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The MOE is proposing to amend regulations under the Environmental Protection Act to mandate collection of landfill gas at all larger landfills. Unfortunately for municipalities, this would strip landfill gas collection of its eligibility for carbon emission reduction credits. One essential feature of all such credits is that they must be “additional”, that is, go above and beyond normal legal requirements. As soon as the province makes landfill gas collection mandatory, this “additionality” disappears.

Ontario already has mandatory landfill gas capture at very large landfills, those in excess of 3 million cubic metres (s. 15, O.Reg. 232/98). The new regulation would extend this to landfills of 1.5 million cubic metres or more.

While Canada STILL doesn’t have a regulatory regime for emission reduction credits, there has to be one eventually. The sale of such credits could go a long way to pay for landfill gas capture and other climate friendly measures by municipalities and other landfill operators. It would be a shame to throw away the best opportunity for Ontario municipalities to earn such credits.

Comments on the proposal can be made until November 7. EBR 010-0968.

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