Carbon offsets for biogas are most “impactful” when they meet the best-in-class standards for carbon offsets - additional, not overestimated, permanent, not claimed by another entity, and not associated with significant social or environmental harms - along with meeting the following conditions:7
- Project is not required by regulation to implement biogas capture and treatment
- Project is not profitable from the sale of renewable resources from biogas treatment
- Project is capital constrained and will not happen without carbon offsets
- Carbon offsets go directly to purchasing biogas project infrastructure or maintenance, as opposed to non-essential inputs
When reviewing projects for this report, we found that it was difficult to get enough information to determine whether projects met the above conditions. Simply being certified by one of the major certifying agencies did not give us confidence that the project was indeed additional. We expect that some biogas projects will meet these conditions, and some will not. This appears to be confirmed by what others have concluded.8,9
For example, the GHG Management Institute and Stockholm Environment Institute say that the usefulness of landfill gas projects and associated carbon offsets depends on the project. They state: “Varies by location. Projects are likely additional in most parts of the developing world. In developed countries, including the United States, some projects are pursued to avoid triggering regulatory requirements, and projects that generate energy can be economical without carbon revenue.” The report also describes how there is uncertainty in baseline levels of methane output with these projects, which further adds to the difficulty of quantifying their impact.10,11
We therefore focused the remainder of our research on waste biogas projects in developing countries and projects involving small landfills in the US.
Developing countries: Unfortunately, we found few offsets in developing countries available for sale online. The UN offers two such projects, capturing biogas from agricultural waste in India and Thailand. However, after further consideration, we didn’t feel comfortable recommending either.
The Ratchaburi Farms Biogas Project in Thailand is a biogas capture system that generates energy for use on a large pig farm. The first issue with additionality is that the system may be profitable, and as a large company it’s plausible that the farm could and would have made the investment without the carbon credits. But more worrisome is that the project is quite old. It started operating in 2008, and in its original application for offset certification, it requested credits for 10 years. The project was a partnership with the Government of Denmark, who committed to buying some of the credits as part of their commitment under the Kyoto accord. So as far as we can tell, the current offsets for sale were generated before 2018 but were not part of the purchase agreement with Denmark. Given this, it is quite hard to believe that expectation of voluntary offsets purchases 10 years in the future actually contribute to additionality.
The Mabagas Power Plant in India is somewhat more promising. It generates energy by procuring animal waste from nearby farmers and feeding this waste into its digesters. Without this plant, this waste would degrade and release biogas into the air. There are no regulations requiring the construction of the plant. However, a couple of worries have prevented us from recommending these offsets. First, the project seems plausibly profitable. Although the IRR documents submitted as part of the offset certification procedure claim that selling carbon credits is necessary to achieve viability, these numbers are hard to verify. Next, there is a question of who precisely is on the receiving end of these offsets. Mabagas was launched as a joint venture between two companies that mainly deal in (petroleum-based) oil and gas: the state-owned Indian Oil Company, and the German company Marquard & Bahls. As revenue from offsets will ultimately flow to these companies or their subsidiaries, it is unlikely that this capital will fuel more green projects. Overall, we cannot recommend these offsets given the information available at this time.
US-based projects: Although large emitters are required to install methane capture systems, small landfills are not covered by these regulations, and carbon credits may certainly spur them to build capture systems. However, regulations are constantly changing, and plants may install landfill gas capture systems in anticipation of coming under regulatory authority (due to expansion or changing regulations).12
We explored US landfill gas offset options and, at least given the data available, felt unable to confidently recommend any of them. For instance, this landfill in Massachusetts seems to be a project that was very much spurred by carbon credits, with credits originally issued for ten years. However, the offsets available for purchase now are for the second issuance of offsets, while the actual infrastructure seems to only have been modestly updated. It is unclear what additionality these new offsets are providing. The Hilltop Landfill in Virginia was a small landfill that installed methane capture financed with carbon credits. But the landfill closed in 2013, and it seems like the investment has already been refunded from previous carbon credit sales.13 So further sales are likely not additional. Other options we explored are larger landfills that seem likely to fall under methane capture regulations as they grow or as new regulations are put into place.
Overall, we believe that there are likely good biogas offsets that are additional, but currently, we have been unable to find any that meet our criteria. As not all offsets are offered online, it is possible that these high-quality offsets are being directly sold to corporate buyers or are only transacted through brokers. Giving Green will continue searching for biogas projects we can recommend with confidence.
7 http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf
8 http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf
9 https://www.drawdown.org/solutions/buildings-and-cities/landfill-methane
10 http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf
11 https://www.drawdown.org/solutions/buildings-and-cities/landfill-methane
12 http://biomassmagazine.com/articles/16424/epa-proposes-federal-plan-under-2016-landfill-gas-regulations
13 https://www.ecosystemmarketplace.com/articles/offsetting-local-inside-landfill-gas-project/
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