Carbon Farming Initiative
Guidelines for Calculating Regulatory Baselines
for Legacy Waste Landfill Methane Projects
Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education
June 2013
1
Contents
1
2
3
Introduction .................................................................................................................................... 4
1.1
Regulatory additionality test and eligibility ............................................................................ 5
1.2
Regulatory baselines ............................................................................................................... 6
1.3
Transitioning and other projects............................................................................................. 6
Regulatory requirements ................................................................................................................ 7
2.1
Qualitative requirements ........................................................................................................ 7
2.2
Quantitative requirements ..................................................................................................... 7
Calculating the Regulatory Baseline (Rp) ......................................................................................... 8
3.1
Qualitative requirements: legislation, licence conditions, development approvals and
landfill guidelines ................................................................................................................................ 9
4
3.2
Quantitative restrictions ....................................................................................................... 10
3.3
Converting allowable methane concentrations to capture rate .......................................... 10
3.4
Assessment of quantitative restrictions ............................................................................... 11
Regulatory additionality test and eligibility .................................................................................. 12
4.1
Qualitative requirements ...................................................................................................... 13
4.2
Quantitative requirements ................................................................................................... 14
4.3
Note on upgrade projects ..................................................................................................... 14
4.4
Application requirements ..................................................................................................... 15
5
Calculating project baselines ........................................................................................................ 16
6
Examples ....................................................................................................................................... 18
Example 1 – Calculating and applying Rp for a new project with qualitative and quantitative
requirements .................................................................................................................................... 18
Example 2 – Calculating and applying Rp by consulting a registered Greenhouse and Energy
Auditor .............................................................................................................................................. 20
Example 3 – Calculating Rp using the CFI Calculator ......................................................................... 21
Example 4 – Calculating and applying Rp for an upgrade project ..................................................... 22
Example 5 – Assessing the additionality of a project with qualitative and quantitative
requirements .................................................................................................................................... 24
Example 6 – Calculating the project reporting baseline for a new project ...................................... 25
7
Glossary ......................................................................................................................................... 26
8
Reference documents ................................................................................................................... 27
Appendix A: Using the Carbon Farming Initiative Landfill Methane Regulatory Baseline Calculator .. 28
2
Appendix B: Method for calculating regulatory requirement using methane concentration limits
(ppm) contained landfill guidelines ...................................................................................................... 30
Appendix C: Methane emission pathways for estimating regulatory requirements ............................ 33
3
1 Introduction
These Guidelines are established under the Carbon Farming (Capture and Combustion of Methane in
Landfill Gas from Legacy Waste) Methodology Determination 2012 (known as the ‘installations
methodology’) and the Carbon Credits (Carbon Farming Initiative) (Capture and Combustion of
Methane in Landfill Gas from Legacy Waste: upgrade projects) Methodology Determination 2012
(known as the ‘upgrades methodology’).
This document provides guidelines for determining the proportion of methane that is required to be
captured or destroyed to meet regulatory requirements to control greenhouse gas, odour or
methane from landfills. This is known as the ‘regulatory baseline’ capture rate, and is given the
notation ‘Rp’.
The document is structured as follows:
Part 1: Introduction describes the context and application of these Guidelines.
Part 2: Regulatory requirements describes the different types of regulatory requirements that relate
to landfill gas management.
Part 3: Calculating the Regulatory Baseline explains how the regulatory baseline capture rate (Rp) is
calculated for the different types of regulatory requirements.
Part 4: Regulatory additionality test and eligibility explains how the Clean Energy Regulator will use
these Guidelines to determine the eligibility of a landfill legacy emissions avoidance project.
Part 5: Calculating project baselines explains how project proponents will use these Guidelines to
calculate project baselines under the two landfill methodology determinations, and how net
abatement is calculated relative to a project baseline.
As illustrated in Figure 1, these Guidelines are used:
1

by the Clean Energy Regulator to determine whether a legacy landfill emissions avoidance
project passes the regulatory additionality test1 and is eligible to apply a methodology; and

by project proponents to estimate the quantity of methane that would have been destroyed
under baseline conditions (the project baseline, Areg). Net abatement is calculated relative
to the project baseline to determine how many Australian carbon credit units (ACCUs) will
be issued.
The term ‘regulatory additionality test’ refers to section 41 (1) (b) of the CFI Act. To be declared eligible,
projects must not be required to be carried out by or under a law of the Commonwealth, a State or a Territory.
4
Figure 1: Application of these Guidelines for the Clean Energy Regulator (red) and project
proponents (green)
Regulatory baseline capture
rate (Rp) is calculated in
accordance with these
Guidelines
(Part 3)
The Regulator applies Rp to
the amount of gas generated
and compares this with the
amount of gas captured to
determine whether a project
is eligible ...
Project proponent applies Rp
to the amount of gas
captured to calculate the
project baseline (Areg)
...under the regulatory
additionality test.
Project proponent calculates
net abatement amount (the
number of ACCUs, A) relative
to the project baseline.
(Part 4)
(Part 5)
1.1 Regulatory additionality test and eligibility
The Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) provides that the Clean Energy
Regulator (the Regulator) may only approve a project if it is not required to be carried out by or
under a law of the Commonwealth, a State or Territory (section 41 (1) (b)). The Carbon Credits
(Carbon Farming Initiative) Regulations 2011 (CFI Regulations) provide that projects are excluded if
they only pass the additionality test because a legal requirement was repealed after 24 March 2011
(regulation 3.36). This ensures there is no incentive to relax or repeal requirements in order to
generate credits for activity that would have occurred in the absence of the project.
The Clean Energy Regulator will use these Guidelines to assess whether a project passes the Carbon
Farming Initiative (CFI) test for regulatory additionality. A project will pass the regulatory
additionality test if the Regulator determines for the purposes of the CFI that it captures more of the
landfill gas than is required under regulations.
Projects must pass the additionality test to be declared eligible.
Projects that are additional must also meet the eligibility requirements set out in Part 2 of the
relevant methodology determination to participate in the CFI.
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1.2 Regulatory baselines
Two landfill methodology determinations have been approved for use under the CFI Act. These
outline the methods for estimating abatement from the destruction of emissions from waste
deposited prior to 1 July 2012 (legacy waste).
Under these determinations, project proponents are required to calculate the project baseline,
which is the proportion of methane generated that would have been captured from the landfill in
the absence of the project. Project abatement is calculated relative to the project baseline to
determine how many Australian carbon credit units (ACCUs) will be issued for a reporting period.
1.3 Transitioning and other projects
Projects transitioning from New South Wales Greenhouse Gas Reduction Scheme or the Australian
Capital Territory Greenhouse Gas Abatement Scheme (GGAS) or Greenhouse Friendlytm are not
subject to the requirement in section 41 (1) (b) of the CFI Act and should use the relevant default
baseline for transitioning projects.
The default baseline for projects transitioning from GGAS is 24 per cent and zero per cent for
projects transitioning from Greenhouse Friendly.
A project is transitioning from GGAS if the same project was accredited and eligible to generate
abatement certificates under GGAS until the scheme’s closure on 1 July 2012. Note that under
GGAS, Category A Generating Systems, which included a number of landfill gas projects, stopped
being entitled to create abatement certificates under GGAS for abatement after 1 July 2010.
Category A projects are not transitioning from GGAS, but could apply the baseline for projects that
upgrade an existing system, in accordance with the upgrades methodology.
A project is transitioning from Greenhouse Friendly if the same project was accredited and eligible to
generate credits under Greenhouse Friendly until the scheme’s closure on 30 June 2010 and the
project has not been accredited under GGAS since that time.
Where a new project is established on a landfill facility that already has a GGAS or Greenhouse
Friendly project, the new project’s regulatory baseline must be calculated in accordance with these
Guidelines and is not the default regulatory baseline for the transitioning project.
A transitioning GGAS or Greenhouse Friendly landfill project is a transitioning project for the first
crediting period only. These Guidelines must be used to determine the regulatory baseline for any
landfill gas capture project that is approved for a second crediting period.
Projects transitioning from the Cities for Climate Protection program are subject to a regulatory
baseline and are not exempt from the regulatory additionality test.
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2 Regulatory requirements
For the purposes of the CFI Act, the term ‘regulatory requirement’ refers to qualitative requirements
to capture, control, manage or limit landfill gas, methane, odour or greenhouse gases and
quantitative restrictions such as an allowable methane concentration. Regulatory requirements may
be contained in state or territory legislation, guidelines for waste management and landfills set by
state and territory environmental regulators, landfill licences, or in environmental or development
approvals.
The Clean Energy Regulator must determine whether a project passes the regulatory additionality
test before declaring it eligible to participate in the CFI (Part 4). To pass the regulatory additionality
test, projects must exceed (and not only meet) the regulatory requirement.
Note that these determinations are for the purposes of implementing the CFI Act only, and do not
replace or override assessments by the relevant state or territory regulator, and that where
available, state or territory assessments of compliance will be used.
Project proponents must estimate the proportion of landfill methane required to be captured by
regulatory requirements (Part 3) in order to identify the project baseline (Part 5).
2.1 Qualitative requirements
Qualitative requirements may be included in state or territory legislation or in guidelines for waste
management and landfills set by state and territory environmental regulators. Many landfill licences
or development approvals include a qualitative requirement to capture, control, manage or limit
landfill gas, methane, odour or greenhouse gases. These requirements may be expressed in a variety
of ways and do not need to include specific instructions or directions. For example:








install a landfill methane capture system
develop a plan to install a landfill methane capture system
install a landfill methane capture system to keep within allowable methane concentrations
control or reduce methane concentrations
control, manage or limit odour
capture landfill gas where practicable
reduce emissions of greenhouse gases
limit, minimise or control greenhouse gases.
These Guidelines contain information about how project proponents must demonstrate, and the
Clean Energy Regulator will determine, whether a project exceeds qualitative requirements (Part
4.1) and how project proponents are to translate qualitative requirements into a quantitative
regulatory baseline capture rate (Part 3.1).
2.2 Quantitative requirements
State and territory environmental regulators have established guidelines for sustainable waste
management and landfill performance. Quantitative requirements may also be set out in landfill
7
licences, legislation or other regulatory documents or derived from assessment notices provided by
state and territory environmental regulators. They can be expressed in different terms, such as:


allowable methane concentration limits for intermediate and final cover surfaces, which are
designed to minimise fugitive methane emissions through these layers; or
compliant capture rate (derived from assessment notices).
These Guidelines contain information about how project proponents must demonstrate, and the
Clean Energy Regulator will determine, whether a project exceeds quantitative requirements (Part
4.2) and how project proponents are to translate the different types of quantitative requirements
into a regulatory baseline capture rate (Parts 3.3 and 3.4).
8
3 Calculating the Regulatory Baseline (Rp)
This section sets out the instructions for converting different types of regulatory requirements to a
baseline proportion of gas that must be captured (the regulatory baseline). The regulatory baseline is
used in two ways:
-
for the regulatory additionality test, it is applied to the amount of methane generated by the
landfill; and
for the project baseline, it is applied to the amount of methane captured by the project.
The regulatory baseline is approved for the seven year crediting period. Changes to CFI Regulations
after a project is approved will not affect the project baseline for the duration of the crediting
period. The regulatory baseline is expressed as a percentage, which is then used for each reporting
period to calculate the project baseline for that period, which is expressed in tonnes of carbon
dioxide equivalent (t CO2-e). The additionality of the project and its associated regulatory baseline
must be reassessed if the project applies for a further crediting period.
Project proponents should determine the regulatory baseline capture rate (Rp) by undertaking the
following steps:
Step 1 – Determine the qualitative requirement, if any. This is 30 per cent where there is any
qualitative requirement to capture, control, manage or limit landfill gas, methane, odour or
greenhouse gases, or zero if there is no such qualitative requirement – see 3.1 below.
Step 2 – Determine the quantitative requirement, if any. Calculate the quantitative regulatory
requirement from the relevant state and territory guidelines surface methane concentration limits
or determine the level of gas capture required to comply with the specified limits for methane
concentrations in accordance with 3.3 or 3.4 below. If there is no quantitative requirement, the rate
is zero.
Step 3 – Identify the rate of capture that satisfies both regulatory requirements (Rp), which is the
higher rate of capture from step 1 or step 2. Where there are no quantitative or qualitative
requirements, the regulatory baseline is equal to zero (Rp = 0).
The following sections provide instructions for converting qualitative and quantitative regulatory
requirements (which can be expressed in different ways) into capture rates, which are expressed as
a proportion. The capture rates can then be used for steps 1 to 3 above. Note that the steps above
require all proponents to undertake the process set out in 3.1 and in whichever of 3.3 or 3.4 is
applicable.
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3.1 Qualitative requirements: legislation, licence conditions, development
approvals and landfill guidelines
Where the landfill operator is subject to legislation or guidelines for waste management and
landfills, or has a licence condition or development approval, which includes, or has had at any time
since 24 March 2011 included, any form of general or specific qualitative requirement to capture,
control, manage or limit landfill gas, methane, odour or greenhouse gases, then for the purposes of
the CFI this means that the landfill operator is required to capture 30 per cent of landfill methane.
Where the proponent can demonstrate that none of these requirements are in place, the qualitative
requirement on a project will be zero for the purposes of the CFI.
3.2 Quantitative restrictions
State and territory environmental regulators have established guidelines for sustainable waste
management and landfill performance. These include allowable methane concentration limits for
intermediate and final cover surfaces, which are designed to minimise fugitive methane emissions
through these layers.
To keep within allowable methane concentrations, landfills need to capture a certain proportion of
the landfill methane generated. This section contains instructions for determining, for the purposes
of the CFI, the proportion of gas generated that must be captured for compliance with quantitative
restrictions on methane concentrations at landfills.
Proponents can convert the allowable methane concentrations to capture rate in accordance with
3.3. The current NGER (Measurement) Determination must be used to calculate landfill methane
generation. Proponents can use the NGER solid waste calculator and accompanying user guide for
this purpose.
Alternatively, proponents can determine the proportion of methane generated that must be
captured for compliance with the relevant allowable methane concentration, in one of two ways.
Proponents can either consult the relevant state or territory environmental regulator, or engage a
registered greenhouse and energy auditor to calculate the required methane capture rate in
accordance with 3.4.
3.3 Converting allowable methane concentrations to capture rate
The limits for allowable methane concentration (shown in Appendix B) differ according to
jurisdiction and are sourced from landfill guidelines listed in section 8, all of which pre-date 24
March 2011. South Australia and the Northern Territory do not prescribe allowable methane
concentrations. The Australian Capital Territory applies the same limits as Victoria. The allowable
flux rates (also shown in Appendix B) are sourced from the reference document Draft CFI Methods.
Appendix B provides guidance on converting allowable methane concentrations into the rate of
capture required by regulation.
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The Carbon Farming Initiative Landfill Regulatory Baseline Calculator is available on the Carbon
Farming Initiative website (http://www.climatechange.gov.au/reducing-carbon/carbon-farminginitiative) and provides a simplified method to estimate the level of gas capture required to meet the
above allowable methane concentrations required by regulation.
It is assumed that landfill methane only escapes through final cover, intermediate cover and daily
cover/operational areas. Appendix C provides a diagrammatic representation of landfill methane
emissions pathways.
3.4 Assessment of quantitative restrictions
Project proponents may ask the relevant state or territory environmental regulator to determine the
gas capture rate required for compliance with the highest specified limits for methane
concentrations that have been in place since 24 March 2011. Alternatively, if regulatory
requirements have not changed since 24 March 2011, project proponents may instead ask the
relevant state or territory environmental regulator whether their current gas capture rate complies.
This advice may take the form of confirmation that all practicable measures have been taken to keep
emissions within allowable limits.
If the state or territory regulator advises that the current level of gas capture complies, the project
proponent may take the corresponding methane capture rate to be the approved rate of capture
that is required to keep methane concentrations within allowable limits. The corresponding methane
capture rate is calculated as the amount of gas captured over the 12 months prior to the assessment
divided by the amount of gas generated in the same 12 months, calculated in accordance with the
NGER Determination (solid waste calculator). Evidence of the state or territory regulator’s decision
that a lower capture rate is compliant must be provided to the Clean Energy Regulator.
The required level of gas capture could be given in different terms such as methane concentration,
flux rate, proportion of generation allowed to be released or proportion of generation required to be
captured. The project proponent must convert these to a capture rate in accordance with table 1.
Table 1: Converting quantitative regulatory requirements to a proportion of gas generation that
must be captured
Regulatory requirement
Allowable methane concentration
Conversion to proportion of generation
See Part 3.3
Allowable flux rate
See Part 3.3
Proportion of generation
No conversion necessary
Amount of gas captured
Convert the amount into a proportion of gas generated
(calculated in accordance with the NGER Determination)
Determine the quantity of gas (in t CO2-e) that must be
captured to meet the stated requirement. Divide the
amount by the amount of gas generated (calculated in
accordance with the NGER Determination)
Other
11
Project proponents should note that state and territory environmental regulators are under no
obligation to undertake an assessment of quantitative restrictions, and that other options are
available to project proponents to determine this gas capture rate.
As an alternative to consulting the state or territory environmental regulator, project proponents
may engage a registered greenhouse and energy auditor to determine the gas capture rate that is
required for compliance with the highest specified limits for methane concentrations that have been
in place since 24 March 2011. In this case:
-
the auditor must be registered in accordance with s75A of the National Greenhouse and Energy
Reporting Act 2007;
the assessment must include the regulatory requirement expressed as the proportion of
methane generation; and
neither the same individual auditor, or the same company, who determines the required gas
capture rate, can be involved in preparing an audit report accompanying the project proponent’s
application for a certificate of entitlement.
A formal record of the assessment must be provided to the Clean Energy Regulator. The Clean
Energy Regulator must be satisfied that the evidence that has been provided is sufficient to establish
the gas capture rate required to comply with the project’s quantitative restrictions.
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4 Regulatory additionality test and eligibility
A project must pass the regulatory additionality test to be eligible to participate in the CFI. To
determine if a project is additional, the Clean Energy Regulator must be satisfied that it captures
more landfill gas than is required by regulations. Note that these assessments are for the purposes
of implementing the CFI Act and do not replace or override assessments by the relevant state or
territory regulator, and that where available, state or territory assessments of compliance will be
used. The regulatory additionality test is applied before the start of each crediting period: it is not reassessed during a crediting period. As outlined in Part 1.3, transitioning GGAS and Greenhouse
Friendly projects are exempt from the regulatory additionality test.
To determine whether a project passes the regulatory additionality test, the Clean Energy Regulator
will consider the regulatory requirements that are in place during the crediting period for the
relevant landfill, or that have been in place since 24 March 2011, and whether the project will
exceed these requirements.
Where a landfill is subject to both qualitative and quantitative requirements the project must exceed
both types of requirement.
The Clean Energy Regulator must also be satisfied that a project meets the eligibility requirements
set out in Part 2 of the relevant methodology determination.
4.1 Qualitative requirements
The Clean Energy Regulator will consider the nature of the regulatory requirement and whether the
project will exceed the minimum option that would meet that requirement. To pass the regulatory
additionality test, projects must exceed (and not only meet) the regulatory requirement
For example, if there is a regulatory requirement to control odour, reduce greenhouse gases, or
install a gas capture system, a project to install a generation system, kiln or any other system that
captures gas for commercial sale or re-use would be considered to exceed the requirement. This is
because there is a financial incentive to capture as much gas as possible with systems designed to
generate electricity or utilise heat.
Installation of a flare would also exceed the minimum requirement in some circumstances. For
example, a landfill may be subject to a regulatory requirement to manage odour at the boundary. If
this requirement has been satisfied through measures to monitor odour, installation of a flare would
pass the regulatory additionality test.
If the regulatory requirement was to install a flare, a CFI project to install a flare would meet the
requirement but would not necessarily exceed it. If a licence condition required the installation of a
landfill gas generation system, installation of a generation system would not necessarily exceed the
regulatory requirement.
In these cases, the proponent would need to provide further evidence to the Clean Energy Regulator
to show that the type of system installed would capture more than 30% of the gas generated.
13
4.2 Quantitative requirements
Where there is a quantitative requirement in place, the Clean Energy Regulator will use these
Guidelines to determine the equivalent proportion of gas generated that must be captured to
comply with the requirement (Rp). Alternatively, the project proponent may provide an assessment
notice from the relevant state or territory environment regulator to demonstrate that the current
rate complies. The Clean Energy Regulator will then determine whether the project will exceed this
rate of capture. The following section illustrates some of the methods the Clean Energy Regulator
may use to determine whether a project passes the regulatory additionality test.
Method 1: Past performance data
Where a project has operated prior to application for a declaration of eligible offsets projects (as for
most backdated projects), past performance data could be used. Under this option, the Clean Energy
Regulator would require evidence of the project’s past capture rate as a proportion of generation. If
the past capture rate exceeds the regulatory baseline capture rate, the project will pass the
regulatory additionality test. Proponents will need to demonstrate that their projects continue to
operate with the same equipment or with an upgrade in order to be assessed as continuing to
exceed regulatory requirements.
Method 2: State and territory regulator assessments
For projects that use state or territory environmental regulator assessments to show that they
comply with (rather than exceed) regulatory requirements prior to the project, the Clean Energy
Regulator may seek evidence that the project will exceed this requirement. This evidence could be in
accordance with that for qualitative requirements, described above.
Alternatively, the proponent may seek advice from the relevant state or territory regulator that the
project captures more than is required for compliance. Project proponents should note that state
and territory environmental regulators are under no obligation to provide this information.
Method 3: independent assessments
For projects that use independent registered national greenhouse and energy auditors to show that
they comply with (rather than exceed) regulatory requirements prior to the project, the Clean
Energy Regulator may seek evidence that the project will exceed this requirement. This evidence
could be in accordance with that for qualitative requirements, described above.
4.3 Note on upgrade projects
Upgrade projects must comply with regulatory requirements for two years prior to the upgrade
taking place. This ensures that projects that have not complied with regulatory requirements in the
past do not receive credits for upgrades that bring them up to regulatory requirements.
The project proponent must demonstrate to the Clean Energy Regulator’s satisfaction that an
upgrade project meets the eligibility requirements of the methodology determination by providing
evidence that the capture rate in the two years prior to the upgrade taking place exceeds regulatory
requirements.
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4.4 Application requirements
The project proponent must include a copy of any relevant licensing conditions and development
approvals in their application for an eligible offsets project declaration. They must also include the
following information where relevant:





15
methane generation calculations for the year (or for upgrade projects, the two years)
immediately prior to the project, including evidence of use of NGER methodology;
evidence that the project is a transitioning project, if applicable;
for upgrade projects, evidence that an upgrade has taken place;
information on how the quantitative requirement has been calculated; and
where assessing quantitative regulatory requirements in accordance with 3.3, evidence of a site
specific methane capture rate requirement for the year (or for upgrade projects, the average
proportion captured over the two years prior to the upgrade) immediately prior to the project,
that has been approved and validated by the relevant state or territory environmental regulator,
or by a registered greenhouse and energy auditor, such as:
- an inspection report where the environmental regulator has undertaken gas monitoring
for compliance assessment;
- an inspection report which has reviewed an environmental audit that contains sufficient
information on assessment of landfill gas emissions against regulatory requirements;
- an environmental audit report that contains sufficient information on assessment of
landfill gas emissions against regulatory requirements;
- where relevant, a copy of the assessment by the relevant state or territory regulator of
compliance of a project’s gas capture rate; or
- where relevant, information on test wells and the data collected from them and details
of any estimation based on that data.
5 Calculating project baselines
The project baseline (Areg) is calculated for each reporting period by multiplying the amount of
methane from legacy waste captured during the reporting period (𝛄 ∑𝐧𝐡=𝟏 𝐐𝐜𝐨𝐦,𝐡 ) by the proportion
of methane captured under baseline conditions (Rp in the installations methodology, and Bp in the
upgrades methodology). Note that the calculation of project baseline differs from the regulatory
additionality test whereby Rp is applied to the amount of methane generated from legacy waste.
To calculate the project baseline, the regulatory requirement must first be translated to a proportion
of gas that must be captured.
The proportion of landfill gas that must be captured for compliance with regulatory requirements is
the regulatory baseline (Rp), which is determined in accordance with Part 3. The regulatory baseline
is applied to the amount of landfill methane captured, and not the amount of landfill methane
generated, to calculate the project baseline2.
Table 2 summarises the project baselines for different project types covered by the two
methodologies. This shows how the regulatory requirement is used in the calculation of the project
baseline.
2
Note that the regulatory baseline capture rate is applied to the amount of landfill gas generated in order to
determine eligibility.
16
Table 2. Summary of project types and baselines
Project type
Installations methodology
Baseline
𝐧
𝐀𝐫𝐞𝐠 = 𝛄 ∑ 𝐐𝐜𝐨𝐦,𝐡 × 𝐑 𝐏
𝐡=𝟏
Transitioning Greenhouse Friendly
projects
Transitioning GGAS projects
Projects that install new landfill gas
capture equipment after 1 July 2010
Upgrades methodology
Under this methodology, the baseline capture amount is
calculated by multiplying the amount of methane captured
during the reporting period by Rp
Rp = 0
No gas would be captured in the absence of the project
Rp = 0.24
24% of the gas captured would have been captured in the
absence of the project
Rp is calculated in accordance with these Guidelines.
The proportion of the gas captured that would have been
captured in the absence of the project is the regulatory
requirement
𝐧
𝐀𝐫𝐞𝐠 = 𝛄 ∑ 𝐐𝐜𝐨𝐦,𝐡 × 𝐁𝐏
𝐡=𝟏
Projects that installed new landfill
gas capture equipment between 1
July 2007 and 1 July 2010
Transitioning Cities for Climate
Protection projects
Projects that upgrade existing
landfill gas capture equipment
Under this methodology, the baseline capture amount is
calculated by multiplying the amount of methane captured
during the reporting period by Bp
Bp = Rp, calculated in accordance with these Guidelines.
The proportion of the gas captured that would have been
captured in the absence of the project is the regulatory
requirement
Bp = Rp, calculated in accordance with these Guidelines.
The proportion of the gas captured that would have been
captured in the absence of the project is the regulatory
requirement
Bp is the higher of:
- Rp, calculated in accordance with these Guidelines; and
- 1 − ∆C, calculated in accordance with the methodology
Examples 1, 2, 4 and 6 demonstrate how the regulatory baseline (Rp) is used in the calculation of
avoided emissions (Ap), which is then used to calculate the amount of abatement that can be
credited under the CFI. The examples includes only key elements of the CFI landfill gas capture
methodologies, and are therefore not a comprehensive representation of the methodologies.
17
6 Examples
Please note that the examples below include only key elements of the CFI landfill gas capture
methodologies for simplicity, and are therefore not comprehensive representations.
Example 1 – Calculating and applying Rp for a new project with qualitative and
quantitative requirements
A landfill operator plans to install a gas capture system and uses the Carbon Farming
Initiative Landfill Regulatory Baseline Calculator to work out how much gas must be
captured to keep within allowable methane concentrations. This indicates that the
proportion of methane capture needed to meet this requirement is 15 per cent.
The landfill also has a qualitative license condition that requires the operator to install a gas
capture system (5.1). The landfill is therefore taken to have a regulatory requirement of 30
per cent.
The landfill generated 20,000 t CO2-e and captured 10,000 t CO2-e in the period used for
estimating the regulatory baseline. This equates with a capture rate of 50% of methane
generated, which exceeds the regulatory requirement of 30%. The project passes the
regulatory additionality test.
Step 1: Identify the rate of capture that satisfies both regulatory requirements.
The regulatory baseline for the project is the higher regulatory requirement of 30 per cent
(Rp = 0.3).
Step 2: Calculate the quantity of methane destroyed under baseline conditions, i.e. the
project baseline (Areg), using equation 12. In this example, the project captures 10,000
t CO2-e in the reporting period (γ ∑nh=1 Q com,h = 10,000).
n
Areg = γ ∑ Q com,h × 𝐑 P
h=1
Areg = 𝟏𝟎, 𝟎𝟎𝟎 × 𝟎. 𝟑
Areg = 𝟑, 𝟎𝟎𝟎 t CO2-e
Step 3: Calculate avoided emissions (Ap) using equation 23
n
Ap = [(γ ∑ Q com,h ) − Areg ] × (1 − OF) − Ecom
h= 1
3
OF = oxidation factor. Some of the methane captured would have oxidised and not been emitted to the
atmosphere had gas capture equipment not been installed. Oxidation must therefore be deducted in order to
calculate accurately the additional abatement achieved by installing gas capture equipment beyond what
would have occurred otherwise. Ecom = quantity of methane and nitrous oxide emissions released from
combustion devices in the landfill facility, in t CO2-e.
18
𝐀𝐩 = [𝟏𝟎, 𝟎𝟎𝟎 − 𝟑, 𝟎𝟎𝟎] × 𝟎. 𝟗 − 𝐄𝐜𝐨𝐦
𝐀𝐩 = 𝟔𝟑𝟎𝟎 − Ecom
19
Example 2 – Calculating and applying Rp by consulting a registered Greenhouse and
Energy Auditor
A project installed in 2008 captured 20,000 t CO2-e over the 12 months prior to applying to
participate in the CFI. In this example, this period is also the reporting period.
γ ∑nh=1 Q com,h = 𝟐𝟎, 𝟎𝟎𝟎
The landfill generated 25,000 t CO2-e in the 12 months prior to applying to participate in the
CFI, so the project was demonstrated to capture 80% of methane generated and hence
passed the regulatory additionality test.
Step 1: Determine the regulatory baseline capture rate
The landfill operator seeks an assessment by a registered greenhouse and energy auditor.
The auditor states that the required gas capture to meet regulatory requirements is 65
per cent of the gas generated.
This means the regulatory baseline capture rate is 65%.
Rp = 0.65
Step 2: Calculate the quantity of methane destroyed under baseline conditions, i.e. the
project baseline (Areg), using equation 12 (note that for this project Bp = Rp)
n
Areg = γ ∑ Q com,h × 𝐁P
h=1
Areg = 𝟐𝟎, 𝟎𝟎𝟎 × 𝟎. 𝟔𝟓
Areg = 𝟏𝟑, 𝟎𝟎𝟎 t CO2-e
Step 3: Calculate avoided emissions (Ap) using equation 2
n
Ap = [(γ ∑ Q com,h ) − Areg ] × (1 − OF) − Ecom
h= 1
𝐀𝐩 = [𝟐𝟎, 𝟎𝟎𝟎 − 𝟏𝟑, 𝟎𝟎𝟎] × 𝟎. 𝟗 − 𝐄𝐜𝐨𝐦
𝐀𝐩 = 𝟔𝟑𝟎𝟎 − Ecom
20
Example 3 – Calculating Rp using the CFI Calculator
A project proponent uses the CFI Landfill Methane Regulatory Baseline Calculator to
determine the capture rate that corresponds with the allowable methane concentration that
applies to the landfill.
The proponent inputs data as indicated below:
CFI Landfill Methane Regulatory Baseline Calculator
Is the project new?
Yes
State/territory
VIC
Intermediate cover area
75,000 m²
Final cover area
210,000 m²
Total annual methane generation under NGER
methodology, i.e. CH4*
55,000 t CO2-e
Annual daily cover/operational area methane generation
under NGER methodology, i.e. CH4* (t CO2-e)
1000 t CO2-e
The calculator indicates that the required capture rate, being the regulatory baseline, is 66%
(Rp = 0.66).
21
Example 4 – Calculating and applying Rp for an upgrade project
A landfill operator is planning to upgrade an existing landfill gas capture system which
currently captures 40% of landfill gas, and participate in the CFI using the upgrades
methodology. The baseline capture rate for upgrade projects is the higher of the upgrade
baseline (1-∆𝐂) and the regulatory baseline capture rate.
Step 1: Determine the regulatory baseline capture rate.
The landfill operator uses the CFI Landfill Regulatory Baseline Calculator to work out how
much gas must be captured to keep within allowable methane concentrations. This indicates
that the proportion of methane capture needed to meet this requirement is 50 per cent.
The landfill operator also seeks an assessment by the relevant state or territory
environmental regulator. The state or territory regulator confirms that the current rate of
gas capture – 40 per cent – is sufficient to keep landfill gas within allowable methane
concentrations.
The regulatory baseline for the project is the amount assessed by the state or territory
environmental regulator as being sufficient to keep landfill gas within allowable methane
concentrations, which is 40 per cent (Rp = 0.4).
Step 2: Calculate the upgrade baseline capture rate.
A landfill operator upgrades the gas capture system and measures the new gas capture rate
as 45 per cent of the gas generated by the landfill.
The upgrade baseline for this project is calculated as 1 – ∆𝐂, where ∆𝐂 is equal to the
proportion of the methane from landfill waste captured and destroyed that is attributable to
the upgrade, calculated as the difference between the capture rate before and after the
upgrade, as a proportion of the current capture rate ( ∆𝐂 = (𝐂𝐩𝐚 − 𝐂𝐩𝐛 ) ÷ 𝐂𝐩𝐚 ).
∆𝐂 = (𝟎. 𝟒𝟓 − 𝟎. 𝟒𝟎) ÷ 𝟎. 𝟒𝟓
∆𝐂 = 𝟎. 𝟏𝟏
1 − ∆𝐂 = 𝟎. 𝟖𝟗
Step 3: Determine the baseline capture rate (Bp), which is the higher of the regulatory
baseline and the upgrade capture rate.
The baseline capture rate for this project is the higher capture rate of 89% (Bp = 0.89).
Step 4: Calculate the quantity of methane destroyed under baseline conditions, i.e. the
project baseline (𝐀 𝐫𝐞𝐠 ), using equation 12. In this reporting period, the project captures
20,000 t CO2-e.
𝐧
𝐀𝐫𝐞𝐠 = 𝛄 ∑ 𝐐𝐜𝐨𝐦,𝐡 × 𝐁𝐏
𝐡=𝟏
22
𝐀𝐫𝐞𝐠 = 𝟐𝟎, 𝟎𝟎𝟎 × 𝟎. 𝟖𝟗
𝐀𝐫𝐞𝐠 = 𝟏𝟕, 𝟖𝟎𝟎 t CO2-e
Step 5: Calculate avoided emissions (Ap) using equation 2
𝐧
𝐀𝐩 = [(𝛄 ∑ 𝐐𝐜𝐨𝐦,𝐡 ) − 𝐀𝐫𝐞𝐠 ] × (𝟏 − 𝐎𝐅) − 𝐄𝐜𝐨𝐦
𝐡= 𝟏
𝐀𝐩 = [𝟐𝟎, 𝟎𝟎𝟎 − 𝟏𝟕, 𝟖𝟎𝟎] × 𝟎. 𝟗 − 𝐄𝐜𝐨𝐦
𝐀𝐩 = 𝟏𝟗𝟖𝟎 − 𝐄𝐜𝐨𝐦
23
Example 5 – Assessing the additionality of a project with qualitative and
quantitative requirements
A project was installed in October 2010 and applies to use the installations methodology. The
project is located at a landfill that is subject to a qualitative licence condition to control odour,
as well as a quantitative requirement in state landfill management guidelines limiting methane
concentration for intermediate and final cover surfaces to 500ppm.
Qualitative requirement
The Clean Energy Regulator is satisfied that the installation exceeds the minimum that could be
done to control odour and that the project exceeds this qualitative requirement.
Quantitative requirement
The project proponent provides outputs from the CFI Landfill Methane Regulatory Baseline
Calculator (Part 3.3 of these Guidelines) to demonstrate that the quantitative requirement
translates to a regulatory capture rate (Rp) of 0.65 (65%).
The Clean Energy Regulator seeks evidence from the proponent of past capture rate. The
proponent provides evidence that the project captured 15,000 t CO2-e since it was installed.
The proponent also uses the NGER solid waste calculator to determine that the amount of gas
generated by the landfill (CH4*) over the same period was 20,000 t CO2-e. This translates to an
actual capture rate of 75% (15,000 divided by 20,000), which exceeds the regulatory
requirement.
The project exceeds all regulatory requirements that apply, so the Clean Energy Regulator
determines that the project passes the regulatory additionality test.
24
Example 6 – Calculating the project reporting baseline for a new project
A new gas capture facility is installed at a landfill in 2011. This project applies the installation
methodology.
Under these Guidelines, the project is taken to have passed the regulatory additionality test
and have a regulatory baseline of 30 per cent. The landfill captures 15,000 t CO2-e in a year.
Regulatory baseline (Rp) = 30 per cent
Captured amount (γ ∑nh= 1 Q com,h ) = 15,000 t CO2-e
Step 1: Calculate the quantity of methane destroyed under baseline conditions, i.e. the
project baseline (Areg), using equation 12.
n
Areg = γ ∑ Q com,h × R P
h=1
Areg = 15,000 × 0.3
Areg = 4500 t CO2-e
Step 2: Calculate avoided emissions (Ap) using equation 2.
n
Ap = [(γ ∑ Q com,h ) − Areg ] × (1 − OF) − Ecom
h= 1
Ap = [15,000 − 4500] × 0.9 − Ecom
Ap = 9450 − Ecom
25
7 Glossary
Allowable flux rate - the maximum rate of landfill methane flux that can occur without the landfill
methane concentration exceeding the allowable methane concentration.
Allowable methane concentration - a concentration of landfill methane permitted to occur at a
landfill, stipulated in landfill guidelines established by state or territory environmental regulators.
Daily cover – the material normally used to cover a day's deposition of waste in an active landfill
area.
Final cover – the material usually used to cover previously active landfill waste disposal areas that
have reached final height and are unlikely to be used for waste disposal again.
Intermediate cover – the material normally used to cover previously active landfill working areas
that won't be used for waste disposal for an extended period of time - typically a few weeks to a few
months.
Landfill development approval – an approval for landfill development normally issued by a state or
territory planning authority, which specifies landfill design and development requirements.
Landfill guidelines – the regulatory guidelines setting out permitted levels of methane emissions
from landfill facilities, which are issued by state or territory environmental regulators.
Landfill licence – licences issued by state or territories environmental regulators or planning
authorities that contain landfill operating requirements.
Operational area – an active landfill area i.e. an area where waste has been placed, has not reached
final height and is not covered with intermediate and/or final cover.
Oxidation factor – the percentage of methane which oxidises within the landfill’s cover layers. The
oxidation factor for near surface methane in the landfill is 10 per cent (that is, 0.1).
Project baseline – the amount of methane destroyed under baseline conditions in a reporting
period.
Regulatory baseline – represents the methane that the landfill is required to capture by regulation,
or was required to capture at 24 March 2011, whichever is greater.
26
8 Reference documents
Carbon Farming (Capture and Combustion of Methane in Landfill Gas from Legacy Waste)
Methodology Determination 2012, Comlaw
National Greenhouse Energy and Reporting (Measurement) Determination 2008, Comlaw,
http://www.comlaw.gov.au/Details/F2009C00576
New South Wales Environmental Protection Agency, Environmental Guidelines: Solid Waste Landfill
(1996)
Northern Territory Government Department of Natural Resources, Environment, the Arts and Sport;
Guidelines for the Siting, Design and Management of Solid Waste Disposal Sites in the Northern
Territory (2010)
Queensland Department of Environment and Resource Management, Waste Disposal (ERA 60):
Monitoring Systems (2010)
Queensland Department of Environment and Resource Management, Waste Disposal (ERA 60):
Landfill, Siting, Design, Operation and Rehabilitation (2010)
Environmental Protection Agency South Australia, Environmental Management of Landfill Facilities
(municipal solid waste and commercial and industrial general waste) (2007)
Department of Primary Industries, Water and Environment Tasmania, Landfill Sustainability Guide
(2004)
Environmental Protection Agency Victoria, Best Practice Environmental Management: Siting, Design,
Operation and Rehabilitation of Landfills (2010)
Western Australian Department of Environment and Conservation, Best Practice Environmental
Management: Siting, Design, Operation and Rehabilitation of Landfills (2006)
GHD, Draft CFI Methods (2011)
27
Appendix A: Using the Carbon Farming Initiative Landfill
Methane Regulatory Baseline Calculator
The regulatory baseline calculator is available from the CFI website and can be used with standard
spreadsheet software. The Calculator is designed to assist project proponents to calculate the regulatory
baseline capture rate (Rp) as described in Part 3 of these Guidelines. The calculator automates the manual
calculation of Rp, which is set out in Appendix B.
Input fields
Note: not all fields require input - the calculator will ensure only necessary data is requested.
The following list contains the fields for input:












Is the project new?
Is this an existing project transitioning from GGAS (NSW or ACT)?
Is this an existing project transitioning from Greenhouse Friendly?
Is this an existing project transitioning from Cities for Climate Protection?
Has the landfill operator been subject to guidelines for waste management and landfills, or
has a licence condition or development approval, which includes, or has had at any time since
24 March 2011 included, any form of qualitative requirement to capture, control, manage or
limit landfill gas, methane, odour or greenhouse gases, or to plan to do any of those
activities?
If you want to adopt, as the quantitative requirement, a level of landfill methane capture
required to comply with the highest specified limits for methane concentrations that have
been in place since 24/03/11, supplied by the relevant state or territory environmental
regulator or greenhouse and energy auditor registered in accordance with s75A of the NGER
Act 2007, please input the proportion of methane generation that must be captured
(proportion).
If you want to adopt, as the quantitative requirement, a rate of landfill methane captured
during 12 months prior to the project, that the relevant state or territory environmental
regulator confirms is compliant with the specified limits for methane concentrations or is a
result of adopting all practicable measures to keep within the specified limits, and regulatory
requirements have been unchanged since 24/03/11, please input the actual proportion of
methane generated that was captured (proportion).
State/territory.
Intermediate cover area (m2).
Final cover area (m2).
Total annual methane generation under NGER methodology, i.e. CH4* (t CO2-e).
Annual daily cover/operational area methane generation under NGER methodology, i.e. CH4*
(t CO2-e).
Calculating methane generation and capture
28
Values for methane generation and capture are needed to estimate regulatory baselines and these values
must be estimated using the National Greenhouse and Energy Reporting (Measurement) Determination
2008 methodology for solid waste disposal on land. The NGER solid waste calculator is available to assist
with calculating methane generation. The NGER solid waste calculator and the accompanying user guide
are available at http://www.cleanenergyregulator.gov.au/National-Greenhouse-and-EnergyReporting/Forms-and-calculators/Pages/default.aspx.
Total annual methane generation and annual methane generation from daily cover/operational areas
should be calculated separately using the NGER solid waste calculator. Modelling for annual methane
generation from daily cover/operational areas must only include waste vertically below the daily
cover/operational surface area.
Incorporation of methane concentration limits contained in landfill guidelines
The regulatory baseline calculator determines a proportion for regulatory requirement based on methane
concentration limits within landfill guidelines and their corresponding methane flux rates. Tables 3 and 4
in Appendix B of these Guidelines show the methane concentration limits and flux rates by state and
territory. This proportion for regulatory requirement based on methane concentration limits is then used
as in input for determining the regulatory baseline (Rp) for the project.
29
Appendix B: Method for calculating regulatory
requirement using methane concentration limits (ppm)
contained landfill guidelines
The method outlined below enables project proponents to manually calculate the regulatory baseline
capture rate (Rp) in accordance with Part 3 of these Guidelines. Tables 3 and 4 (below) set out limits for
allowable methane concentration and flux rate as inputs for these calculations. Further information on
how the values in these tables were derived is set out in 3.3. Please note that these calculations are
automated in the CFI landfill regulatory baseline calculator, as set out in Appendix A.
Table 3: Final cover regulatory methane concentration and
corresponding flux rates
State/territory
Allowable
methane
concentration
(CH4 ppm)
Allowable flux
rate (g
CH4/m2/hr)
estimated from
CH4 ppm
NSW
500
2.5
VIC
100
0.3
QLD
500
2.5
WA
500
2.5
SA
N/a
N/a
TAS
500
2.5
ACT
100
0.3
NT
N/a
N/a
Table 4: Intermediate cover regulatory methane
concentration and corresponding flux rates
30
State/territory
Allowable
methane
concentration
(CH4 ppm)
Allowable flux
rate (g
CH4/m2/hr)
estimated from
CH4 ppm
NSW
500
2.5
VIC
100
0.3
QLD
500
2.5
WA
500
2.5
SA
N/a
N/a
TAS
500
2.5
ACT
100
0.3
NT
N/a
N/a
Step 1: Determine permitted methane emissions for the final cover area
(i) Determine the allowable methane flux rate (t CO2-e/m2/hr) using Table 3 and the methane
concentration limit set by the relevant landfill guideline for the final cover area.
(ii) Calculate the product of the figure from (i), the final cover area (m2) and 8760 (number of hours
in a year) to determine the total annual allowable methane emissions from the final cover area
(t CO2-e).
(iii) Divide total annual allowable methane emissions by 0.9 to determine the permitted methane
emissions for the final cover area.
Note This accounts for 10 per cent of methane generated which is oxidised in the landfill cover layer as
opposed to being emitted.
Step 2: Determine permitted methane emissions for the intermediate cover area
(i) Determine the allowable methane flux rate (t CO2-e/m2/hr) using Table 4 and the methane
concentration limit set by relevant landfill guidelines for the intermediate cover area.
(ii) Calculate the product of the figure from (i), the final cover area (m2) and 8760 (number of hours
in a year) determine the total annual allowable methane emissions from the intermediate cover
area (t CO2-e).
(iii) Divide total annual allowable methane emissions by 0.9 to determine the permitted methane
emissions for the intermediate cover area.
Note This accounts for 10 per cent of methane generated which is oxidised in the landfill cover layer as
opposed to being emitted.
Step 3: Determine permitted methane emissions for the daily cover/operational area
Landfill guidelines do not currently set limits on methane emissions from daily cover areas. The permitted
methane emissions for the daily cover area must be determined using a different procedure to the one
set out in Steps 1 and 2.
Assumption For the purposes of these Guidelines it is assumed that the emissions through the
daily cover area must not exceed the quantity of methane generated by waste vertically below the
daily cover/operational area.
Estimate the quantity of methane generated from waste vertically below the daily
cover/operational area for the year preceding the project, in accordance with the National
Greenhouse and Energy Reporting (Measurement) Determination 2008.
Note The NGER solid waste calculator can be used by only including the quantity of waste vertically below the
daily cover/operational area. This calculation is the maximum allowable quantity of methane emissions from
the daily cover/operational area.
Step 4: Obtain total annual methane generated for the landfill using the National Greenhouse and
Energy Reporting (Measurement) Determination 2008
Estimate the total quantity of methane generated from waste in the landfill in accordance with the
National Greenhouse and Energy Reporting (Measurement) Determination 2008.
31
Note The NGER solid waste calculator can be used by inclusion of all landfilled waste.
Step 5: Determine total annual permitted methane emissions for the landfill
Sum the permitted methane emissions for the final, intermediate and daily cover/operational
areas.
Step 6: Determine total methane that must be captured to meet landfill guidelines limits
Deduct total permitted methane emissions from total methane generated.
Step 7 Calculate regulatory requirement to meet landfill guidelines methane concentration limits
Regulatory requirement = Methane captured to comply/Total methane generated.
32
Appendix C: Methane emission pathways for estimating regulatory requirements
Allowable intermediate
cover emissions =
State/Territory Landfill
guidelines flux.
Allowable emissions from final and intermediate cover
penetrations and landfill gas treatment technology
assumed to be nil.
Allowable daily cover/operational
area emissions = methane
generated from waste vertically
below.
Final cover permitted
emissions = State or
Territory Landfill
guidelines flux.
Allowable sub-surface
service emissions
assumed to be nil.
33
Sub-surface geology emissions
assumed to be nil.