decisions to establish or continue landfill gas capture and combustion activities.

3.2.3 Financial reasons to reduce emissions

In the absence of material social or reputational drivers, it appears the primary reasons operators undertake projects are regulatory and financial. Similarly, where landfill operators capture and combust more landfill gas than is necessary to satisfy regulatory requirements, it appears it is due to the financial incentives associated with the sale of ACCUs, LGCs and electricity. This is consistent with feedback received from industry representatives and the evidence provided by consultants. Data obtained from industry sources suggest the costs of, and revenue generated by, landfill gas projects differ significantly between projects. Projects that generate electricity have significantly higher capital costs but access significant sources of additional revenue compared to flaring-only projects. This suggests these projects should be considered separately when looking at the role the generation of ACCU’s plays in building a business case for gas capture and combustion beyond the ordinary course of business.

Landfill gas and waste industry representatives broadly agreed the real cost of landfill gas capture and combustion infrastructure had not decreased over time. Several representatives

21 10 July 2017, submission from City of Armadale

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reported costs increased in line with inflation and were subject to increasing costs of complying with more stringent health and safety regulations.

The gas generated at a landfill contains compounds damaging to infrastructure, leading to a need to replace equipment over time. Furthermore, operational landfills are constructed in cells which are generally filled one at a time. As landfilling moves to a new cell new landfill gas infrastructure is installed. This creates ongoing costs for landfill gas projects. Several proponents of flaring only projects stated they would cease to combust landfill gas and remove the flare at the end of the crediting period. Others said the maintenance regime required to keep the system running optimally would cease and landfill gas capture rates would fall after the end of the crediting period.

A financial analysis of flaring only projects, based on a small sample of small to medium sized operations, showed the relevant flaring projects relied on ACCUs to recoup project costs. Although a site may use gate fees to cover the costs of a flare, in the absence of ACCUs, it is unlikely a flaring project would continue to operate unless required to do so under legislation. The payback period for most of the sampled flaring projects extended beyond the current seven year crediting period (see Table 2). The analysis also found the net present value for most of the sampled flaring projects was negative, even with ACCUs.

Table 2 provides indicative values for the costs and revenue for landfill gas flaring and generation systems. The costs and revenues illustrate a flaring project equivalent to 1000 m3 per hour and an electricity generation project equivalent to 1.8 megawatts.

Table 2: Illustrative costs and revenues for a flaring and electricity generation project

Item Flaring Electricity generation Capital cost $875,500–$1,184,500 $3,595,500–$4,864,500 Annual operating and maintenance costs

$178,500–$241,500 $297,500–$402,500

Engine overhaul (annualised) N/A $221,000–$299,000 Non-ACCU revenue per year 0 $714,000–$966,000 ACCU revenue per year $297,500–$402,500 $467,500–$632,500 Payback period range (years) 6–13.5 2.5–6 Benefit cost ratio 0.98–1.32 1.28–1.73 Benefit cost ratio range 0.7–1.6 1.25–1.9

Source: Department analysis, RMCG 2017, SMEC 2017.

Projects that combust landfill gas using an internal combustion engine to generate electricity incur significantly higher capital costs than flaring-only projects, but also have access to additional revenue streams. The initial capital cost associated with landfill gas generators are approximately $2-2.5 million per megawatt. These capital costs are comparable to other electricity generation technologies. The available data also suggest landfill gas power generation is competitive with other generation technologies.22

The annual operation and maintenance costs of electricity generation projects are higher than for flaring-only projects. Much of the additional cost relates to maintenance of engines, which according to industry sources and technical experts, need to be overhauled every 4 to 8 years.

22 Clean Energy Finance Corporation (2015) The Australian bioenergy and energy from waste market.

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On the other hand, generating electricity provides additional revenue sources—the sale of electricity and credits through participation in the RET. Under the RET, registered suppliers are awarded a Large-scale Generation Certificate (LGC) for every megawatt hour of electricity produced. The supplier may then sell the certificates.

Analysis of a sample of electricity generation projects found ACCUs provided approximately 32–38 per cent of their revenues. This represents a significant proportion of project revenues and could be the deciding factor in a new project being developed.

The majority of industry representatives were of the opinion the crediting period should be extended for electricity generation activities. The arguments for extending the crediting period were the ongoing costs of operating a landfill gas generation system, and the uncertainty of future electricity and large-scale generation certificate prices. Some landfill gas operators claimed they were locked into power purchase agreements, and were not able to take advantage of higher spot prices in the electricity market.

Project data analysed by RMCG modelled the payback period for seven out of eight sampled electricity generation projects to be between 3–6 years. The analysis found extending the crediting period from seven to 14 years would not have a significant effect on the viability of existing generation projects. Both the financial analysis and the technical report found that new electricity generation projects would not be viable without the incentive of seven years crediting provided under the existing ERF method.

The financial assessment of projects found they are sensitive to the price of electricity and LGCs. Some industry representatives noted the price of certificates under the RET is expected to fall, which is likely to happen once the target is achieved (i.e. in or around 2020). However, there is considerable uncertainty in the energy market and it is unclear whether the emerging National Energy Guarantee may replace the RET as a source of income for electricity generation projects.

One submission received through the public consultation provided calculations suggesting the revenues generated under the RET and by selling electricity were sufficient for electricity generation activities to continue in the absence of the landfill gas method.

Finding 7: The primary reasons operators undertake projects are regulatory and financial. Capture and combustion of landfill gas beyond the levels required to meet state and territory regulations is driven largely by the financial returns associated with the sale of ACCUs, LGCs and electricity. The magnitude and timing of the revenues and expenses associated with landfill gas projects differs between the two eligible project types: flaring and electricity generation. The initial capital costs associated with installing a flare and the associated infrastructure are significantly less than those associated with an electricity generation project, as are the operating and maintenance costs. Both project types have to continually install new pipes and other infrastructure to capture landfill gas and transport it to the combustion device as new cells are created at landfills. Both flares and generators also require ongoing maintenance, much of which is attributable to the ‘dirty’ nature of landfill gas. However, unlike flares, electricity generators must undergo expensive overhauls every 4-8 years. While the costs associated with the installation and operation of electricity generation projects are substantially higher than those associated with flaring projects, so too are the revenues. Both types of projects receive revenue from the sale of ACCUs. However, unlike flaring projects,

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electricity generation projects receive revenue from the sale of electricity and LGCs issued under the Renewable Energy Target (RET).

Finding 8: Extending the crediting period for flaring projects is unlikely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events. The only source of revenue from the operation of flaring-only projects is the sale of ACCUs. The capture and combustion of landfill gas with flares involves ongoing capital expenditure for piping infrastructure, and maintenance and operational costs associated with the flares and associated equipment. For existing flaring projects, if they are no longer able to access and sell ACCUs, they are unlikely to be able to cover the costs associated with the operation of the project. As a consequence, in the absence of applicable regulatory obligations, the capture and combustion activities are likely to stop. The same applies to new project activities: extension of the crediting period is unlikely to result in the issuance of ACCUs for emissions reductions that would otherwise occur in the ordinary course of events.

Finding 9: Extending the crediting period for electricity generation projects is likely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events. For existing electricity generation projects, in most cases, the revenues from the sale of electricity and LGCs are likely to cover the ongoing capital, operational and maintenance costs of the projects, including engine refurbishment costs. Due to this, it is likely that, in most instances, existing electricity generation projects will continue in the absence of the incentive provided by the ERF. Similarly, the available evidence indicates the extension of the crediting period is unlikely to promote new electricity generation projects that would not have otherwise occurred. The Committee’s ability to reach definitive conclusions on these issues was affected by data limitations and uncertainties associated with policy settings and the electricity market. However, on the basis of the available information and having regard to the need for conservativism, the Committee concluded that extending the crediting period for electricity generation projects is likely to result in the issuance of ACCUs for emissions reductions that would occur in the ordinary course of events.

4 RECOMMENDATIONS

On the basis of the above, the Committee recommends:

• The crediting period for flaring-only projects should be extended by no more than five years. Any extension to the crediting period would be in addition to existing crediting periods, which typically run until 2021, but up to 2025 for some recently registered projects. There is a risk that extending crediting periods by more than five years would overlap with future regulations or other mandatory action.

• On balance, and having regard to the need for conservatism, the crediting period for electricity generation projects should not be extended. Extending the crediting period for electricity generation projects carries too great a risk of crediting abatement that is likely to occur in the ordinary course of events.

The Committee is aware that, if the crediting period is extended for flaring-only projects but not for electricity generation projects, it could potentially prompt proponents to switch between the project types. The Committee is also aware that not extending the crediting period for

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electricity generation projects could undermine the incentive for these projects to capture and combust ‘surplus methane’ (methane unable to be used for electricity generation) through the installation and operation of flares. These issues will be considered in the full review of the method. The Committee will also give further consideration in the full review to the application of the method to small and medium landfills.

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Appendix A: Summary of state and territory guideline objectives for landfill gas management.

State Date published

Objectives for landfill gas management Allowable methane levels

Queensland December 2013

• Ensure there are no adverse health, safety or environmental impacts due to landfill gas

• Minimise greenhouse gas emissions

• Surface levels: 500ppm

New South Wales

2016 • Minimise emissions of untreated landfill gas to air and through sub-surface strata and services


• Minimise emissions of offensive odour

• Minimise explosive risk to humans from gas build-up in confined spaces

• Ensure that, wherever feasible, landfill gas is sustainably utilised for energy recovery

• Minimise emissions of air pollutants from the combustion of landfill gas in flaring or electricity-generating equipment

• Surface levels: 500ppm

• Subsurface: 1% by volume

Victoria October 2014

• No health, safety or environmental impacts due to landfill gas and dust


• Prevention of offsite nuisance odours and dust

• Meet requirements of relevant waste management policies and plans

• Surface (capped): 100ppm

• Surface (covered): 200ppm


Tasmania 2004 • Landfill gas must not present a source of odour or an explosion or toxicity hazard

• The contribution to greenhouse gas emissions should be minimised

• Surface: 500ppm

• Subsurface: 1.25% by volume

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State Date published

Objectives for landfill gas management Allowable methane levels

South Australia

January 2007

• Prevention of adverse impacts from on-site and off-site migration and emissions of landfill gas

• Limitation of gas concentrations in monitoring bores at the boundary of the landfill facility or within structures located on or off site to less than 1% methane by volume or 1.5% carbon dioxide by volume

• Minimisation of greenhouse gas emissions as much as reasonably practicable

• Sustainable utilisation of landfill gas as much as reasonably practicable

• Management of potential hazards from asphyxiation or explosion in areas accessed by humans and in structures, equipment and other facilities

• Prevention of nuisance or offence from odorous emissions or dust.

• Management of airborne impurities, pathogens and toxins

• Monitoring of landfill gas migration and emissions and remediate emissions that pose a risk to the community or facilities.


Northern Territory

January 2013

No objectives for landfill gas Subsurface: 1% (5% if no nearby buildings

Western Australia

No guidelines

N/A N/A

Australian Capital Territory

No guidelines

N/A N/A

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Appendix B: List of registered landfill gas projects.

Project operator Project name Project ID number

Date registered

ACCUs total units issued

Contract number

Contracted abatement (tonnes CO2-e)

Loca-tion

Post- code

Type

LMS Energy Pty Ltd

Albury Landfill Gas Project

EOP100159 10/02/2013 122,270 CAC783640 1,568,376 NSW 2641 Transition

LMS Energy Pty Ltd

Awaba Landfill Gas Project

EOP100160 10/02/2013 122,918 CAC783640 See Albury Landfill Gas Project

NSW 2283 Transition

LMS Energy Pty Ltd

Ballarat Landfill Gas Project

EOP100161 10/02/2013 143,973 CAC362004 906,223 VIC 3351 Transition

Cleanaway Solid Waste Pty Ltd

Banksia Landfill Gas Abatement Project

EOP101222 16/07/2015 38,687 CAC163129 791,855 WA 6230 Transition

Kingborough Council

Barretta Landfill Gas Project

ERF101638 4/08/2015 0 n/a 0 TAS 7050 New

EDL LFG (ACT) Pty Ltd

Belconnen Landfill Gas Project

EOP100632 26/11/2012 64,115 n/a 0 ACT 2617 Transition

LMS Energy Pty Ltd

Bendigo Landfill Gas Project

EOP100187 11/04/2013 89,137 CAC362004 See Ballarat Landfill Gas Project

VIC 3550 Transition

LMS Energy Pty Ltd

Birkdale Landfill Gas Project


QLD 4159 Transition

LMS Energy Pty Ltd

Blaxland Landfill Gas Project

EOP101204 26/05/2015 21,435 CAC120527 180,000 NSW 2774 New

LMS Energy Pty Ltd

Bromelton Landfill Gas Project

EOP101206 26/05/2015 15,299 CAC120527 See Blaxland Landfill Gas Project

QLD 4285 New

EDL LFG (VIC) Pty Ltd

Brooklyn Landfill Gas Project

EOP100099 20/12/2012 198,253 CAC405488 913,546 VIC 3012 Transition

Eurobodalla Shire Council and Mike Ritchie and Associates Pty Ltd

Brou Landfill Gas Capture and Combustion Project

ERF102915 12/04/2016 0 n/a 0 NSW 2545 New

EDL LFG (QLD) Pty Ltd

Browns Plains Landfill Gas Project

EOP100191 12/04/2013 52,106 CAC403360 947,569 QLD 4118 Upgrade

LMS Energy Pty Ltd

Buderim Landfill Gas Project

EOP100101 17/08/2012 52,131 CAC164941 385,393 QLD 4556 Transition

Moreton Bay Regional Council

Bunya Landfill Gas Project



Caboolture Landfill Gas Project

ERF101486 16/07/2015 39,424 CAC752641 See Bunya Landfill Gas Project

QLD 4051 Transition

LMS Energy Pty Ltd

Caloundra Landfill Gas Project


COUNCIL OF THE CITY OF SHELLHARBOUR

Capture and Combustion of Landfill Gas at Dunmore Recycling and Waste Disposal Depot, Shellharbour City Council

EOP100503 11/02/2014 35,717 CAC742375 80,114 NSW 2529 Transition

Landfill Gas Industries Pty Ltd

Capture and Combustion of Landfill Gas from Benaraby Landfill Project



Capture and Combustion of Landfill Gas from Saltwater Creek Landfill, Maryborough, QLD

EOP100516 29/01/2014 65,907 CAC342427 See Benaraby Landfill Project

QLD 4650 Transition


Capture and Combustion of Landfill Gas from Willawong Landfill Project

EOP100180 22/03/2013 210,901 CAC342427 See Benaraby Landfill Project

QLD 4100 Transition


Cedars Road Landfill Gas Extraction and Combustion


LMS Energy Pty Ltd

Cessnock Landfill Gas Project

EOP100648 9/12/2013 34,006 CAC164941 See Buderim Landfill Gas Project

NSW 2325 Transition

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Date registered


Contract number


Loca-tion

Post- code

Type

City of Armadale City of Armadale Landfill Gas Flaring Project


LMS Energy Pty Ltd

Copping Landfill Gas Project


TAS 7174 Transition


Dakabin Landfill Gas Project

EOP100504 4/07/2014 97,414 CAC752641 See Bunya Landfill Gas Project

QLD 4503 Transition

LMS Energy Pty Ltd

Darwin Landfill Gas Project


NT 0812 Transition

LMS Energy Pty Ltd

Drysdale Landfill Gas Project


VIC 3222 Transition

LMS Energy Pty Ltd

Dulverton Landfill Gas Project

EOP101207 4/06/2015 9,351 CAC120527 See Blaxland Landfill Gas Project

TAS 7307 New

LMS Energy Pty Ltd

Eastern Creek 2 Landfill Gas Project

EOP100163 10/02/2013 823,449 CAC143500 3,526,278 NSW 2766 Transition

EDL LFG (NSW) Pty Ltd

Eastern Creek Landfill Gas Project

EOP100103 13/11/2012 197,722 CAC405488 See Brooklyn Landfill Gas Project

NSW 2766 Transition

Enviroguard Pty Limited

Erskine Park Landfill Gas Project


Tamworth Regional Council

Forest Road Landfill Gas Project

ERF103371 6/04/2016 0 CAC781171 120,000 NSW 2340 New

AGL Energy Services Pty Ltd

Glenorchy Landfill Gas Abatement Facility

EOP100247 14/08/2013 145,937 CAC198503 179,000 TAS 7010 Transition


Gosnells Landfill Gas Abatement Facility


Clarence Valley Council

Grafton Regional Landfill landfill gas capture and combustion project



Grange Avenue Landfill Gas Project

EOP100629 1/11/2012 87,568 CAC403360 See Brown's Plains Landfill Gas Project

NSW 2765 Transition

Bass Coast Shire Council

Grantville Landfill Gas Capture and Combustion Project

ERF103347 15/04/2016 0 CAC475741 44,540 VIC 3990 New


Greenpoint Landfill Gas Abatement Facility

EOP100502 26/08/2013 38,083 n/a 0 NSW 2251 Transition


Gympie Landfill Gas Project

ERF118292 20/11/2017 0 CAC495317 41,000 QLD 4570 New

LMS Energy Pty Ltd

Hallam Landfill Gas Project

EOP100093 27/11/2012 975,003 CAC143500 See Eastern Creek VIC 3976 Transition


Hawkesbury Landfill Gas Project

ERF101539 18/08/2015 16,580 CAC102423 47,400 NSW 2756 Upgrade


Hervey Bay Landfill Gas Project

EOP101085 26/05/2015 7,296 CAC102350 128,800 QLD 4655 New

LMS Energy Pty Ltd

Hervey Range Landfill Gas Project

EOP101208 27/05/2015 0 CAC668305 See Caloundra Landfill Gas Project

QLD 4817 New


Hobart McRobies Gully Landfill Gas Abatement Facility

EOP100250 14/08/2013 86,268 CAC354956 89,000 TAS 7004 Transition

Veolia Environmental Services (Australia) Pty Ltd

Horsley Park Landfill Gas Project


Latrobe City Council

Hyland Highway Landfill Gas System Upgrade (Stage 1)

ERF116688 20/11/2017 0 n/a 0 VIC 3844 Upgrade

Waste Management Pacific (S.A.) Pty Limited

Inkerman Landfill Gas Abatement Project

EOP101224 20/07/2015 66,789 CAC107173 411,514 SA 5550 Transition

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Date registered


Contract number


Loca-tion

Post- code

Type

Veolia Environmental Services (Australia) Pty Ltd and Acquista Investments Pty Ltd as the Trustee for Borrelli Family Trust

Integrated Waste Services - LFG Project

ERF111304 23/03/2017 0 CAC548746 350,000 SA 5501 New

LMS Energy Pty Ltd

Ipswich Landfill Gas Project


QLD 4303 Transition


Jacks Gully Landfill Gas Project

EOP100059 13/11/2012 183,042 CAC405488 See Brooklyn Landfill Gas Project

NSW 2570 Transition

Kimbriki Environmental Enterprises Pty Ltd

Kimbriki LFG flare project

ERF101977 30/09/2015 15,919 CAC101989 79,000 NSW 2084 New


Kincumber Landfill Gas Abatement Facility


Rockhampton Regional Council

Lakes Creek Road Landfill Gas Project

ERF106224 9/12/2016 0 n/a 0 QLD 4701 New


Lucas Heights 2 Landfill Gas Project

EOP100105 12/12/2012 1,139,801 CAC781436 1,405,774 NSW 2234 Transition


Lucas Heights 2B Landfill Gas Project


NSW 2234 Transition

LMS Energy Pty Ltd

Maitland Landfill Gas Project


NSW 2323 Transition

BLACKTOWN WASTE SERVICES PTY LIMITED

Marsden Park Landfill Gas Capture and Combustion Project

ERF101986 24/09/2015 0 n/a 0 NSW 2765 New

LMS Energy Pty Ltd

Mirabooka Landfill Gas Project


WA 6062 Transition

LMS Energy Pty Ltd

Molendinar Landfill Gas Project


LMS Energy Pty Ltd

Mornington Landfill Gas Project


VIC 3941 Transition

Mike Ritchie and Associates Pty Ltd

MRA Aggregated Landfill Gas projects

ERF103411 11/04/2016 0 CAC657049 56,500 Nation-wide

n/a New

Landfill Operations Pty Ltd

MRL LFG Abatement Project

EOP100096 16/01/2013 933,074 CAC662701 494858 VIC 3029 Transition

EDL LFG (ACT) Pty Ltd

Mugga Lane Landfill Gas Project

EOP100107 26/11/2012 393,248 n/a 0 ACT 2620 Transition

LMS Energy Pty Ltd

Nambour Landfill Gas Project

EOP100658 13/12/2013 43,464 CAC668305 See Caloundra Landfill Gas Project

QLD 4560 Transition

LMS Energy Pty Ltd

NAWMA Landfill Gas Project


SA 5114 Transition

LMS Energy Pty Ltd

Newcastle Landfill Gas Project


NSW 2287 Transition

Suez Recycling & Recovery Holdings Pty Limited

Newline Road Landfill Gas Capture and Combustion Project

ERF101696 4/08/2015 9,175 n/a 0 NSW 2324 Transition

LMS Energy Pty Ltd

Noosa Landfill Gas Project

EOP100656 9/12/2013 39,035 CAC668305 See Caloundra Landfill Gas Project

QLD 4562 Transition

LMS Energy Pty Ltd

Pedler Creek Landfill Gas Upgrade Project

ERF109627 14/02/2017 0 n/a 0 SA 5169 Upgrade

Port Macquarie Hastings Council

Port Macquarie-Hastings Council Cairncross Waste Management Facility Landfill Gas Project

ERF103826 7/07/2016 0 n/a 0 NSW 2446 New

LMS Energy Pty Ltd

Reedy Creek Landfill Gas Project

EOP101202 3/07/2015 19,876 CAC873169 See Molendinar Landfill Gas Project

QLD 4220 Upgrade

LMS Energy Pty Ltd

Remount Landfill Gas Project


TAS 7250 Transition

LMS Energy Pty Ltd

Rochedale Landfill Gas Project

EOP100183 22/03/2013 541,269 CAC783510 2,008,305 QLD 4123 Transition

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Date registered


Contract number


Loca-tion

Post- code

Type


Rockingham Landfill Gas Abatement Facility


EDL LFG (QLD) Pty Ltd

Roghan Road Landfill Gas Project


QLD 4018 Transition

LMS Energy Pty Ltd

Shepparton Landfill Gas Project


VIC 3631 Transition


Shoalhaven Landfill Gas Abatement Facility

EOP100245 14/08/2013 76,131 n/a 0 NSW 2540 Transition

Suez Recycling & Recovery Holdings Pty Limited

SITA Elizabeth Drive Landfill Gas Capture (flaring & electricity generation) - Kemps Creek project


LMS Energy Pty Ltd

South Cardup Landfill Gas Project

EOP100109 17/08/2012 750,945 CAC143500 See Eastern Creek WA 6122 Transition

LMS Energy Pty Ltd

Southern Waste Landfill Gas Upgrade Project

ERF111111 15/02/2017 0 n/a 0 SA 5170 Upgrade

LMS Energy Pty Ltd

Stapylton Landfill Gas Project

EOP100540 21/07/2014 128,074 CAC873169 See Molendinar Landfill Gas Project

QLD 4207 Transition

LMS Energy Pty Ltd

Stuart Landfill Gas Project


QLD 4811 Transition

LMS Energy Pty Ltd

Suntown Landfill Gas Project


LMS Energy Pty Ltd

Swanbank Landfill Gas Project

EOP100172 1/03/2013 485,932 CAC143500 See Eastern Creek QLD 4306 Transition

Coffs Harbour City Council

The Coffs Harbour City Council Landfill Legacy Emissions Avoidance Project



Ti Tree Energy Generation Project

ERF101356 3/07/2015 56,903 CAC102353 570,051 QLD 4306 Transition


Ti Tree Gas to Energy Project

EOP100559 12/11/2012 99,429 CAC254087 See Horsley Park Landfill Gas Project

QLD 4305 Transition

Toowoomba Regional Council

Toowoomba Waste Management Centre – Landfill Gas Project

ERF118305 17/11/2017 0 CAC171002 198,611 QLD 4350 New

LMS Energy Pty Ltd

Tweed Landfill Gas Project


NSW 2487 Transition


University Drive Landfill Gas Project

EOP101084 19/03/2015 25,787 CAC102350 See Hervey Bay Landfill Gas Project

QLD 4670 New


Wagga Landfill Gas Abatement Facility



Wattle Glen Landfill Gas Project


QLD 4304 Transition


Whylandra Waste and Recycling Centre Landfill Gas Project

EOP100510 24/04/2014 54,850 CAC333101 See Cedars Road Landfill Gas Extraction and Combustion

NSW 2830 Transition

Wollongong City Council

Whytes Gully Landfill Gas Project

ERF111278 7/03/2017 0 n/a 0 NSW 2526 Upgrade

LMS Energy Pty Ltd

Wollert Landfill Gas Project

EOP100098 30/11/2012 802,825 CAC783510 See Rochedale Landfill Gas Project

VIC 3750 Transition


Woodlawn Bioreactor Project


NSW 2580 Transition

29


Date registered


Contract number


Loca-tion

Post- code

Type

Veolia Environmental Services (Australia) Pty Ltd and EnergyAustralia Pty Ltd

Woodlawn Energy Generation Project

ERF101358 16/07/2015 87,731 CAC102472 560,000 NSW 2580 Transition


Woy Woy Landfill Gas Abatement Facility


LMS Energy Pty Ltd

Wyndham Landfill Gas Project

EOP100168 10/02/2013 296,500 CAC783510 See Rochedale Landfill Gas Project

VIC 3030 Transition

LMS Energy Pty Ltd

Wyong Landfill Gas Project


NSW 2259 Transition

erac - landfill gas method crediting period review report · • a financial assessment of landfill...

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