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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. # 1 Page Clause/ # Section 39 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. 2 41 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. 3 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. Page 1 of 10 Summary Alberta Climate Change Office # 4 Page Clause/ # Section Nature of the Comment/Question 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 Page 2 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section Nature of the Comment/Question 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. Page 3 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section Nature of the Comment/Question 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 Page 4 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section 20 Page 5.4.2 39, Line 34 21 Page 5.4.3 40, Line 6 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 Page 5 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section 23 Page 5.4.4 40, Line 20 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 Page 6 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section 28 Page 7 Section 1.3 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 19 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 Page 7 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section 41 ” 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)? 37 Page 39 5.4.2 Technical 38 Page 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. Page 8 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section Nature of the Comment/Question Alberta Climate Change Office Response 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 42 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 Page 9 of 10 Summary Alberta Climate Change Office # Page Clause/ # Section Nature of the Comment/Question Comment 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 Page 10 of 10