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Proposed National Environmental Standard to Control Greenhouse Gas Emissions from Landfills Resource Management Act Section 32

Executive Summary

1 Introduction

2 Statement of the Issue

3 What are the Options?

4 The Proposed Landfill Gas Standard

5 Efficiency and Effectiveness of the Proposed Standard

6 Summary of Findings

References

Appendix 1: Landfill Base Data

Appendix 2: Emissions, Benefit and Cost Model Spreadsheets

3 What are the Options?

3.1 Introduction

There are a number of different national policies that could be applied to manage greenhouse gas emissions from landfills. These range from continued guidance, economic instruments, climate projects, national environmental standards, through to the 'do nothing' and status quo.

The following sections set out these options and look at their appropriateness for achieving the stated objectives for landfill gas emissions.

3.2 Determining the most appropriate option

In order to find the most appropriate option for controlling landfill gas emissions, the Ministry has considered a list of potential options. These have been analysed, and for the purposes of this report only the following options have been considered in detail:

• Option 1: status quo (the current situation - the baseline in the analysis)
• Option 2: guidance and climate change projects
• Option 3: economic instruments (charging and permit trading)
• Option 4: preparation of national environmental standards.

3.2.1 Option 1: Status quo

Prior to the introduction of the Resource Management (Energy and Climate Change) Amendment Act 2004, the majority of regional councils were requiring large landfills to collect and destroy methane. However, the Amendment Act removes the ability of regional councils to consider the effects on climate change from air discharges, which means there is no certainty that regional councils will continue to place controls on landfill gas emissions.[Note that regional councils could still require management of landfill gas for health and safety and nuisance impacts.]

For the purpose of this analysis, 'status quo' refers to the Government continuing with its promotion of best practice through advocacy of the Centre for Advanced Engineering's Landfill Guidelines, and regional councils not being able to consider the effects of climate change from air discharges.

Tables 1 and 2 set out two types of analysis. Table 1 examines the advantages and disadvantages of the option while Table 2 looks at whether the option achieves the stated objectives.

Table 1: Advantages and disadvantages of the status quo option

Table 2: Assessment of status quo against the objectives

This option clearly does not achieve the stated objectives. However, the use of this option as a baseline in the analysis is crucial in comparing the benefits and costs of other options.

3.2.2 Option 2: Status quo plus climate change project mechanism

This is similar to the status quo, but with the inclusion of the climate change project mechanism. The climate change project system means applicants can apply for a grant of carbon credits if they have a project that will decrease the amount of greenhouse gas that would have otherwise been emitted into the atmosphere when compared to business as usual. In turn, these project operators can sell these credits to other nations who produce more carbon than their quota, thus generating income. A number of landfill operators have recently received credits, and this option assumes that a similar process continues into the future.

Tables 3 and 4 set out two types of analysis for this option. Table 3 examines the advantages and disadvantages of this option, while Table 4 looks at whether the option achieves the stated objectives.

Table 3: Advantages and disadvantages of the 'status quo plus projects' option

Table 4: Assessment of 'status quo plus projects' against the objectives

This option is not appropriate because it does not meet the crucial objective of establishing nationally based landfill gas management greenhouse gas emissions.

3.2.3 Option 3: Economic instruments (charging and trading)

This option would involve placing a tax or charge on landfill gas emissions, whereby a polluter is forced to pay a certain amount of money for every unit of pollutant emitted. The aim of such an option is to provide an economic incentive for landfill operators to minimise emissions and in this case divert organic waste or collect and flare their gas. This option may also form the basis of a tradable permit scheme.

The RMA supports investigating imposing financial charges, but the Act, on its own, would not facilitate the use of charges. Changes to existing legislation would likely to be needed. A question also remains over the ability to trade discharge permits.

Tables 5 and 6 set out two types of analysis for this option. Table 5 examines the advantages and disadvantages of this option, while Table 6 looks at whether the option achieves the stated objectives.

Table 5: Advantages and disadvantages of the 'economic instruments' option

Table 6: Assessment of 'emissions charge' against objectives

This option is not appropriate for a number of reasons. There are questions over its feasibility (particularly under the RMA in its existing form), and it does not meet the objectives of establishing nationally based landfill gas management greenhouse gas emissions to provide certainty for the waste management industry. If a tradable permit approach were found to be feasible, there would still need to be some sort of emissions cap (to establish a 'cap and trade' programme, for example). To sum up, as a stand-alone option the use of charging or a trading regime will not achieve the stated objectives.

3.2.4 Option 4: Preparation of a national environmental standard

The Resource Management (Energy and Climate Change) Amendment Act 2004 specifies the use of national instruments to control greenhouse gas emissions. The Act makes explicit mention of national environmental standards in this regard:

New section 70A removes the power of regional councils, in making rules on the discharge of greenhouse gases into air, to have regard to the effects of a discharge on climate changes ... new section 70B permits regional councils to make rules as necessary to implement a relevant national environmental standard made by regulation under section 43.

New section 104F provides, as a further exception to the prohibition in new section 104E, that regional councils may determine the specified applications that are necessary to implement a relevant national environmental standard made by regulation under section 43, but must be no more or less restrictive than the national environmental standard being implemented.

Due to the specific reference to national environmental standards within the Amendment Act, consideration of national instruments is restricted to the consideration of a national environmental standard, and not other alternatives such as national policy statements.

National environmental standards are regulations that set a national technical standard that all operators in the country are required to meet. The proposed standard sets a consistent national approach by specifying the requirement to collect and destroy landfill gas emissions for landfills over a million tonnes in capacity, unless the landfill contains less than 5% organic matter.

Tables 7 and 8 set out two types of analysis for this option. Table 7 examines the advantages and disadvantages of this option, while Table 8 looks at whether the option achieves the stated objectives.

Table 7: Advantages and disadvantages with the 'NES' option

Table 8: Assessment of 'landfill NES' against objectives

From the above it can be seen that this option meets the stated objectives and has a number of advantages. This option will, therefore, be taken forward the next step for further analysis.

3.3 Findings of the appropriateness test

The appropriateness test has assessed a range of options, setting out their relative advantages and disadvantages and whether each option can meet the stated objectives.

We found that only one option has the ability to meet the stated objectives: the national environmental standard option. This option is considered to be the most appropriate from the range of option assessed. Further analysis of this option will determine its effectiveness and efficiency.

3.4 The call for national environmental standards

As further support for the national environmental standard option, a number of events have led to calls from stakeholders for the Ministry to consider the introduction of standards.

• At a series of public meetings held in mid-2002, business, councils and community groups called on the Ministry to get on with developing a national policy approach for key resource management issues.
• A consultative process was held with regional councils to scope the policy programme needed to support a national approach.
• In May 2003 the Ministry for the Environment presented the concept of national environmental standards to regional council representatives, and feedback was positive.
• The Ministry for the Environment hosted a national roadshow to obtain further input from the community and key interest groups in November 2003. Feedback at the roadshow meetings was largely supportive of the proposed national standards.

3.5 Moving to the next stage in the analysis

Given the above tests and taking into account calls from stakeholders, the national environmental standards option has been taken forward for more detailed analysis. This is not to suggest that this is the only viable option, but it is the only option that meets the current stated objectives.

In order to test the effectiveness and efficiency of the national environmental standard option, the proposed standard is set out in summary in section 4. Section 5 then examines the costs and benefits associated with this option in order to determine its efficiency. The benefits will measure the effectiveness of this option to reduce greenhouse gas emissions from landfill sites.