Comment on ‘Reducing Canada’s landfill methane emissions: Proposed regulatory framework’

Regulating methane emissions is an important policy tool for Canada because it offers a way to effectively limit near-term global warming. Environment and Climate Change Canada published a document in April 2023, proposing a regulatory framework for reducing landfill methane emissions. New regulations will set a much-needed standard for policy consistency across the provinces and territories, and this paper provides feedback on the framework. In 2021, Canada’s waste sector methane emissions were 14 per cent of total emissions, representing an 11 per cent increase since 1990. Waste sector emissions include municipal solid waste landfills, industrial wood waste landfills, solid waste biological treatment and incineration, and wastewater treatment and discharge, among others. Extending regulations to landfill methane will fill an important gap in Canadian emissions policy. With a federal framework in place, up to 90 per cent of municipal solid waste landfills and 19 per cent of all methane emissions would be regulated, compared to the current scenario in which 58 per cent of landfill methane is directly vented to the air. Currently, most provinces require only capture for use over flaring, or flaring over venting and these emissions are only indirectly regulated via offset markets. Potential improvements include: • Expanding the regulation’s applicability to all landfills; • Building benefit-cost analysis relying on social damages from emissions into threshold determination; • Providing guidance on best-in-class options for compliance and increasing the stringency of the performance standard; • Prioritizing capture for use over capture and destruction, and creating incentives for the same; • Allowing for offset credit generation where facilities exceed the performance requirement; • Ensuring provincial or territorial equivalency is granted only in the case of more stringent regulation; and • Addressing the current inconsistency in regulation of industrial landfills. Environment and Climate Change Canada’s proposed framework is a crucial first step in eliminating a nationwide gap in emissions policy, but there is still much work to do to fine-tune the regulatory design.