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

CORPORATE
CARBON
…NEW MARKET SOLUTIONS

30 November 2021

Emissions Avoidance Methods

Method Development and Purchasing Branch | Scheme Operations Division

methoddevelopment@cleanenergyregulator.gov.au

CC: methoddevelopment@cer.gov.au

Re: 2021 Biomethane method package

Dear CER Method Development and Purchasing Branch,

Thank you for the opportunity to comment on the proposed 2021 biomethane method package
under the Emissions Reduction Fund.

Corporate Carbon is actively engaged across all major sectors of the Australian Emissions
Reduction Fund (ERF). We value the efforts made by the ERF to work together with key
stakeholders on the development of the 2021 biomethane method package, and to communicate
the importance of this method package to the broader community who aim to develop and promote
biomethane projects.
Our specific comments in relation to the proposed 2021 biomethane method package are provided
below. Please let me know if I can provide any additional information in relation to this submission,
or if you would like to discuss this submission in further detail.

Sincerely,

Gary Wyatt

Managing Director

Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000  AFS Licence No: 430199
 1300 227 206  info@corporatecarbon.com.au  www.corporatecarbon.com.au
1. Recognising possible leakage arising from claiming displacement abatement from existing
biogas projects that generate useful heat and/or electricity and divert this biogas to
biomethane production due to project implementation

How are the emissions from heat and/or electricity delivered by existing biogas projects accounted
for when that biogas is diverted to biomethane production? If the biogas is only flared to the
atmosphere, then there is no displacement abatement attributed to the combustion of biogas.
However, if a fraction of the biogas produced is currently used for heat and/or electricity production,
then another energy source will be required to deliver the respective level of energy if it is displaced
to biomethane production. If that is the case, this type of carbon leakage effect needs to be
accounted for when estimating displacement abatement from expanding biomethane projects.

2. Including agricultural wastes in the eligible types of waste for biomethane production

We support conducting further research work required to allow for the inclusion of agricultural
wastes as eligible biogas wastes that can be digested and further refined for biomethane production

3. Continuing with AWT and SSOW biomethane method variations
We support developing the biomethane method variations for the Alternative Waste Treatment
(AWT) and Source Separated Organic Waste (SSOW) methodology determinations in early 2022.

4. Including solid food waste as eligible wastewater in the proposed Carbon Credits (Carbon
Farming Initiative—Domestic, Commercial and Industrial Wastewater) Methodology
Determination Variation 2021

Solid food waste can be processed in water treatment systems. There may be some cases in which
this activity results in carbon abatement.

Corporate Carbon Group of companies including Corporate Carbon Advisory Pty Ltd
ABN 77 149 699 543  Suite 4, Level 16/25 Bligh St, Sydney NSW 2000  AFS Licence No: 430199
 1300 227 206  info@corporatecarbon.com.au  www.corporatecarbon.com.au