10 May 2018
Stuart Dyke, Assistant Manager, Compliance and Assessment
documentasset::Landfill Guidelines for National Greenhouse and Energy Reporting, from Waste 2018.
So hi, I’m Stuart Dyke, from Compliance and Assessment and I want to talk about participating in the National Greenhouse and Energy Reporting scheme, including telling you about our upcoming update to our landfill guidelines.
So, firstly I’m going to give a brief introduction to the National Greenhouse and Reporting Scheme, and I’m going to call it NGER from this point on. It is a single national reporting framework for collecting and disseminating energy consumption, energy production and greenhouse gas emissions data. If your facility or company meets one of the reporting thresholds for energy or emissions then there are reporting requirements. That information is used for informing national government policy, supporting state and territory programs and to meet our international reporting obligations.
As I said, we are updating our landfill guidelines to assist with NGER reporting and this will be in time for the 2017-18 reporting period - reporting for that starts on the first of July this year- so that’s when we will have the guidelines ready. The guidelines are called estimating emission and energy from solid waste and landfill biogas management – which is a bit of a mouthful but we wanted to make it clear what the coverage is. That it is for both emissions and energy and for landfills and electricity generators.
The reasons for the update are pretty straight forward, to make it easier for people to report particularly because some parts of the legislation have been unclear in the past with respect to what the requirements are. There’s nothing worse than having reporters who are trying to do the right thing and find out the right information and having them contact us and us not being able to give clear information back and saying something like “please go and get legal advice.” So it’s much better if we can give a straightforward answers to straightforward questions. It is also streamlining our documentation, for the solid waste calculator spreadsheet tool there’s a user guide, we’ve pushed them together now so it’s just one document and I think a big feature of this update is that we are clarifying energy reporting, so as I said that’s been a part of the legislation that has been confusing for people.
Landfills themselves do have quite extensive data requirements and the new guidelines will provide a lot of information about what data you have to collect, what the standards are, and quality requirements for that data. We are also going to provide, as I said, instructions to use our spreadsheet calculation tools, so the spreadsheet calculation tool does a lot of the heavy lifting of the calculations because for landfills they are relatively complex the calculations and the data requirements are large so we just wanted to simply it with the calculator and so there’s instructions for that in the document.
As I touched on before energy reporting has been a source of confusion for both the reporter and sometimes for the agency, so we are going to provide really clear guidance on when energy reporting is required, what activities require that to be reported and who has to do the reporting. So I’ll just give an overview of the emissions and energy sources that are reportable under NGERs. So over on the left there’s emissions from uncaptured landfill biogas – so they’re reportable emissions. If you capture landfill gas then energy production is required to be reported, and when you combust landfill gas in an engine or a flare there’s energy consumption and productions to be reported, and emissions. So there’s a few different points in the activities where emissions and energy have to be reported.
When complying and reporting information, there are overarching principles for the measurement and estimation. So transparency is just things like making sure you keep your records for five years, making sure there is a clear audit trail for the information and clear documentation of any assumptions or decisions you make during compilation of your report.
Comparability is simple, it’s just basically use the methods that are in the legislation so that everyone is doing the same thing.
Completeness is even simpler just make sure you don’t miss any sources of emissions, so if you have a stack of emissions coming out if an electricity generator obviously don’t miss that.
Accuracy that means that you have to minimise uncertainly by applying reasonable resources. So that just basically means do the best you can. In the methods for estimation there’s a number of different ways you can estimate but you’ve got to do the best you can using the best available data – that’s the main principle there.
An interesting or unusual feature of NGER is the concept of facility, so facility might be commonly understood to just be a particular site, but under NGER a facility is a series of activities and there is a reporter for each facility and that reporter is the party that has the greatest operational control and that’s the party that has the greatest power to implement environmental policies, operation policies and work health and safety policies. I’m not going to get into that part of the reporting, I’ll just refer to other guideline on our website and there’s a link at the end of this presentation to our guideline.
I’ll give a simple example of a facility configuration. There is where all of the relevant activities are part of the same facility and they will be reported by one party, so there is the waste management, the gas collection and combustion and there’s biological treatments such as composting. So they are all sources of emissions and in this particular case there will be one reporter for that.
So here’s another configuration, this is where the activities are spread across multiple facilities, you have landfill on the left, waste management top right this is the flaring electricity generation and the bottom right is the biological treatment and composting. So there’s different ways for the facilities to be configured and that determines who has the reporting responsibilities for the different sources of emissions and also energy.
As I said there’s relatively extensive requirements in terms of data and calculations for landfills compared to other sectors so in the guidelines there’s some step by step flowcharts and guidance in there. Si there’s a lot of steps, but if you just follow the steps it should be okay, and it just makes it a bit simpler than trying to wade through the legislation which is a bit complicated at times. One of the key things in the calculations is working out the amount of waste that actually goes into the landfill itself, which causes emissions, And that is different to what is received at the gate of your landfill, so a common mistake we have with reporters is people work out the amount of waste that goes into the landfill and input it into our solid waste calculator tool and it brings up an incorrect result. It is a common reporting error so that is in the guidelines. So there is waste received at the landfill, that is reportable and then there are the items in orange which is the amount of waste diverted from land fill and that is the amount of waste you actually get in the landfill so it is just about following the steps and the guidelines to make sure you report the right items.
Waste is categorised into waste stream, that is about where the waste originates from, the waste is further categorised into waste mix types, that is more about the substances and the materials themselves, and to work out those compositions there are defaults and site-specific estimates but once again that principle applies if you use the best available data – that’s the broad principle. So in terms of some of the waste streams there is:
There’s a few different ways to calculate your waste stream proportions, but for each set of circumstances there’s only one correct way of doing it so once again in the legislation is a bit complex, so we’ve just provided some flowcharts so you can just work through them and it will ensure that you report compliantly.
That was waste streams, and the waste mix types there’s default proportions which is what nearly everyone uses because the statistically vail sampling, from my understanding, is very uncommon. So there is an example in the table of some default proportions within default waste mixed type proportions within a couple of waste streams.
To estimate the methane content in your landfill gas, once again there are different ways to do it, so you can measure at the point of combustion and certain standards and accuracy requirements apply, or there is industry practice with is under Criterion BBB that’s more flexible, and you can back calculate from the amount of electricity that you generated and in circumstances where you don’t have equipment then there is a default 50% methane concentration for flaring that can be used.
There is a requirement to report your emissions split up between legacy and non-legacy if your landfills huge, I don’t know if many meet that requirement, but legacy emissions are from waste that was deposited prior to first of July 2016 and non-legacy emissions are from waste deposited from first of July 2016 and onwards. So legacy and non-legacy used to have different meanings from another government initiative from a few years ago, but I won’t get into that.
But anyway the solid waste calculator tool that we have performs all the extra calculations and does the heavy lifting.
So this is something we have clarified for this year that is emissions from flaring must be reported by the facility that operates that flare, the facility that includes that flare. So that is irrespective of any contractual arrangements between different facilities. It is just if you operate the flare you report the emissions.
Energy production is something that we have clarified for the first time this year, in time for the reporting period and it sort of demonstrated that NGER has a bespoke use of the English language for legal purposes sometimes, so if you force gas into a pipe i.e. use a blower or an extraction fan to draw gas into collection wells and into a pipe that’s considered to have been “injected into a pipeline” which is from the legislation – and if its injected into a pipeline then the landfill biogas has been captured for combustion and that constitutes energy production, so there’s the concepts that in common understanding aren’t very clear but looking into the legal definitions themselves that’s what it means.
So that means that whenever methane is captured it has to be reported as energy produced so that doesn’t matter if it gets combusted or transferred to another facility. It is the facility that operates the landfill gas collection wells that has to report, so the energy production is considered to occur at the point at which the gas enters the collection wells. It is important if you have all of these activities spread across two facilities then the facility operators have to have common understanding of whose operating the collection wells because they have to report energy production.
For energy consumptions it is similar, so if it is burnt then energy consumption needs to be reported and it is by the party that is operating the combustion device.
So I will give a couple of examples of what I said so this is a single facility example where all of the activities occur in the one facility, and in that case all the emissions and all the energy consumption and all the energy production have to be reported by that party.
This is an example where you have the activities spread across two facilities and in this case it is the second facility – the landfill gas management facility that operates the biogas collection wells. And in that case the landfill facility just reports emissions from the landfill, and the landfill gas management facility has to report all of the energy production, all of the energy consumption and emissions from the combustion.
As I said earlier, we are updating the spreadsheet calculation tool as well – the solid waste calculator, this is just a quick snapshot of it, it has got about another 30 columns to the right and another few sheets but it is the way it has to be. So we are updating that to make it easier to use, so having more questions included. We are going to make it more comprehensive and I just wanted to make clear that there has been no update to the legislation – I should of said this earlier – so the updates to the guidelines and the update to the calculator is not because there has been any update to the legislation.
If you have any more questions after today please feel free to contact us.
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