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Consultation on draft Climate Change (Waste) Regulations 2010 and amendments to the Climate Change (Unique Emissions Factors) Regulations

The Ministry for the Environment is now consulting on draft regulations for reporting landfill methane emissions under the NZ Emissions Trading Scheme (NZ ETS).

This factsheet is intended to guide waste disposal facility (landfill) operators and other interested parties in making a submission in response to the draft regulations.

The consultation period on the proposed regulations is from 21 June to 23 July 2010.

This factsheet contains information on:

Emissions Trading Scheme requirements for Waste Disposal Facility Operators
making a submission
the regulations
the approach to emissions calculation and reporting
- basic reporting and default methodology
- non-default waste composition
- methane collection and destruction
- non-default waste composition and methane destruction on the same site
matters for future consideration.

Requirements for Waste Disposal Facility Operators

The New Zealand Emissions Trading Scheme (NZ ETS) requires Waste Disposal Facility Operators (DFOs) to:

collect and report information about their methane emissions from 1 January 2012, and
surrender New Zealand Units (NZUs) to cover these emissions from 1 January 2013.

DFOs may voluntarily register as participants, and submit emissions returns, from 1 January 2011 to 31 December 2011. The Ministry for the Environment intends to have the necessary regulations in effect by 1 January 2011, so DFOs wishing to test their procedures by voluntarily reporting from this date can do so.

Making a submission

The purpose of consultation on these draft regulations is to ensure the final version is practical, understandable, and cost effective for the organisations that need to comply. We are seeking feedback on:

the workability of the methods used
any issues around collecting the necessary data.

Written submissions are welcome and should be sent to: emissionstrading@mfe.govt.nz or sent in hard copy to Emissions Trading, Ministry for the Environment, PO Box 10362, Wellington, New Zealand.

Submissions close on Friday 23 July at 5:00pm.

The draft regulations are available at www.climatechange.govt.nz/ets/participating/waste. Hard copies are available from the Ministry for the Environment, 23 Kate Sheppard Place, Wellington. Copies of the Solid Waste Analysis Protocol and the IPCC Waste Model can also be made available if required.

For further information, go to www.climatechange.govt.nz, or call 0800 Climate (0800 254 628) or email emissionstrading@mfe.govt.nz

About the regulations

The methodologies used have been recommended by the Waste Technical Advisory Group (TAG) in its report of March 2010. In addition, Tonkin & Taylor Ltd has provided advice to develop the TAG’s recommendations into the usable calculation method incorporated in the draft regulations. The Tonkin & Taylor and TAG reports are available at www.climatechange.govt.nz/ets/participating/waste.

The regulations are in two parts:

the Climate Change (Waste) Regulations 2010, and
the amended Climate Change (Unique Emissions Factors) Regulations.

Climate Change (Waste) Regulations 2010

The Climate Change (Waste) Regulations 2010 establish the basics of emissions reporting and provide a simple default methodology for the use of DFOs who may operate smaller facilities, and prefer a straightforward reporting method. This option will allow them to base their reporting on information that already has to be collected for calculation of the Waste Disposal Levy. No additional data collection will be needed to comply with these Regulations.

Climate Change (Unique Emissions Factors) Regulations

The amended Climate Change (Unique Emissions Factors) Regulations provide options for DFOs to use more complex methodologies which account for parameters that the default methodology assumes to be standardised. These are:

The composition of the waste disposed, if this is shown to be different from the default assumptions.
The capture and destruction of methane, by flaring or for energy production.
Both non-default waste composition and methane capture at the same facility.

DFOs wishing to use a non-default methodology will need to apply for approval to use a Unique Emissions Factor (UEF) incorporating the relevant composition data, destruction rate, or both. The requirements for making an application are in the draft regulations.

Approach to emissions calculation and reporting

When waste is disposed into a landfill, it emits methane over a period of several years to several decades. The National Greenhouse Gas Inventory, and New Zealand’s Kyoto Protocol obligations, are based on emissions as they actually occur from year to year. However, following the TAG’s recommendations, these regulations are based on a ‘mass balance’ methodology, where emissions are attributed to waste when it is disposed. The total amount of methane that a tonne of waste is expected to emit will be reported in the year in which that tonne is placed in a landfill.

This means that, on average, emissions will be reported some years before they actually occur. The cost of meeting obligations based on those emissions will be also brought forward in time. On the other hand, there will be no reporting or surrender obligations for any landfill after it has been closed. Legacy emissions from closed landfills will be kept out of the NZ ETS although they form part of New Zealand’s international obligations.

The TAG recommended the use of a mass balance methodology because:

passing costs on to landfill users will be easier as the cost is transparent at the time the waste is disposed
compliance will be simpler because it minimises the need for analysis to determine emissions over time
it is only necessary to report on a landfill while it is actively receiving waste.

Basic reporting and default methodology

The draft Climate Change (Waste) Regulations specify that the net tonnage of waste disposed in a year must be collected and recorded. This is the same information that has to be reported under the Waste Minimisation (Calculation and Payment of Waste Disposal Levy) Regulations 2009. The only difference is that a calendar year is used for all NZ ETS purposes, unlike the Waste Levy which uses financial years.

The methane emissions for a reporting year will be calculated as:

E = EF × A

Where E is the emissions for the year in tonnes of CO₂-equivalent (tCO₂e)

EF is the applicable emissions factor, whether the default factor below or a UEF

A is the net tonnage disposed in the year

If the DFO chooses to use the default methodology, the emissions are simply calculated as:

E = 1.1454 × A

The default emissions factor of 1.1454 tCO₂e per tonne of waste is the net result of applying default values for a number of factors – the details of the defaults are in the Tonkin & Taylor Ltd report. These default assumptions are consistent with those applied in reporting New Zealand’s waste sector emissions internationally in the National Greenhouse Gas Inventory.

Non-default waste composition

The composition of waste going into a landfill affects the amount of methane it’s likely to generate. The crucial factor is the proportion of degradable organic carbon (DOC) in the waste; the above default emission factor incorporates a DOC fraction of 0.1818.

A DFO can apply for approval to use a set of UEFs for non-default waste composition, based on sampling and reporting of the waste entering the facility. In this context, composition refers to the proportions of the defined components of waste listed below. These include food, garden waste, paper, and textiles.

The general procedure to estimate the composition of waste entering a landfill is that described in the Solid Waste Analysis Protocol (“SWAP” – available at www.mfe.govt.nz/publications/waste/solid-waste-analysis-mar02/index.html) Procedure 2. Using these sampling and sorting procedures, the waste needs to be classified by source and by its components. The categories to be used are listed below.

Waste sources:

Municipal solid waste (MSW)
Commercial and Industrial (C&I)
Building and Demolition (B&D)
Other sources (OTHER).

Within one or more of these source categories, the waste has to be analysed to determine the fractions of the following waste components:

Food waste (FW)
Garden waste (GW)
Paper (PW)
Wood (WW)
Textiles (TW)
Nappies (NW)
Sewage sludge (SW)
Other components.

This sampling and analysis needs to be carried out for a year’s waste received at the facility. The data for this base year may be used to support an application to use UEFs for the facility in reporting current and future disposal. A separate UEF will be used for each source category for which analysis has been done. Each of these four UEFs is calculated from the sampling and analysis data as:

UEF = (0.945 × FW) + (1.260 × GW) + (2.520 × PW) + (2.709 × WW) + (1.512 × TW) + (1.512 × NW) + (0.315 × SW)

Where UEF is the Unique Emissions Factor

Only components to are included in this calculation – any ‘other components’ fraction found in the sorting and analysis is assumed to have zero DOC.

In subsequent years the DFO will need to monitor the amount of waste disposed by source. The emissions reporting from year to year will reflect changes in the proportions of the four source categories. Emissions in each reporting year are calculated as:

E = (EF_MSW × A_MSW) + (EF_C&I × A_C&I) + (EF_B&D × A_B&D) + (EF_OTHER × A_OTHER)

Where E is the emissions in tCO₂e for the year EF_<waste source_> is the UEF approved for that source category at the facility, or the DEF if no UEF has been approved

A _<waste source> is the net tonnes of waste for that source category disposed in the year.

If the composition of the waste being received, within a source category, changes significantly the DFO will need to:

repeat the SWAP analysis, and
apply for a new UEF covering that source category.

For instance, this might happen if a change in the collection area served by the landfill means that the proportion of garden waste in the MSW received at the site changes.

Methane collection and destruction

DFOs that collect and destroy methane, by flaring it or by using it for energy production, need a methodology to report only the net amount that is actually emitted. Any DFO carrying out methane destruction will be able to apply for a UEF that takes this into account.

The efficiency of methane collection varies from one site to another, depending on the coverage achieved by the collection system and the efficiency of the collection wells. In addition, the destruction equipment used may not achieve 100 per cent combustion of the methane. The methodology used in these draft regulations for methane destruction is based on:

Monitoring the amount of gas collected and passed to the destruction equipment, and the concentration of methane in it, for a period of one year.
Estimating the gross amount of methane that the landfill is expected to generate in the same year. This requires data on the waste disposal history of the site, and application of a first-order decay (FOD) model to estimate the rate of methane generation from the waste now in the landfill.

The amount of gas sent to the destruction equipment will need to be determined by direct metering of the gas flows, with sampling and analysis to determine the methane concentration. It is expected that landfills carrying out methane destruction will have continuous metering equipment in place.

The IPCC Waste Model (available in spreadsheet form at www.ipcc-nggip.iges.or.jp/public/2006gl/vol5.html) is recommended for calculating the gross methane generation. Alternative models may be used, provided the input parameters are set to the required default values. These defaults are given in the Tonkin & Taylor Ltd report.

The UEF is calculated as:

EF = 1.1454 × (1 – C)

Where C is the efficiency of methane collection and destruction, calculated as:

C = D × Q/G

Where D is the destruction factor for the type of destruction equipment used

Q is the metered quantity of methane sent to the destruction equipment (tonnes)

G is the estimated gross methane generation (tonnes).

The IPCC model requires methane quantities to be entered in tonnes. If alternative models are used, it is likely that quantities of methane in m³ (at normal temperature and pressure) may be required in the model. When a conversion is required, users must assume a density of 0.668 kg/m³ for methane.

Once a UEF for methane destruction is approved, the DFO will use it for reporting their emissions for each year. They must also update the landfill gas generation model each year to reflect changes as more waste is added. When there is a material change in the collection and destruction efficiency (C) it will be the DFO’s responsibility to reapply for a new UEF reflecting the change that has taken place.

A default destruction efficiency (D) is given for each type of equipment used (open flares, enclosed flares, and gas engines or turbines). If documented manufacturer’s data is available, confirming that the actual destruction rate can be expected to be higher than the default, this may be used.

Non-default waste composition and methane destruction on the same site

It is likely that a number of DFOs will wish to apply for UEFs covering both non-default waste composition and methane collection and destruction. In this case a UEF must be approved for each of the four waste sources. The UEF for each source category will be calculated as:

EF = [(0.945 × FW) + (1.260 × GW) + (2.520 × PW) + (2.709 × WW) + (1.512 × TW) + (1.512 × NW) + (0.315 × SW)] × (1 – C)

Total emissions for each reporting year are calculated as:

E = (EF_MSW × A_MSW) + (EF_C&I × A_C&I) + (EF_B&D × A_B&D) + (EF_OTHER × A_OTHER)

Where E is the emissions in tCO₂e for the year

EF_<waste source_> is the UEF approved for that source category at the facility, or the DEF if no UEF has been approved

A_<waste source> is the net tonnes of waste for that source category disposed in the year.

The DFO will need to update their landfill gas generation modelling, and apply for a new UEF as necessary, in the same way as for the two individual UEF options.

Matters for future consideration

These draft regulations are intended primarily to meet the needs of voluntary reporting from next year, while being robust enough to ensure that the basic methodology and data requirements are not expected to change when reporting becomes mandatory. Some issues that the TAG discussed, but did not fully resolve, have been left for future consideration and possible amendments. These are the oxidation factor and possible direct measurement of methane emissions.

The proposed methods incorporate an oxidation factor of 10 per cent, that is, the assumption that 10 per cent of methane that enters the landfill cap material is oxidised to CO₂ before being emitted. This follows the current approach to reporting landfill emissions in greenhouse inventories in New Zealand and elsewhere. It is now considered likely to be conservative, but is retained in these draft regulations in the absence of standards that specify a measurement method.

Direct measurement of the methane leaving the surface of the landfill is a possible alternative method, which would avoid the need to explicitly account for the waste composition. Application of this method will require advances in measurement and analysis. Also, it would be more appropriate in combination with an approach in which the actual emissions over time are reported, rather than the ‘mass balance’ approach actually adopted.