Biomethane method package: proposed new method activity under the Emissions Reduction Fund

Emissions Reduction Assurance Committee
Clean Energy Regulator
Department of Industry, Science, Energy and Resources
GPO Box 2013
CANBERRA ACT 2601

Email: methoddevelopment@cleanenergyregulator.gov.au

30 November 2021

Dear Sir/Madam

Re: Biomethane method package: proposed new method activity under the Emissions Reduction
Fund

Thank you for the opportunity to provide feedback on the Biomethane method package: proposed
new method activity under the Emissions Reduction Fund (ERF).

The Waste Management and Resource Recovery Association of Australia (WMRR) is the national peak
body for all stakeholders in the essential waste and resource recovery (WARR) industry. We have more
than 2,000 members across the nation, representing a broad range of business organisations, the
three (3) tiers of government, universities, and NGOs. Our members are involved in a range of
important waste and resource recovery activities within the Australian economy, including
infrastructure investment and operations, collection, manufacturing of valuable products from
resource recovered materials, energy recovery, and community engagement and education.

WMRR acknowledges that the federal government has, over the last few years, placed welcomed
emphasis on the role that the WARR sector can play in reducing carbon emissions and WMRR notes
that the ERF has been key in driving the abatement of CO2-e from the industry; in 2019-20, more than
15.5 million ACCUs were issued to the sector, with the cumulative total under the ERF being upwards
of 80 million.

The government’s recognition industry’s importance in driving carbon abatement has been further
emphasised in recent months, including through the release of the $67 million Food Waste for Healthy
Soils Fund, which seeks to put organic waste to productive use on our agricultural soils, rather than
going to landfill, as well as the recent release of the Bioenergy Roadmap, which lays out a vision for a
sustainable bioenergy industry that can help lower emissions, increase fuel security, enhance waste
recovery, and deliver economic benefits.

We welcome the Clean Energy Regulator’s work to deliver this biomethane package. The changes
proposed will provide greater flexibility to project proponents for how they commercialise renewable
gas that is captured through eligible project activity under the landfill gas electricity generation, animal
effluent, and wastewater treatment methods.
Within the scope of this existing package, WMRR observes that under current drafting, existing
projects that expand to biomethane activities will only be able to realise three (3) to four (4) years of
conversion abatement. It is doubtful that this amount of time will facilitate viable projects and risks
these desired biomethane projects not being able to proceed. Therefore, at least 12 years from when
a biomethane project is installed and commissioned should be enabled.

More broadly, it is submitted that greater effort is required to suitably build on the federal momentum
to abate carbon emissions utilising our essential industry. At this time, the proposed package only
focuses on the use of biomethane and not how it is created. However, in order to receive ACCUs,
consideration of how biomethane is created is imperative. With variations proposed for only three (3)
ERF waste methods – animal effluent management, electricity generation from landfill gas, and
domestic, commercial and industrial wastewater – there are still significant gaps that need to be
addressed to bring it into line with, and fully capitalise on, other federal initiatives such as the Healthy
Soils Fund.

Thus, WMRR makes the following recommendations that we hope the committee will take on board:

• As part of this package, anaerobic digestion (AD) of waste that uses biomethane will be eligible
for ACCUs; however, this does not apply to solid or food waste. It does not seem logical (or
productive) that solid and food wastes have not been included given these processes would use
biogas to displace natural gas, which is the aim of the package, i.e., to displace fossil fuel-based
natural gas with biomethane. At present, there are a number of existing AD facilities that utilise
this feedstock, e.g., Richgro in WA and Earthpower in NSW, along with others in development,
and while government asserts the benefits of biomethane, there remains a policy gap in driving
the continuation and development of facilities that will generate biomethane from solid or food
waste. We believe that there is an opportunity for the ERF to provide incentives to AD proponents
to use biomethane from solid and food wastes, which is lacking in the current package.
• An obvious gap that needs to be urgently looked at is allowing both the use and generation of
biomethane to receive ACCUs.
• As noted above, there is a strong federal push towards putting organic waste to productive use
on our agricultural soils, alongside the Clean Energy Regulator’s ongoing support for soil carbon
sequestration. In WMRR’s view, the committee should consider how it can align its work with
ongoing federal policy development (and funding commitments) to prioritise organic and
agricultural wastes in its ERF methodologies to reward the diversion of these materials from
landfills, and the resultant abatement of carbon emissions.
• Following from the point above, WMRR strongly encourages the committee to first and foremost
to continue its work in varying the Carbon Credits (Carbon Farming Initiative – Alternative Waste
Treatment (AWT)) Methodology Determination 2015 and the Carbon Credits (Carbon Farming
Initiative – Source Separated Organic Waste (SSOW)) Methodology Determination 2016 to include
biomethane activities.
• It is noted however, that the regulator has also decided not to allow for a crediting extension for
these methods. It is vital that current and future proponents that utilise the AWT and SSOW
methods are eligible to receive ACCUs for generation and use of biomethane and WMRR is urging
the committee to prioritise this work in 2022.
• WMRR also recommends urgent pursuit of the intended prioritised research in 2022 for rapid
inclusion of a broader set of agricultural wastes under the biomethane methods.

Please do not hesitate to contact the undersigned if you would like to further discuss WMRR’s
feedback.

Yours sincerely

Gayle Sloan
Chief Executive Officer
Waste Management and Resource Recovery Association of Australia