Download Summary of Feedback and Responses

Summary
Alberta Climate Change Office
Draft Quantification Protocol for Aerobic Composting – Summary of Feedback and Responses
The draft quantification protocol for aerobic composting was posted for 30 day public comment on May 15, 2016. This table is a summary of the comments received from the comment
period and the government response.
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5.4.2
Nature of the Comment/Question
Comment
Technical
How is a proponent expected to get the information to support what landfill the
waste previously went to? For example most restaurants may contract a waste
hauler to collect all of their waste but it is not of their concern to determine
where it is going. This information will be unavailable for most proponents who
want to use the protocol. The destination should be identified as the closest
landfill in distance. Intuitively, for a waste hauling company to reduce their
costs, it will travel the shortest distances.
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Technical
5.5
Alberta Climate Change Office Response
The requirement in 5.4.2 is to keep a daily log of the landfill the
waste would have went to if it was not received at the composting
facility, not the landfill that the waste previously went to. The
purpose of this requirement is to demonstrate that the waste
would have gone to landfill in the absence of the composting
facility.
In many areas of Alberta (specifically the capital region) the
closest landfill is not necessarily the destination landfill.
3 years of baseline data is not possible. Waste haulers do not keep logs like this The intent of the records requirement is that there are records
available to demonstrate that the waste was disposed of at a
and they are even less likely to hand them to their now competitors who are
landfill for three years prior to the offset project. The wording of
now creating compost. The baseline should be identified based on what is
required within a municipal jurisdiction. Ie) If municipality has no waste diversion record requirements in Section 5.5 was clarified to reflect this
intent.
requirement, the baseline can be identified as landfill without records.
This is required to prove that the material is being diverted from
landfill and therefore resulting in additional greenhouse gas
emission reductions.
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42
Jan 18, 2017
5.5.1
Technical
Many users of the protocol will not be able to attain proof that materials were
landfilled other than affidavits from their clients. Some of their clients may have
old contracts with waste haulers but they will not state where the waste is going.
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
Section 7 of the Specified Gas Emitters Regulation requires that
emission offsets are real and demonstrable, quantifiable and
measurable. The requirement in the protocol to demonstrate
baseline disposal practice supports real and demonstrable
emission offsets.
Please see response #2.
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Alberta Climate Change Office Response
Comment
All waste going to an aerobic composting facility would be eligible because they
are diverting the organics from a waste stream going to landfill.
I would suggest consulting companies like XXXX or other aerobic composters to
understand how their collection business works and how they convinced clients
to let them collect their organics.
Editorial
Section 3.1.5 could not be found in the protocol
Corrected
5
40 and 5.4.6 bullet
41
1,2,3
27, P12 Table 4
6
28, P14 Table 4
Technical
7
19
Editorial
8
Pg 29 Inclusion of Technical
P13 Residual
Processing
Jan 18, 2017
Figure 4
Technical
If transportation of residuals to landfill are to be included as a project source,
why wouldn't transportation of organics to landfill be included as a baseline
source? At XXXX, all waste is brought to the transfer station. The organics are
composted on site. Thus, the composting activity results in GHG avoidance
from not transporting organics to landfill.
Transportation of organics to landfill in the baseline condition is
excluded because the emissions from transportation are likely
functionally equivalent in the baseline and the project scenario.
For example, in the baseline scenario the waste would be
transported to the landfill and in the project scenario the waste is
transported to the compost facility. If a project is in a situation
where transportation emissions are not functionally equivalent
they may apply for a deviation to the protocol. Please see the
Technical Guidance for Offset Project Developers for procedure
to request a deviation.
Excluding P14 is contradictory to the requirement on Pg. 42, ll.10-11 to
Removed the requirement to complete composition of residual
complete annual composition of residual streams. Some organics are expected streams.
in residual streams when mechanical screening is used; previously, the
emissions from the disposal and decomposition were included.
Figure 4 is supposed to be the Project Condition SS, but the actual figure is for Corrected.
the Baseline Condition
Residuals (non organic) are accepted ‘as is’ from landfills and no processing is
needed. This source should be excluded as these non-organic residuals are not
additional from composting (i.e. they would occur regardless and is outside of
the scope of the project).
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
In some projects the emissions from mechanical processing to
separate residuals from the compost are additional when
compared to the baseline. If a project does not have emissions
from processing residuals or the residual processing is outside
the scope of the project the project developer can outline and
justify this in the project plan. The wording for justification for why
it is included changed to “included as the emissions from
mechanical processing of residuals in the project are expected to
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Comment
Alberta Climate Change Office Response
be more than the baseline condition”
9
Pg 42, -compostion
II. 10- of each
11
residual
streams
Technical
Not sure how this information relates to the quantification protocol – there is no Removed the requirement to complete composition of residual
streams.
direct equation etc.
10 Pg. 32 P7 Anaerobic Technical
digestion in
the
composting
facility
Method:
“Direct
measurement
of mass of
materials
composted on
a wet weight
basis (60%
moisture)
60% is based on default values from IPCC. Current measurement is of waste as Correcting for moisture content is required to ensure that the
weight of eligible waste received is measured in a standardized
received. Would correction to 60% moisture be required?
way. Higher moisture content may result in over crediting.
11 Pg 39 Best
Technical
management
practices for
composting
projects
Are the reporting requirements for this reasonable?
12 Pg 40- Section 5.4.6 Editorial
41
Section 3.1.5 was referred multiple times. There is no Section 3.1.5., should be Corrected.
Section 5.4.5.
13 Pg 41
Section 5.2.2 was referred. There is no Section 5.2.2.
Corrected.
There is a statement that no flexibility is allowed. However in Table 6 it states
Reference to Appendix B removed.
Section 5.4.7 Editorial
14 Page 7 Section 1.3
Jan 18, 2017
Technical
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
It is important that the composting facility follow these best
management practices to ensure the waste is decomposing
aerobically.
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Comment
there is a flexibility process in Appendix B.
Alberta Climate Change Office Response
15 Page
41, ln
41
Record
Technical
Requirements
There is now a requirement for 3 years of raw baseline data. This is an
Please see response #2
unrealistic request. Owners of this historic data such as competing haulers,
public and private landfills, will either not have the tonnage data linked back to
the generator of the materials and most certainly will not be willing to share the
information. Additionally, even with a willing source, obtaining the original
paperwork (scale tickets, etc) from that historical length of time will be
impossible. At best the raw data may be summarized in a digital format.
16 Page
41, ln
41
Record
Technical
Requirements
Why is 3 years of baseline data required? One year of data from the
Please see response #2.
commercial waste generator in the form of past invoices showing the landfill
charges combined with a formal letter from the generator of the waste should be Attestation is not accepted in the Alberta emission offset system.
ample evidence of landfill diversion.
17 Page
45
No appendix Technical
B
A baseline flexibility process is referenced in Table 6 on pg. 37.
18 41
Records
19 Page 5.4.2
39,
Line 31
Removed reference to Appendix B.
Technical
It will be impossible to get 3 years of historical data – this is a new process for Please see response #2.
everyone.
Technical /
We haul our own waste and pick up from clients on a weekly basis. While we
The date and time the compost is delivered to the site is
Overarching keep records of the date and weight of feedstock arriving, it is not feasible for us important to ensure that the waste is incorporated into the
to develop a verifiable process to track the exact timing of when our employee compost in the required timeline. The completion of the
drops specific bins. As a self hauler, the time of delivery should not play a
information in Table 8 of the protocol will document that this
substantial role in our ability to operate. Operations that have no control over
requirement has been met.
the hauling aspect would need more detailed information than a vertically
integrated organization such as ours.
In addition, we receive mulch from a variety of local arborists and use this as a
supplemental ingredient, but confirming the date and time of drop-offs seems
unnecessarily onerous. Mulch will not turn anaerobic, therefore, the exact timing
of delivery does not contribute to a better or more environmentally friendly end
Jan 18, 2017
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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21 Page 5.4.3
40,
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22 Page 5.4.3
40,
Line 9
Jan 18, 2017
Nature of the Comment/Question
Comment
product.
Alberta Climate Change Office Response
Technical /
As a small business serving 38 food merchants, including several franchisees The emission offset in this protocol is for the emission reductions
Overarching with operations all over the city, it isn't feasible or, in many cases, even possible from avoidance of waste going to landfill. In order to compare the
to obtain 3 years of landfill data. This requirement favors large operations who project condition to the baseline condition the project developer is
have been hauling for many years (and who likely started by hauling to the
required to demonstrate that the waste is indeed being diverted
landfill rather than composting) and would have been tracking this information, from a landfill.
and makes it very difficult for innovative, small start-up companies to claim
credits.
Section 7 of the Specified Gas Emitters Regulation requires that
emission offsets are real and demonstrable, quantifiable and
measurable. The requirement in the protocol to demonstrate
baseline disposal practice supports real and demonstrable
emission offsets.
Technical /
CCME Guidelines for Compost Quality already exist and are being followed by The requirement in Section 5.4.3 is to develop a plan to ensure
Overarching Hop's composting operation. For us to develop an auditable tracking system
that waste is incorporated in appropriate timelines and ensure
that proves incorporation within 72 hours would require a significantly complex that waste is not decomposing anaerobically. The protocol is only
process that adds little value. We adhere to the CCME guidelines for compost requiring projects to demonstrate how they are meeting CCME
production and by creating a new standard the protocol makes claiming carbon requirements and if the project is already meeting CCME
credits not feasible for our operation. Additionally, if this standard is suggesting guidelines, there should be no additional effort t.
that within 72 hours food waste becomes anaerobic, commercial food waste
haulers should then be tracking every single establishment from the time food
waste hits the bin to the time it gets incorporated into the composting process
(not just from when it arrives at the facility). Based on this, it seems that this
requirement is penalizing organizations that pick up more frequently vs. letting
compost sit in a bin at a client site until they are able to incorporate it.
Technical /
Our business model is focused on taking food waste and creating compost
The purpose of this requirement is to ensure that waste is not
Overarching through in-vessel technology. We do our own pickups, often multiple times per decomposing anaerobically while waiting to be incorporated.
week, and aim to incorporate waste into our composting process as soon as
possible. This guideline, which again is outside of what is require by the CCME
regulations, seems to favor large, windrow style composting operations who
have been operating for many years. To provide an auditable C:N ratio (which
varies week to week and throughout the year) the process would require that
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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24 Page 5.5
41,
Line 41
25 Page 5.5
42,
Line 4
26 Page 5.5.1
42,
Line 20
27 Page 7, “Ineligible
line 14 project
conditions”,
bullet 3
Jan 18, 2017
Nature of the Comment/Question
Alberta Climate Change Office Response
Comment
bin contents be blended into a paste and tested each and every time. This is
onerous, unnecessary, and economically unfeasible for a small operation. The
C:N ratio of our compost is consistently tested, exceeding the requirements of
the CCME.
Technical /
Our process includes the following: bins are labelled by client, weighed, and
The composting facilities that are likely to use this protocol vary
Overarching dated upon arrival at our facility. It is unclear whether this labelling system is
significantly in their process and size. Prescriptive requirements
sufficient to meet the "composting facility best management practices". We
in the protocol may be unnecessarily limiting. The requirement in
recommend that the protocol be more prescriptive around the requirement that Section 4.4.4 is to have a system for labeling materials and for
documentation contain "sufficient detail to enable a third party verifier to assess the system to be verifiable. Obtaining an opinion from a verifier
eligibility of waste", keeping in mind the feasibility and economics of operating a may be a useful tool for determining if your specific system is
small inner-city composting facility (see comments above).
verifiable.
Technical /
Again, the requirement for a minimum 3 year baseline favors large operations Please see response #2.
Overarching who have been operating for a long time and who likely started by hauling to the
landfill rather than composting. As an innovative start-up, our clients don't have
this data, and this requirement will make it impossible for any small composting
operation to claim credits.
Technical /
Because we haul our own waste and measure it on site, we do not have weigh Table 8 in the protocol provides an example of the type of
Overarching scale tickets. We do, however, have a process that includes balances and
information to be included for recording the waste accepted at
checks to ensure the ability for verification. The above criteria (5.4.2 Eligible
the composting facility.
Waste Acceptance) references "on-site scales and/or commercial receipts", and
therefore this requirement is also not consistent with the above requirements. If
receipted weigh tickets are required, the protocol should contain increased
detail regarding the information that needs to be included on those tickets.
Technical /
Again, this seems overly onerous and to favor large operations, creating a
Please see response #2.
Overarching specific barrier to new entrants. This seems to make only public haulers eligible
for carbon credits, and not haulers / composting facilities that encourage waste The intent is to meet system requirements, not to favour a larger
diversion.
operator over a smaller operator.
Editorial
Section 3.1 should be section 5.4?
Corrected
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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Nature of the Comment/Question
Comment
Technical
The text says no additional flexibility is provided, but in Table 6 (Baseline
condition flexibility mechanism) on page 37, it indicates there is a flexibility
mechanism in Appendix B.
Alberta Climate Change Office Response
Corrected
29 Page
17
Figure 3:
Editorial
Process Flow
Diagram for
the Project
Condition
“P8: Electricity usage for Composting Operation”: this SS is referred to
Corrected
subsequently throughout the document as P24. Suggest consistent numbering.
30 Page
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Figure 4:
Editorial
Project
Condition
Sources and
Sinks for
Composting
Projects
The diagram present refers to the baseline condition. Project condition diagram Corrected
is omitted.
31 Page
32
Table 5, third Editorial
page, first row
of P7
(summary
equation)
“Emissions Material Treatment”: is this the former name of the SS?
Corrected to Emissions (CH4 and N2O from material treatment
anaerobic degradation in the composting facility)
32 Page
35
Table 5
Technical
Table 5 omits an equation for P12
Added equation for P12 to Table 5.
33 Page
35
Table 5
Technical
Table 5 omits an equation for P13
Added equation for P13to Table 5.
34 Page “Record
Technical
41, line Requirements
Jan 18, 2017
The requirement for “three years of raw baseline data” could be impossible. For Please see response #2.
example, if the baseline data were to be obtained from another organization, the
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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Nature of the Comment/Question
Comment
project developer may not have access to “raw” data specifically; it may be
digitized from its original form, compiled or otherwise summarized.
Alberta Climate Change Office Response
35 Page “Record
Technical
41, line Requirements
41
”
The requirement for “three years of raw baseline data” could be impossible.
Why is three years of baseline data required? Would one year of data be
sufficient to demonstrate that the organic waste that is presently being
composted was previously sent to landfill?
36 Page “Record
Technical
41, line Requirements
41
”
In the case of commercial landfilling and commercial composting, composters Please see response #2.
and conventional waste haulers are business competitors, and it is highly
Attestation is not accepted in the Alberta emission offset system.
unlikely that records proving the hauling of organic waste by a conventional
waste hauler will be shared in order to support a composting project. Therefore,
we suggest including clarity on the other types of records that could be
acceptable to form the baseline condition. For example, would the invoices
sent to the waste generator (i.e. a grocery store) for the removal of organic
waste by the hauler be sufficient? Could that be combined with a letter of
attestation from the waste generator (i.e. grocery store)?
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5.4.2
Technical
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41
5.5
Technical
How is a proponent expected to get the information to support what landfill the The requirement in 5.4.2 is to keep a daily log the landfill the
waste previously went too? For example most restaurants may contract a waste waste would have went to if it was not received at the composting
hauler to collect all of their waste but it is not of their concern to determine
facility, not the landfill that the waste previously went to. The
where it is going. This information will be unavailable for most proponents who purpose of this requirement is to demonstrate that the waste
want to use the protocol. The destination should be identified as the closest
would have went to landfill in the absence of the composting
landfill in distance. Intuitively, for a waste hauling company to reduce their
facility.
costs, it will travel the shortest distances.
In many areas of Alberta (specifically the capital region) the
closest landfill is not necessarily the destination landfill.
Bullet 4 was clarified to read: “the landfill from which the waste is
being diverted from”.
3 years of baseline data is not possible. Waste haulers do not keep logs like this Please see response #2.
and they are even less likely to hand them to their now competitors who are
Jan 18, 2017
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
Please see response #2.
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Comment
now creating compost. The baseline should be identified based on what is
required within a municipal jurisdiction. Ie) If municipality has no waste diversion
requirement, the baseline can be identified as landfill without records.
39 Page
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5.5.1
40 7
1.3 Flexibility Overarching Previous drafts had included text providing for flexibility.
City of Medicine Hat has approval for Bio solids, which otherwise is deemed a
non-eligible material.
The program requires flexibility for if other unforeseen and unique
circumstances arise.
Flexibility can be considered on a case by case basis, however
there are no general flexibility mechanisms provided in the
protocol.
41 29
4.1
Editorial
Formatting of the equation is difficult to follow.
Inserting a “return” after each “+” would make it easier read.
Corrected.
42 40
5.4.3
Editorial
Should “putrescible” be defined?
Putrescible was removed as the term eligible waste will address
this.
It appears what is deemed putrescible waste can differ.
Dictionary defines it as “liable to decay”, could apply to all organics.
Locally trees, branches, sawdust, and clean wood can be stock piled for months
before being mixed.
Will we need to test these stockpiles to demonstrate to an auditor that the pile
did not go anaerobic?
43 40
5.4.6
Technical
Not sure where to find the reference to “Section 3.1.5”
Corrected.
44 40
5.4.6
Technical
There are several references dealing with the CCME for composting.
The CCME requirements are relevant to this protocol because
Jan 18, 2017
Technical
Many users of the protocol will not be able to attain proof that materials were
Please see response #2.
landfilled other than affidavits from their clients. Some of their clients may have
old contracts with waste haulers but they will not state where the waste is going. Attestation is not accepted in the Alberta emission offset system.
All waste going to an aerobic composting facility would be eligible because they
are diverting the organics from a waste stream going to landfill.
I would suggest consulting companies like XXXXX or other aerobic composters
to understand how their collection business works and how they convinced
clients to let them collect their organics.
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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I recall this was discussed during the review. The CCME is relevant to ensuring
quality compost and good pathogen reduction, but this shouldn’t be required for
the GHG CO2e.
Adding the CCME requirements will significantly increase the amount of data
that will have to be quantified, verified, and then audited.
This is of concern. Consider the first audit on the local submission. Audit dealt
with 36 months of data. The Audit team examined every entry for all 36
months.
The Project XXXX’s passive windrow compost operation is frequently noncompliant with the letter of text within the CCME guidelines. We operate
throughout the winter when it is impossible to achieve 5 turns within a 15 day
period because each time the windrow is turned, the outer 150 to 450 mm of
material is often frozen. It may take 5 turns within 35 days as it requires several
days for the frozen material that is churned into the center of the row to thaw
and achieve the 55 degree.
Alberta Climate Change Office Response
some requirements ensure that an aerobic composting process is
occurring and that the waste is not anaerobic. The protocol is
only requiring projects to demonstrate how they are meeting
CCME guidelines and if the project is already meeting CCME
guidelines, there should be no additional effort t. If projects are
unable to meet CCME guidelines due to extreme weather,
explanation and justification should be provided in the offset
records and documentation.
45 41
5.4.7
Technical
The CQA testing frequency for compost is close but doesn’t match the 1 sample The protocol references CCME guidelines for compost.
per 1000 tonnes. This frequency will exceed the CQA requirements.
46 37
Table 6
Technical
What is meant by “no leakage”?
Leakage occurs when the implementation of an activity or project
What is meant by “permanence”? Does this mean that the documents cannot shifts emissions upstream or downstream of the project
boundary. Leakage occurs if there is no net reduction in
be edited? Cannot be edited without leaving a trail? Must be re-producable?
emissions resulting from the activity and instead emissions are
shifted.
Permanence is the likelihood of reversal associated with an
emission reduction. Permanence is only applicable in
sequestration and capture projects (e.g. wild fire burning trees in
an afforestation project) so this requirement was deleted from
Table. 6.
Jan 18, 2017
Summary of Comments/Responses for the Aerobic Composting Protocol
© 2017 Government of Alberta
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