GAIA's comments on CDM methodology ACM 0001

Problems with Clean Development Mechanism Waste Methodology ACM00011. IntroductionThe Clean Development Mechanism (CDM) was established not only to reduce emissions ascost-effectively as possible, but also to promote sustainable development and technologytransfer to developing countries. Unfortunately, in the case of the waste sector, considerableevidence indicates that the projects approved by the CDM are not achieving either goal;indeed, in many cases they are directly undermining both.In the case of waste management, the CDM supports downstream technologies rather thanupstream approaches. Downstream technologies seek to reduce emissions and produceenergy from waste after it is generated and they typically include waste incineration orlandfill options. On the other hand, upstream strategies prevent these wastes from beingdisposed in the first place and thereby open up the possibility of much larger GHG abatementthrough the reduction of emissions associated with raw material acquisition, manufacturing,and transportation (U.S. EPA, 2006; Hogg, 2006; Tellus Institute, 2008).The most salient example of such problems lies in the conflict between CDM waste disposalproject and the informal recycling sector. In most of the developing world, wastepickers 1recover recyclable material from the waste stream and return it to production via recyclingand re-manufacturing. The climate benefits of their activities are difficult to quantify but havebeen widely acknowledged, both in the academic literature and by the CDM board itself,through the approval of a small-scale plastics recycling methodology AMS-III.AJ.This methodology AMS-III.AJ, however, does not address the conflict that exists betweenCDM projects, which dispose of waste in incinerators and landfills, and the recycling sector.Waste pickers largely belong to the informal sector, which limits their ability to takeadvantage of CDM credits; even if they were able to do so, the credits available to them aredwarfed by the credits that accrue to large waste disposal firms. This may explain why theplastics recycling methodology has yet to be successfully applied to any projects.While some firms claim to dispose only “non-recyclable” waste, this is a myth; more than80% of the municipal waste stream is recyclable, including organics (Neamatalla, 1998).Landfills that generate income from landfill gas capture need to bury a high proportion oforganic waste – even as waste pickers increasingly employ composting and biogas to keeporganics out of landfills and prevent methane generation. Keeping organic waste out oflandfills has been recognised by the UNEP as the most cost-efficient manner to reduceemissions from the waste sector; yet by rewarding the production and capture of landfillmethane, the CDM is providing a perverse incentive to avoid the best method of emissionsreductions in favor of one of doubtful effectiveness.1 Wastepickers is the accepted English word to refer to the informal recycling sector amongst the wastepickersorganizations signing on this document; so, terms like scanvengers or rag pickers are considered pejorative andshall not be used. Moreover, wastepickers organisations in Latin America use their local names in theircommunications as regional network: barequeros in Colombia, pepenadores in México, sirujas in Argentina,catadores in Brasil, basuriegos in Peru and Ecuador, buceadores in Cuba, or generally, recuperadores orrecicladores.

Since CDM projects earn CERs in accordance with the amount of waste handled, there is alsoa financial disincentive to reduce waste disposal. This directly interferes with the livelihoodsof waste pickers – some of the poorest people in developing country cities – whosesustenance is predicated precisely upon reducing the amount of materials being wasted.While host countries are responsible for ensuring that a CDM project advances sustainabledevelopment goals, the CDM Executive Board has the responsibility to ensure that CDMprojects promote the best option for reducing emissions cost-effectively; therefore a CDMproject should not replace a cheaper and more effective option. Yet this is precisely whathappens when the CDM approves a landfill project: it displaces the most sustainable meansof solid waste handling.Methodology ACM0001 (Consolidated baseline and monitoring methodology for landfill gasproject activities) is an example of a CDM methodology that supports downstream solutionsrather than upstream ones. It contains methodological flaws that overestimate the amount ofGHG reductions that can be attributed to the CDM project. Even worse, several studiesindicate that forecasting the generation of landfill gases is highly complex, making itimpossible to accurately model or measure the amount of gas generated (Mueller et al.,2009).The purpose of this report is to bring to light problems with the methodology, recommendchanges to ensure that the calculation of greenhouse gas reductions using thesemethodologies are more accurate, and prevent the displacement of upstream strategies,especially when waste pickers are involved. We suggest that our <strong>comments</strong> on thismethodology be read together with our <strong>comments</strong> on AM0025 and the “Tool to determinemethane emissions avoided from disposal of waste at a solid waste disposal site” as theyjointly address many of the issues that arise in the CDM’s waste sector projects.The Global Alliance for Incinerator Alternatives (GAIA) is well poised to comment on theseCDM methodologies. We are a worldwide alliance of more than 600 grassroots groups, nongovernmentalorganizations, and individuals in over 82 countries whose ultimate vision is ajust, toxic-free world without incineration. GAIA’s members include scientists, waste pickersand campaigners who have built up a wealth of expertise regarding waste management issuesduring the past ten years of GAIA’s existence. We not only work to close incinerators,landfills, and other end-of-pipe technologies, but we also promote viable alternatives such asthe implementation of Zero Waste. GAIA submits this comment together with theSouthAfrican Wastepickers Association, the Red Latinoamericana de Recicladores(REDLACRE) and the Alliance of Indian Wastepickers (AIW).2. Critique of the Waste Methodology ACM0001The CDM methodology ACM0001 take a myopic view of waste management. Rather thansupporting waste reduction and separation at the source, it only deals with waste once itreaches the landfill. This is a very inappropriate way to deal with emissions from waste, asseveral studies have shown that landfill gas capture systems have very low efficiency rates,present severe impacts to the communities and the environment, and are not the mosteffective solution. Finally, CDM’s support to landfill gas capture systems through thismethodology becomes a perverse incentive to prevent further implementation of waste

eduction and recycling programs, which are the most beneficial for the economy, theenvironment and communities.This section will address particular elements of the methodology that should be revised toprevent further damage.2.1 The baseline scenarioIn its Fourth Assessment Report (2007), the IPCC recognized that “waste minimization,recycling and re-use represent an important and increasing potential for indirect reduction ofGHG emissions through the conservation of raw materials, improved energy and resourceefficiency and fossil fuel avoidance” (Bogner et al., 2008). In fact, recycling and compostingare activities that are occurring in developing countries. In Cairo, recycling rates reached tobe as high as 95% primarily through the contribution of the informal wastepicking sector(Drabinski, 2009).Yet, the projects that use this methodology rarely, if ever, account for recycling whencalculating the baseline against which emissions reductions are measured, as well asalternative scenarios. Thus these projects tend to displace the activities of waste pickers. Thiscreates significant negative economic impacts on the waste pickers themselves as well as theentire economy that depends on their work – the aggregators, wholesalers, resalers andremanufacturers (Schamber 2008, Schamber y Suárez 2007, Medina 2007).Moreover, the reduction in recycling results in an increase in overall GHG emissions that isnot captured by the methodology due to the exclusion of recycling from baseline calculations.As it has been pointed out in recent studies, waste recycling and composting provides moreemission reductions than collection and combustion of landfill gas with energy use (e.g.electricity generation), against the manufacture of new materials from virgin sources (Couthand Trois, 2010).Finally, costs increase because waste that was previously handled through the informal sectorbecomes the responsibility of the public sector; and the technologies employed are muchcostlier. The construction of a sanitary landfill itself requires significant resources, and theUS EPA has estimated that a 40-acre (160,000 m 2 ) landfill gas collection system with a flaredesigned for a 600 ft³/min extraction rate will cost $991,000 (approximately $24,000 peracre) with annual operation and maintenance costs of $166,000 per year at $2,250 per well,$4,500 per flare and $44,500 per year to operate the blower. More advanced systems,involving electricity production, involve additional capital and operating funds (US EPA2009).The role of the informal sector in resource recovery and associated climate change mitigationis largely overlooked in developing countries. Waste pickers require support to formcooperatives and organizations, access better equipment, negotiate direct access to wastesources, and generally improve their health, safety, and livelihoods. Municipal governmentsin developing nations need assistance to understand the value of the informal sector and toincorporate the informal sector in waste strategies.The potential for additional greenhouse gas emission reductions from expanded recycling andcomposting is also often overlooked – and is undermined when the projects that use thismethodology are not evaluated in comparison to a recycling-heavy approach toward waste

management (see recommendations regarding an M5 alternative scenario below). Thisapproach is feasible with appropriate regulation and technology transfer, as has been shownin the state of California, USA, where the California Integrated Waste Management Act (AB939, Sher, Chapter 1095, Statutes of 1989 as amended [IWMA]) made all of the state’s cities,counties, and approved regional solid waste management agencies responsible for enactingplans and implementing programs to divert 50 percent of their solid waste (through wastereduction, reuse, recycling, and composting programs). 2 As a result, this mandate has inspiredthe City of San Francisco, California to achieve a 77% landfill diversion rate in 2010 3 – andto establish a mandatory recycling and composting ordinance 4 that has contributedsignificantly toward getting methane-producing organic materials out of the remainingfraction of waste that is landfilled. 52.2 Identification of alternative scenariosCurrently, methodology ACM001 does not contemplate carrying out surveys of currentrecycling and composting practices (whether by informal sector or formal sector) in order toestimate current and potential reductions in GHG emissions through upstream methods.However, such surveys should be carried out and incorporated in the baseline, Step 1:Identification of alternative scenarios.In addition to the mentioned scenarios, two more alternative scenarios should be identifiedand analyzed. The current waste management system prevalent in developing country cities isnot adequately characterized by any of M1, M2 or M3; it therefore needs its own scenario toensure that, at a minimum, the project activity will not increase emissions relative to thestatus quo, which can be identified as M4. In particular, M4 must survey current recyclingpractices and analyze their climate impact through the use of a lifecycle assessment. Inaddition, M4 should pay special attention to the realistic fate of organics under the status quoand their methane generation rates. Current, informal practices of feeding household waste toanimal or backyard composting have been thus far neglected in project activity analyses ofbaselines, but must be documented to have a realistic picture. Alternate scenarios M1, M2and M3 must, in turn, also include an analysis of the impact on recycling rates and theresulting upstream GHG emissions.Even when project activities represent an improvement over current waste managementpractices, it is often far from clear that they represent the best feasible solution; often, theypreclude activities that would result in far fewer emissions. A case in point is sourceseparation, a waste management strategy that diverts organic household waste to compost,biogas or animal feed as a way of preventing methane generation in landfills. M5 shouldtherefore posit and analyze a “recycling-heavy” scenario that includes not only dry wasterecycling but also a system of source separation and organics treatment such as compost,biogas, or animal feed. Such systems have been successfully implemented in cities such as2 See information about the California Act at http://www3.calrecycle.ca.gov/LGCentral/Enforcement/3 San Francisco City Council, San Francisco achieves 77% landfill diversion rate, the highest of any U.S. city,30th August, 2010, in: http://www5.sfgov.org/sf_news/2010/08/san-francisco-achieves-77-landfill-diversionrate-the-highest-of-any-us-city.html4 The Mandatory Recycling and Composting Ordinance of San Francisco City is available online at:http://www.sfenvironment.org/our_programs/topics.html?ssi=3&ti=865 San Francisco City Program on composting, see at:http://www.sfenvironment.org/our_programs/topics.html?ssi=3&ti=6

Mumbai, San Francisco, Pune, and are realistically replicable worldwide. To exclude M5from the analysis is to reward marginal improvements while foreclosing greater ones.2.3 Problematic parameters in ACM001a) Amount of landfill gas capturedLandfill gas capture systems are fitted with equipment to capture emissions ofmethane gas, yet only a fraction of the methane gas generated is actually captured forconversion into energy. Earlier, the US EPA estimated that gas collection systemscapture 75% of the methane produced by landfills (EPA, 2002) yet more recently, theEPA’s Region 9 has challenged the 75% collection rate assumption, stating, “Webelieve 30 % is a superior efficiency assumption” (EPA Region 9, 2007:1).LFGTE projects also fail to solve the long-term problem of methane emissions frominactive landfills. In January 2008, state scientists were surprised to learn that aCalifornia landfill was still emitting methane 40 years after its closure (Henessey,2008). Thus, LFGTE programs don’t stop landfill methane emissions at their source.It is uncertain how much methane escapes capture, and closed landfills continue toproduce methane for decades.b) Methane fraction in the landfill gas.The methodology ACM001 does not contemplate specific characterization of wasteprior to being landfilled so there is no assessment of organic waste proportion, whichwill definitely affect methane rates.In developing countries, where waste consists mainly of organic matter, theuncertainty over the methane calculations used to base carbon credits is unacceptablyhigh. As noted by the UNEP (2010), the 2006 IPCC Guidelines (IPCC, 2006) indicatethat uncertainties for global emissions from waste can be as high as 10-30% fordeveloped countries (with good data sets) to more than 60% for developing countriesthat do not have annual data. Monni et al (2004) also noted that if alternative, butequally defensible, assumptions were adopted for future waste generation, their resultsfor total methane emissions from landfills worldwide could be 40-50% lower, or 20-25% higher than those actually presented.c) Methane production in landfill gas systems and practices for maximization.In controlled landfills, the process of burying waste and regularly covering depositswith a low-permeability material creates an internal environment that favors methaneproducingbacteria (UNEP, 2010). In fact, where landfill practices are informal and donot extend to site compaction and cover, the optimum anaerobic conditions formethane-production do not develop. Therefore less methane is produced per tone oforganic waste (compared to controlled sites) (UNEP, 2010).In other words, the trend towards more managed landfill practices in developingnations will lead to enhanced anaerobic conditions and therefore generation of greaterquantities of methane in the future, which in combination with its inefficient capturerate results in an increase of GHG fugitive emissions released into the atmosphere.

However, such projects also generate CERs, which can only be regarded as spurious.As LFGTE projects often depend financially upon sales of energy from the methane,landfill operators usually manipulate operations to generate more methane in thelandfill, which increases fugitive emissions and its short-term impact on globalwarming (Sierra Club, et al., 2010). As the EPA found in 2003, operators of LFGTEsystems increasingly add liquids to landfills in the form of “leachate recirculation”(the liquid that drains from a landfill) or other liquids in order to “promotedegradation of biodegradable waste.” This reportedly improves the “cost effectivenessfor those sites where the landfill is utilized for its energy potential” (Thorneloe, 2003:3,8).Adding liquids to landfills not only generates more methane, but also causes a greaterproportion of that methane to escape into the atmosphere for two reasons. First, theactions taken to increase moisture degrade gas collection. When leachate isrecirculated in landfills, the landfill becomes waterlogged and compacted. Theseconditions preclude the use of the most effective and rigid methane collection pipes(AEA Technology, 1999). Second, because the top of such a landfill is left uncoveredlonger to allow for more rain penetration, it is impossible to maintain a seal to preventthe gas collection systems from also pulling air from the surface along with methanefrom the surrounding wastes. EPA scientists acknowledge that this leads to a “largerloss of fugitive emissions” than would occur in a traditional “dry tomb” landfill(Thorneloe, 2007:4).In light of the above, practices known to increase methane generation in landfillsshould be prohibited in CDM projects. These include, but are not limited to:recirculating leachate or adding water to the landfill; reducing the well suction toprevent oxygen entering the landfill and oxygenation of the waste; and shutting offwells to allow methane to build up. The current system of issuing CERs based onmethane burned creates a perverse incentive to maximize methane generation, eventhough this also increases uncontrolled methane emissions. Similarly, a landfill gascapture project will provide a perverse incentive to not divert organic waste forcomposting, as the landfill would produce less methane gas.d) An absent parameter: fugitive methane emissionsFugitive methane emissions from landfills are identified as the primary source ofbaseline emissions yet are nowhere calculated. CERs are issued instead based on thequantity of methane captured and burned (Equation 1). The implication is that theonly change in fugitive emissions is due to increased capture; yet this is anungrounded assumption. Changes in the economic structure (e.g., privatization ofwaste management) can affect how much and what type of waste is landfilled.Changes in landfill management practice can affect methane generation, oxidationand emission rates. Given the number of variables and high uncertainties, it isimperative that fugitive methane emissions from the landfill site actually be measuredat frequent intervals, before, during and after the project activity. Although thisimposes a considerable burden on project developers – fugitive methane testing is noteasy or straightforward – it is essential to avoid the issuance of spurious CERs.

2.5 The additionality toolA major reason why the CDM results in the support of downstream solutions in the case ofwaste management lies with the concept of additionality. Below we demonstrate how theinvestment, technological and common practice barrier tests actually end up promoting aproject type that is neither the most environmentally friendly nor the most cost-effectiveoption for the waste sector.• Investment: Traditional market analysis is not effective in determining theadditionality of project implementation in the waste sector for two reasons. One is thatsolid waste management is a public sector responsibility, yet the expertise indesigning and implementing solid waste projects often lies in the private sector. Sincethe public sector is not subject to market pressures, the private sector has a conflict ofinterest in proposing and implementing projects, and corruption is not unknown, theresult is often that more expensive activities are implemented while cheaper ones areneglected. In particular, waste reduction, recycling, biogas, and composting are allcheaper options than incineration; the net costs to the local government will be lower,as the amount of waste dumped into the landfill is less, since typically a tipping fee ischarged per unit weight of waste brought to the landfill. In what can be consideredabsurd, the investment barrier would show that the IRR (internal rate of return) forincineration is too low simply because the calorific content of the waste would be toolow due to high recycling rates. The second reason is that, in most developing countrycities, a significant amount of waste goes uncollected. The status quo or “do nothing”option is therefore often the most financially attractive.• Technology: Incineration is a more 'technologically' advanced option than recycling,composting or waste reduction, but it is clearly not the best option. Yet, thetechnology barrier test would indicate that it is the best option.• Common Practice: Again, incineration is not a common practice compared to otheralternatives, precisely because it is inappropriate for the waste composition andeconomic conditions in developing countries; rather than acknowledge this, theCommon Practice test indicates that the CDM should support such technologies.3. Summary of changes proposed into the methodology ACM001▪ The baseline scenario must be adapted to take into account current recycling practices,especially when involving communities of wastepickers, and an alternative recyclingheavyscenario should be calculated to represent the best opportunity for greenhouse gasemission reductions. Projects should only manage the fraction of waste that can no longerbe recycled or composted by wastepickers. This listing must be undertaken in atransparent manner.▪ Modeling equations must be reviewed to estimate CH 4 production conservatively, giventhe very large uncertainties involved. Additionally, the equations must be adjusted toaccount for conditions in developing countries.▪ Landfill gas installations must be managed to minimize methane releases, not maximize

methane capture. Practices that increase CH 4 production must be banned at the project site.▪ Regular monitoring of fugitive methane emissions is necessary to ensure that they do notincrease under the project.▪ Make rigorous characterization of landfill waste a compulsory parameter in landfill gassystems, as this will affect the production rate of CH 4 and therefore of CERs issuance.5. Next StepsFor all these reasons mentioned above, we suggest a thorough revision of this methodology,especially to ensure that it does not replace the environmentally friendly and cost-effectiveservices that waste pickers provide with costlier and dirtier alternatives such as landfilling.We thank you for reading our <strong>comments</strong> outlining problems with waste managementmethodology ACM0001, as well as feasible solutions. We trust that the Secretariat will takeour concerns into account when proposing priority revision requests of approved creditingmethodologies. Only then it can be ensured that CDM waste management projects are notresulting in the generation of spurious credits, the loss of livelihoods for waste pickers andthe replacement of cleaner upstream solutions with dirtier technologies such as landfills. Welook forward to your response to our concerns.6. ReferencesAEA Technology (1999), Methane emissions from UK landfills (UK Department of theEnvironment, Transport and the Regions, 1999), at p. 2-10.Bogner, J., R. Pipatti, S. Hashimoto, C. Diaz, K. Mareckova, L. Diaz, P. Kjeldsen, S.Monni, A. Faaij, Q. Gao, T. Zhang, M. Abdelrafie Ahmed, R.T.M. Sutamihardja andR. Gregory (2008), Mitigation of global greenhouse gas emissions from waste: conclusionsand strategies from the Intergovernmental Panel on Climate Change (IPCC).R. Couth, C. Trois (2010), “Carbon emissions reduction strategies in Africa from improvedwaste management: A review”. Article in Press, Waste Management.Drabinski, S. (2009), Domestic waste management in Cairo – a case study, Muell und Abfall2/09, Erich Schmidt Verlag.Fichtner Consulting Engineers Limited (2004). The Viability of Advanced ThermalTreatment in the UK, for Environmental Services Training and Education Trust.Hansen, J., Mki. Sato, R. Ruedy, P. Kharecha, A. Lacis, R.L. Miller, L. Nazarenko, K. Lo,G.A. Schmidt, G. Russell, I. Aleinov, S. Bauer, E. Baum, B. Cairns, V. Canuto, M. Chandler,Y. Cheng, A. Cohen, A. Del Genio, G. Faluvegi, E. Fleming, A. Friend, T. Hall, C. Jackman,J. Jonas, M. Kelley, N.Y. Kiang, D. Koch, G. Labow, J. Lerner, S. Menon, T. Novakov, V.Oinas, Ja. Perlwitz, Ju. Perlwitz, D. Rind, A. Romanou, R. Schmunk, D. Shindell, P. Stone,S. Sun, D. Streets, N. Tausnev, D. Thresher, N. Unger, M. Yao, and S. Zhang (2007),Dangerous human-made interference with climate: A GISS modelE study, Atmos. Chem.

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