Submission Template: Emissions Reduction Fund draft method determinationCarbon Credits (Carbon Farming Initiative) Methodology (Landfill Gas) Determination 2014OverviewThis submission template should be used to provide comments on a draft Emissions Reduction Fund method determination.

Contact DetailsName of Organisation: Greenhousegas Consulting ServicesName of Author: Ron WitneyPhone Number: 0409 517 960Email: rwitney@ghgcs.com.auWebsite: Date:

Confidentiality All submissions will be treated as public documents, unless the author of the submission has requested that the submission not be published on the grounds that its publication could reasonably be expected to substantially prejudice the commercial interests of the author or another person. Public submissions will be published in full on the Department of the Environment’s website, including any personal information of authors and/or other third parties contained in the submission. If any part of the submission should be treated as confidential then please provide two versions of the submission, one with the confidential information removed for publication.

A request made under the Freedom of Information Act 1982 for access to a submission marked confidential will be determined in accordance with that Act.

Do you want this submission to be treated as confidential? Yes x No

Submission InstructionsSubmissions should be made by close of business on the day the public consultation period closes for the draft method determination. This date will be specified on the Department’s website: www.environment.gov.au. The Department reserves the right not to consider late submissions.

Where possible, submissions should be lodged electronically, preferably in Microsoft Word or other text based formats, via the email address – EmissionsReductionSubmissions@environment.gov.au

Submissions may alternatively be sent to the postal address below to arrive by the due date.

ERF Governance, ERF DivisionDepartment of the Environment GPO Box 787 CANBERRA ACT 2601

Name of draft method determination: Carbon Credits (Carbon Farming Initiative) Methodology (Landfill Gas) Determination 2014

General commentsWe see the draft Carbon Credits (Carbon Farming Initiative) Methodology (Landfill Gas) Determination 2014 (Draft Method Determination) as an improvement over the existing methodology determinations.

We have the following general comments.

Volume of landfill gas measurement.

There are no requirements for the gas measuring equipment other then the full range accuracy of the Pressure, Diff. pressure and Temperature devices.

Section 29 (1) item 3 of the Draft Method Determination requires the volume of landfill gas to be estimated under Division 2.3.6 of the NGER (Measurement) Determination.

The volumetric measurement of landfill gas does not involve commercial transaction and is a direct measurement so criterion AAA, section 2.31 of the NGER (Measurement) Determination, should apply otherwise criterion BBB, Section 2.38, will apply.

Landfill gas is a gas other than a super compressed gas so section 2.31 (2) (a) (i) of the NGER (Measurement) Determination applies which requires the quantities of gas measured using volumetric measurement in accordance with section 2.32 of the NGER (Measurement) Determination.

Section 2.31 (b) of the NGER (Measurement) Determination requires the quantities of gas be measured using gas measuring equipment that complies with section 2.34 of the NGER (Measurement) Determination

As the Maximum daily quantity of gas combusted is less than 3,501 GJ/day (approximately 8,000 m3/h of landfill gas) the measurement must be carried out at the point of combustion using gas measuring equipment that has a gas measuring equipment category of 1 or 2 as given in the table in 2.31 (4) which have the following transmitter and accuracy requirements (% of range):

Pressure <±0.25%;Diff. pressure <±0.25%;Temperature <±0.50%.

Section 2.32 of the NGER (Measurement) Determination is for volumetric measurement—all natural gases and it is questionable whether this applies to a biogas given that a definition of natural gas is a substance that has been injected into a natural gas supply pipeline.

Section 2.34 of the NGER (Measurement) Determination only requires that gas measuring equipment that is category 3 or 4 equipment in accordance with column 2 of the table in section 2.31 must comply with the following requirements. This section does not apply as landfill gas measurement equipment has a gas measuring equipment category of 1 or 2.

Section 2.38, Simplified consumption measurements—criterion BBB, does not refer to volume measurement of landfill gas.

Other then the accuracy of the Pressure, Diff. pressure and Temperature devices, there are no requirements for the gas measuring equipment.

2

Uncertainty limit on the abatement

There is no uncertainty limit for the abatement in the Draft Method Determination.

Section 29 (1) item 3 of the Draft Method Determination refers to Division 2.3.6 of the NGER (Measurement) Determination which gives the following accuracy requirements for the devices measuring the Landfill gas sent to combustion device.

The accuracy of static pressure device is not greater than ±0.25% of range The accuracy of differential pressure device is not greater than ±0.25% of range The accuracy of temperature device is not greater than ±0.50% of range

The accuracy limits given above is the accuracy based on the measurement range of the device not the measured value. This is a common method of defining the uncertainty of measurement devices.

Where a measurement device’s accuracy is based on a percentage of its range (or full reading capability), the error is a fixed value. For example; an accuracy of ±0.25% of full range of 600 m3/h is ±1.5 m3/h. This is the accuracy all the time so as the measured value is reduced from the full range the ±1.5 m3/h accuracy becomes a much larger percentage of the measured value. At 50 m3/h the accuracy would be ±3% of the measured flow.

Division 2.3.6 of the NGER (Measurement) Determination therefore does not define an uncertainty limit for the landfill gas flow.

There is also no uncertainty defined for the measurement of the methane content of the landfill gas.

Section 29 (1) item 5 of the Draft Method Determination references to in Division 2.3.6 of the NGER (Measurement) Determination. As discussed above, Section 2.34 of the NGER (Measurement) Determination only requires that gas measuring equipment for category 3 or 4. No uncertainty requirement is defined for the landfill gas methane content that has an equipment category of 1 or 2.

A maximum uncertainty for the abatement should be defined in the Method Determination.

The fraction of the volume of landfill gas that is methane

No requirement for the measurement of landfill gas methane content.

Section 29 (1) item 5 of the Draft Method Determination requires the fraction of the volume of landfill gas that is methane to be estimated under Division 2.3.6 of the NGER (Measurement) Determination. As discussed above, landfill gas measurement equipment has a gas measuring equipment category of 1 or 2 and Division 2.3.6 of the NGER (Measurement) Determination does not apply.

No requirement Draft Method Determination defined for the measurement of landfill gas methane content.

There should be an uncertainty for the fraction of methane. There should also be a requirement that the methane content in landfill gas should be measured at the same humidity as used to determine the Landfill gas sent to combustion device.

3

Nitrous oxide emissions released from combustion devices (Ecom)

Equation 12 of the Draft Method DeterminationThe nitrous oxide emission released from combustion devices (Ecom) determined in equation 12 of the Draft Method Determination includes the nitrous oxide released due to the methane that would have been combusted without the project. This Nitrous oxide emission due to the methane that would have been combusted without the project should not be included in the project.

The following equation should be used to give the nitrous oxide emission released from combustion device due to the methane that has been combusted with the project.

If equation 7 of section 19 (3) of the Draft Method Determination applies, then the following equation should be used to give the nitrous oxide emission released from combustion device due to the methane that has been combusted with the project.

The equivalent carbon dioxide produced by the nitrous oxide emissions is clearly trivial

The factor converting cubic metres of methane at standard conditions to CO2 e tonnes is 6.784 × 10 4 × 21 = 0.0142464 t CO2-e/m3.

The emission factor for nitrous oxide (N2O) from landfill biogas that is captured for combustion is 0.03 kg CO2 e/GJ and the energy content factor of methane is 0.0377 GJ/m3. The equivalent carbon dioxide produced by the combustion of cubic metres of methane generating nitrous oxide is therefore 0.001131 kg CO2-e/m3 or 0.000001131 t CO2-e/m3.

The equivalent carbon dioxide produced by the nitrous oxide emissions released from combustion devices (Ecom) is approximately 0.008% of the abatement and is clearly trivial. The determination of the abatement can be simplified by not including the nitrous oxide emissions released from combustion devices. This would not have any significant impact on the accuracy of the abatement.

4

Definitions of a combustion device

The definition of a combustion device is not uniformly used in the Draft Method Determination.

Section 5 of the draft method determination defines a combustion device as:(a) a flare, boiler or internal combustion engine; or(b) a device:

(i) that combusts landfill gas with a destruction efficiency of at least 98%; and(ii) that is operated in accordance with the manufacturer’s instructions; and(iii) the combustion process of which can be monitored on a minute by minute basis.

Section 19 of the draft method determination separates combustion devices as: a combustion device that is a boiler, a flare with monitoring and control system or an internal

combustion engine [in section 19 (2)]; or a combustion device that is not a boiler, a flare with monitoring and control system or an internal

combustion engine [in section 19 (3)].

Section 19 (3) of the Draft Method Determination refers to Section 29 (1) item 2 of the draft method determination. Section 29 (1) item 2 of the Draft Method Determination requires the operation of the combustion devices to be determined for each minute using temperature measurement if the combustion device is a flare.

To enable the operation of the combustion devices to be determined for each minute using temperature measurement would require a monitoring system. All flares would require some degree of control and would have a control system.

To be able to apply section 19 (3) of the Draft Method Determination would require a monitoring and control system and therefore section 19 (3) of the Draft Method Determination would not be applicable (a circular argument). To enable section 19 (3) of the Draft Method Determination to be carried out would require a monitoring system that would mean that section 19 (2) would apply not section 19 (3).

The definition in the Draft Method Determination that boilers or internal combustion engines do not require a monitoring and control system is at odds with the requirement that the combustion devices are required to combust the landfill gas using a combustion device. How can combustion be guaranteed without a monitoring and control system?

Instead of defining a combustion device as a flare, boiler or internal combustion engine the definition of a combustion device should simply be that all combustion devices should:

(i) combust landfill gas with a destruction efficiency of at least 98%; and(ii) be operated in accordance with the manufacturer’s instructions; and(iii) have the combustion process monitored on a minute by minute basis using a monitoring and

control system.

The requirement of a destruction efficiency of at least 98% may be of a concern in the case of open (or candle) type of flares that may have a destruction efficiency less then of 98% in some conditions.

5

Monitoring and control system

There is no definition of the requirement for a monitoring and control system in the Draft Method Determination.

The area associated with the monitoring and control system that will have an impact on the Draft Method Determination is the monitoring and control of the combustion of the landfill gas. The combustion requirements of the method determination can be covered by the requirements for fuel shut off after flame failure in the Australian Standards.

Australian Standards AS 1375—1985 AS 4625—2008 and possibly AS 3814—2009 define the requirements for fuel shut off after flame failure of landfill gas combustion devices. These standard are discussed below.

AS 1375—1985 (Industrial Fuel Fired Appliances Code) sets out the safety principles relating to the design, installation and operation of industrial appliances that involve the combustion of gas or oil, or other fuel in air suspension, or the generation of combustible vapours in such appliances.

It applies to combustion devices, including flares and boilers, as they are industrial appliances that involve the combustion of gas. This standard requires the fuel shut off after flame failure to occur as quickly as possible after the detection of loss of flame.

AS 3814—2009 (Industrial and Commercial Gas-fired Appliances) provides minimum requirements for the design, construction and safe operation of Type B appliances that use town gas, natural gas, simulated natural gas, liquefied petroleum gas, tempered liquefied petroleum gas, or any combination of these gases either together or with other fuels.

The standard specifically excludes simple atmospheric burners that are not fitted into a combustion chamber and burn in an open ventilated space under the control of an operator. As it is unlikely that a flare would be under the control of an operator this exclusion is unlikely to apply to Flares.

A common feature of the fuel gases listed in AS 3814 is that they are hydrocarbon based, their composition is regulated, and they are or were sold to consumers. Biogas is none of those so it is questionable whether a appliance combusting landfill gas could be considered a Type B appliance and that this standard applies.

AS 3814 requires that the flame safeguard system response time shall not exceed 3 s for main atmospheric burners which are neither manually-ignited nor fitted with a manually-ignited permanent pilot(s).

Atmospheric burners are a system where all of the air for combustion is produced by the inspirating effect of the gas or the natural draught in the combustion chamber or combination of the two without mechanical assistance. This would apply to most flares

AS 4625—2008 (Electronic flame safeguards and flame detectors) applies to electronic flame safeguards and flame detectors for use on gas or multi-fuel burners. They do not cover complete burner management systems except insofar as the flame safeguard has provision to be interlocked into the burner management system.

AS 4625 requires the electronic flame safeguard going to safety shutdown (or initiating a reignition cycle if it applies to the type) within of 1 s for flame safeguard Type A and B and within 2 s for the other flame safeguard types.

Based on the above Australian Standards all combustion devices are required to have a control system to ensure that no landfill gas is sent to the combustion device for more than 3 seconds without it being

6

combusted.

Due to the significant hazards associated with gas fired appliances it is extremely unlikely that they will not be operated in accordance with the manufacturer’s instructions.

A monitoring and control system should be present on all combustion devices due to the combustion devices being required to have electronic flame safeguards and flame detectors to the above Australian Standards, These standard should be referred to in the Method Determination.

Methane sent to combustion device (Msent,h, Msent,h,y, Msent,h,a)

Depending on the time period required, the calculation of the methane sent to combustion device is carried out on different time basis, either the reporting period (calculating Msent,h), the financial year (y) in the reporting period (calculating Msent,h,y) or the hour (a) in the reporting period (calculating Msent,h,a).

The use of different time basis in the calculations could lead to some confusion. The use of the different time basis in the calculations is discussed below.

Application of Msent,h,a

As discussed in the section above in this document on the monitoring and control system a monitoring and control system should be present on all combustion devices due to the combustion devices being required to have electronic flame safeguards and flame detectors to the Australian Standards. This implies that equation 7 would not apply and Msent,h,a would not be required.

If Msent,h,a is required the number of data points required to cover a year at one hour intervals results in a large data set.

Any calculation using equation 7 would be more likely to be carried out on the raw data on separate spreadsheets. If the methane sent to the combustion device Msent,h,a during the period is worked out using equation 8 and if the landfill gas flow is paired with the methane content, this would also be included on the raw data spreadsheet.

The application of Msent,h,y

Section 18 of the system in the draft method determination requires the proportion of the methane combusted during the reporting period in cubic metres that was not generated from carbon tax waste is worked out using the formula (equation 4):

This equation requires the use of the methane combusted on a financial year basis, Mcom,y, therefore the landfill gas sent to the combustion device Msent,h,y also needs to be on a financial year basis.

The application of Msent,h

As the methane combusted on a financial year basis, Mcom,y is required it is unlikely that the landfill gas sent to the combustion device for the project period Msent,h would be used.

The Method Determination can be simplified to use only Msent,h,y, Msent,h,a and have Msent,h as the sum of Msent,h,y and Msent,h,a.

A flowchart of the Draft Method Determination is shown on page 8 and a flowchart of a revised Draft Method Determination is shown on page 9.

com,y CTW,yNCT y

com total,y

M MW 1

M M

7

8

9

Specific comments – please insert your specific comments below, listed against the part of the draft method determination to which they apply.Note: In some cases the draft Explanatory Statement may flag specific issues for consideration by stakeholders.

Draft method determination reference

Comments

Section 8 (a) The statement “installing a landfill gas collection system at a landfill where there has never been such a system;” could apply to existing landfill projects as all projects were new and have a landfill gas collection system installed at a landfill where there has never been such a system.

This section needs to be revised to avoid this possible misunderstanding. A date is required after which the installation of a landfill gas collection is defined as new.

A possible revision is

“installing a landfill gas collection system at a landfill after 24 April 2014 where there has never been such a system”

Section 8 (b) The statement “recommencing landfill gas collection for the purpose of combustion, using either a new or existing landfill gas collection system, at a landfill where no landfill gas collection system has operated:

(i) after 24 April 2014; and(ii) during the 3 years before the application for the declaration of the project as

an eligible offsets project is made”

It is not clear whether “after 24 April 2014” refers to the date recommencing landfill gas collection for the purpose of combustion or “after 24 April 2014” refers to the date where no landfill gas collection system has operated.

This section needs to be revised to avoid this possible misunderstanding, a possible revision is:

“recommencing landfill gas collection for the purpose of combustion after 24 April 2014, using either a new or existing landfill gas collection system, at a landfill where no landfill gas collection system has operated during the 3 years before the application for the declaration of the project as an eligible offsets project is made.”

Section 9 (1) (a) The calculation of the net abatement achieved by an upgrade project depends on the magnitude of improvement to collection efficiency.

The Draft Method Determination assumes that the upgrade action requires a capital investment to increase the collection efficiency. An increase in collection efficiency would result from an increase in the amount of methane collected or a reduction in the methane generated by the landfill.

An increase in capture efficiency would apply on a closed landfill site even if there were no increase in the collection system due to the reducing methane generated by the landfill.

Likewise a reduction in collection efficiency would occur on a new site due to the increased methane generated by the landfill even if the capacity of the collection system were significantly increased.

10

If the default methane content were used to determine the methane content of the landfill gas then by extracting a greater volume of landfill gas at a reduced methane content would represent a upgrade even though there is no increase in methane combustion.

The used of collection efficiency can allow increased abatement to be claimed where is no change in the methane collection system or the combustion devices.

Most landfill gas projects operate the flare and collection systems to their maximum capacity so that any increase in methane combustion would be the result of an upgrade in their collection or combustion systems.

Section 20 (5) “ECLFG,h means the energy content of the landfill gas sent to the combustion device (h) during the reporting period in gigajoules worked out using the table in section 29.”

The energy content of the landfill gas sent to the combustion device can be defined on a Higher Heating Value (HHV) basis or a Lower Heating Value (LHV) basis. The energy content of the landfill gas needs to be on a Higher Heating Value basis for the factor ECLFG used to convert the energy content of the landfill gas to methane volume to be correct.

Section 20 (6) “Qeg,h means the electricity (supplied to the grid or used on site) produced by internal combustion engine (h) during the reporting period in megawatt hours worked out using the table in section 29.”

The definition of Qeg,h does not restrict the electricity produced by internal combustion engine to that due to the combustion of landfill gas. There may be support energy provided by the combustion of fossil fuel used in the operation of the internal combustion engine.

The definition of Qeg,h needs to define that only the generation included in this value is that due to the combustion of landfill gas.

Section 20 (6) (a) “the factor for the electrical efficiency of the internal combustion engine (h) determined in accordance with the manufacturer’s specifications”

The electrical efficiency of the internal combustion engine given in the manufacturer’s specifications can be defined on a Higher Heating Value (HHV) basis or a Lower Heating Value (LHV) basis. For the factor ECLFG used to convert the electrical energy to methane volume to be correct the efficiency needs to be on a High Heating Value basis and this should be defined in the determination.

The manufacturer’s specifications can give a range of the electrical efficiencies which and may apply to fuels other then landfill gas.

The equipment manufacturer specification provided for landfill gas fuel only should be used. If the specification provides a range of efficiency values, the highest value of the range should be used.

Section 29 (1) item 1

The energy content of the landfill gas sent to combustion device requires the use of the methane content of the landfill gas determined by a methane analyser or the use of the default methane content value.

As discussed above the energy content of the landfill gas sent to combustion device needs to be on a High Heating Value basis.

11

Section 29 (1) item 3

This item gives the instructions for the determination of Landfill gas sent to combustion device Qeg,h as a cumulative value for the reporting period.

This value can be the cumulative value for a financial year in the reporting period, one hour of the reporting period, 12 months immediately after the upgrade is completed or 2 years immediately before the upgrade is completed.

A cumulative value of Landfill gas sent to combustion device is appropriate when the default methane content is used.

If the actual methane content is used cumulative value of Landfill gas sent to combustion device needs to be paired with fraction of the volume of landfill gas that is methane. In this case the period of the cumulative value needs to be short enough to enable the methane sent to the combustion device to be accurate.

Section 29 (1) item 4

Electricity (supplied to the grid or used on site) generated by internal combustion engine (h) is estimated under Part 6.1 of the NGER (Measurement) Determination

There are no measurement requirements for electricity produced by the electricity generating unit for the facility as measured at the unit’s terminals. There is therefore no uncertainty defined for this value.

Section 29 (1) item 5

This item gives the instructions for the determination of the fraction of the volume of landfill gas that is methane to be measured a continuous basis estimated under Division 2.3.6 of the NGER (Measurement) Determination.

As discussed above, Division 2.3.6 of the NGER (Measurement) Determination does not apply as the landfill gas measurement equipment has a gas measuring equipment category of 1 or 2.

No requirement is defined for the landfill gas methane content measurement.

Do you consider projects that would apply the draft method are likely to cause significant adverse environmental, economic and/or social impacts?If so, what existing frameworks (such as regulatory frameworks or policies) are in place to address any such impacts?

No comment

12