Under the prosed Safeguard Mechanism reforms, ALOA submits that the 75% collection efficiency cap built into NGERS has the effect of increasing emissions at landfills should the gas capture exceed modelled gas production. This ultimately increases emissions from landfills the more gas is collected.
ALOA makes the following key points:
- Amendments to the NGERS 75% capture efficiency cap must be implemented before landfills continue to be included in the Safeguard Mechanism.
- Landfill Gas ERF Methodology must be amended before landfills continue to be included in the Safeguard Mechanism.
- The interaction of the 75% capture efficiency and the Safeguard Mechanism can lead to unintended consequences, whereby landfills reduce actual gas capture in an attempt to not trigger the Safeguard Mechanism’s 100,000 tonne threshold.
- With consideration of the above, ALOA proposes that landfills’ participation in the Safeguard Mechanism be postponed until these issues can be appropriately consulted with industry, government and regulators.