In an efficient building that is run on renewables, it is likely that the largest residual emissions source under the operational control of the landlord will come from waste to landfill. So, the obvious way for the landlord to further reduce those emissions is to increase recycling… or is it?
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I guess the answer depends on the material and where you send it to be recycled.
If that material is high in organic matter and it is processed at a facility where it claims Australian Carbon Credit Units (ACCUs) for emissions avoided from landfill, then the rights to claim the emissions reduction are sold to someone else… likely a large polluter who retires ACCUs as a compliance requirement under the Safeguard Mechanism.
If you are doing your carbon accounting correctly, you have to ask: who actually owns the environmental claim?
Herein lies the double-counting paradox. The facility cannot have it both ways. They cannot sell the literal “right” to those avoided emissions to a heavy emitter to cancel out industrial pollution, while simultaneously marketing a zero-emissions or low-carbon disposal service to you.
If the offset has been sold, the climate benefit has left the building. Even if Scope 3 accounting rules technically allow you to log a reduction, this creates a profound risk to the environmental integrity of your carbon claims when someone else outside your value chain has already pocketed the exact same reduction.
So how would you know if you are caught in this loop? In theory, it should be transparent. An organisation generating ACCUs signs up to foundational integrity principles – chiefly, ensuring that additional activities wouldn’t have happened without the ACCU income, and that emissions reductions are never double counted.
Realistically, trying to track down whether your specific commercial waste stream is backing someone else’s compliance credit feels like finding a needle in a haystack.
These facilities should simply report to you what the emissions factors are for your materials. For those readers who have attempted to gain access to information about what happens at a recycling or alternative waste treatment plant, I hear you…it may be challenging.
There is always the Clean Energy Regulator website… maybe you could navigate your way through that to find out if your processing facility is affected.
I hear your frustration. You’ve invested in setting up your site and changing processes to separate materials and send them off for recycling. It is now your problem to work out if some other organisation has already claimed the emissions reduction offsets against their pollution.
How is it even considered additional on the part of the facility when you were the one that chose to use their service on the basis that it was recycling? You separated it, and it was never going to landfill. Yet somehow this passed the additionality test… that’s a whole other story.
The point of this piece is to open your eyes to the challenges of carbon accounting. There are lots of questions you need to ask, and when in doubt, be conservative.
Recycling is still worth doing to stop pollution and the depletion of natural resources. It’s just a shame your well-placed efforts may be unknowingly supporting large polluters with cheap offsets as part of their Safeguard Mechanism compliance requirements.
The solution is for the Safeguard Mechanism to only allow the use of carbon removals with a permanence that aligns with the lifecycle of the emissions. This would then align with the higher integrity rules that the Australian government endorsed as an alternative to the Climate Active program that they are closing.
Harmonising the integrity expectations of voluntary actions of corporations and the compliance requirements of Australia’s largest emitters would be a good outcome.
