Proposed National Environmental Standards for Landfill Gas

• 1 Introduction
• 2 Overview of Submissions
• 3 Detailed Submission Summary
• Appendix A: Public Notice
• Appendix B: Submitters
• Appendix C: Proposed Landfill Gas Collection and Destruction Standard - Fact Sheet

2 Overview of Submissions

2.1 Summary of submitters' positions

Eighteen submissions were received, of which 13 supported or conditionally supported the proposal, one opposed the development of the standard, and four gave no specific comment on their position.

Table 2.1 summarises the overall positions of the submitters, expressed as either:

• support
• conditional support
• oppose
• neutral.

Table 1: Submissions received, and overall position towards the proposals

View table of submissions received, and overall position towards proposals (large table)

2.2 Key themes

The following key themes were identified in submissions:

• There is concern from landfill operators (private and local authority) about the relationship between the standard and climate change mechanisms. There is concern that the collection and destruction of landfill gas for the purpose of compliance with the standard would be treated as "business as usual" and not "additional" for the purposes of climate change project incentive awards and/or emissions trading. This could affect the potential income from the Ministry for the Environment's emissions reduction programme or sale of carbon credits.
• Some submitters consider that the beneficial use of landfill gas (eg, in electricity production) has, or may have, net environmental benefits in excess of those gained from flaring alone. Therefore, a requirement to demonstrate equivalent or better destruction compared to flaring is considered to be onerous and restrictive.
• There are conflicting views on whether the standard should apply only to municipal solid waste landfills, and not cleanfills or construction and demolition waste landfills. Lack of a definition of "cleanfill" in the standard was raised as an issue, as was the potential need for the standard to apply to large closed landfills, which discharge significant quantities of methane.
• The application of a capacity threshold of 1 million tonnes design capacity was generally supported.
• The application of a flaring standard with a minimum temperature of 750 degrees Celsius and a residence time of 0.5 seconds was generally supported.
• The application of a surface emissions limit was generally supported. However, the proposed value of the limit being higher than current practice was raised as an issue, as were potential difficulties in consistent measurement.
• There were conflicting views on whether meeting the surface emissions limit should be used as an alternative to the installation of a collection and destruction system at some sites.

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