On Friday June 1, the Market Advisory Committee released a draft of their recommendations for the potential design of a market system under AB 32 (available on our documents page). Among the many strategic recommendations for designing a market, the MAC recommends excluding all biologic processes, including fugitive methane from landfills.
The report suggests that due to the difficulties in monitoring biological emissions such as fugitive landfill gas emissions, the market cap should exclude all emissions from biological processes. However, despite fugitive landfill emissions not being included under the market cap, the MAC suggests energy produced from landfill gas would still be eligible for carbon offsets. The committee's recommendations explicitly state that "projects that capture landfill and digester gas could be incorporated in an offsets program or through other regulatory measures."
Landfill operators will be able to reap the benefits of an offset program from landfill gas to energy but experience no negative consequences for the increase in their fugitive emissions resulting from the additional organics disposed. CAW opposes this MAC recommendation:
- By allowing carbon offsets to be allocated for landfill gas, the landfill operator will have a direct monetary benefit to producing more landfill gas.
- Since the additional fugitive emissions from landfills would not be included in the cap, this would likely result in an increased demand for organics at landfills and subsequently a lower tipping fee for greenwaste at landfills.
- Lower tip fees at landfills will divert additional organics away from compost facilities. Composting is a significant greenhouse gas emission mitigation measure because it results in greater carbon sequestration in crop biomass, a decrease in the need for GHG-releasing fertilizers and pesticides, and a decline in energy-intensive irrigation.
- A net increase in GHG emissions may result because landfill gas capture systems only capture a fraction of the landfill gas generated. The IPCC estimates that lifetime efficiencies are as low as 20% for landfills.
- Most landfills are already required to capture and destroy their fugitive emissions. Giving offset credits for these systems would violate the additionally requirements of a market system. Companies should not be able to sell credits for something that they are legally required to do because it would not result in any further greenhouse gas reductions.
- The adoption of these recommendations directly conflicts with existing state waste reduction and recycling programs and policies. The Integrated Waste Management Act states that recycling and composting are to be prioritized over landfill disposal and that the state should maximize recycling and composting. These recommendations would take us a step backwards in waste reduction and composting.
Offsets from landfill gas to energy should not be supported until the ARB establishes that the offsets are additional and would result in a net decrease of GHG emissions from landfills and provide an overall environmental benefit to
June 12: The Market Advisory Committee will be holding a public hearing on their proposed recommendations.
June 15: The Air Resources Board will be holding a landfill group technical discussion.
Time: (Pacific Time)
Location: Training Room 1, 1st Floor of Cal/EPA Headquarters