Comment Log Display

Thank you for the opportunity to comment on the proposed cap and
trade regulatory amendments.  Please see attached for comments from
the City of Long Beach.  For ease of reading, the text is also
pasted below.  

Should you have questions, please contact Diana Tang, Manager of
Government Affairs at 562-570-6506.


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January 20, 2017


Mary D. Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95812

RE:	Public Comment on Amendments to the California Cap on
Greenhouse Gas Emissions and Market-Based Compliance Mechanisms
Regulation (Attachment A: Proposed Amendments to the California Cap
on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms
Regulation)

On behalf of the City of Long Beach, I write to comment on the
15-day language issued by the California Air Resources Board (CARB)
pertaining to Proposed Amendments to the California Cap on
Greenhouse Gas Emissions and Market-Based Compliance Mechanisms
Regulation.  Long Beach strongly supports CARB staff’s
recommendation to formalize the limited exemption in the 2nd
compliance period for waste-to-energy facilities; and understands
these facilities will be subject to compliance during the 3rd
compliance period, beginning in 2018.  The City looks forward to
our continued partnership with CARB and other State agencies to
continue greenhouse gas emission reductions through a multitude of
means, including improved waste disposal options so as to reduce
methane impacts associated with landfills.

In partnership with Covanta Energy, Long Beach proposes a long-term
solution that would include waste-to-energy facilities in the cap
beginning in the 3rd compliance period with a provision for
allowances to be granted on the basis of the output-based
allocation methology. This approach provides a more level and
equitable playing field in the waste management sector over the
long-term, thereby preventing emissions leakage out of the cap to
landfills.  The City of Long Beach supports the methodology
proposed in Covanta Energy’s comment letter on this issue.

Since Long Beach, in partnership with the Los Angeles County
Sanitation District, began operating the Southeast Resource
Recovery Facility (SERRF), our waste-to-energy facility, in 1988,
the facility has processed approximately 1,400 tons of municipal
solid waste (MSW) per day.  Over the course of the past 28 years,
13.2 million tons of MSW has been processed through SERRF, creating
6.2 billion kilowatt-hours of electricity that has been loaded onto
the regional grid.  This MSW would have otherwise been sent to a
landfill.  Through the recovery process at SERRF, 5,115 tons of
recyclable white goods and 184,000 tons of metal have also been
extracted and sent to local recycling facilities as opposed to a
landfill.  Furthermore, based on CalRecycle assumptions on
California landfill performance, facility specific greenhouse gas
(GHG) emissions data as reported to the United States Environmental
Protection Agency (U.S. EPA), as well as facility specific net
electrical generation and the local electrical grid (based on U.S.
EPA e-GRID data for the WECC California grid sub-region), the
waste-to-energy facility in Long Beach enables the region to avoid
approximately 0.6 tons of CO2e per ton of MSW processed.  As a
result of diverting MSW from landfills to SERRF, there has been a
reduction of 7.92 million tons of carbon equivalent greenhouse
gasses entering the environment. 

Long Beach is proud to manage one of California’s three
waste-to-energy facilities, which provide an alternative to
landfilling.  The use of waste-to-energy technologies for waste
disposal is consistent with the City’s commitment to
sustainability, recycling, and other environmentally friendly
policies.  We are pleased to share our facility consistently
operates at 20% below pollutant concentration limits in the
facility permit, and supplements local waste reduction efforts. 
While using waste-to-energy technologies in the City, Long Beach
residents generate 4.0 pounds/person/day of solid waste, well below
the current State target mandate of 7.6 pounds/person/day.  The
City also offers a Compost Pilot Program, collecting over 1,000
gallons of compost each week from local restaurants.  Residents
also benefit from a mulch program whereby City tree trimming
operations offer mulch to individual families rather than send the
materials to a landfill; more than 500 tons of mulch was used
locally by Long Beach residents through this program in 2016 alone.
 These programs are constantly evolving to meet State standards and
the needs of our community.  Long Beach’s waste-to-energy facility
is merely one component of a larger waste reduction strategy – but
it is an integral component, and the City values its benefits.

Continued operation of the waste-to-energy facility in Long Beach
is not guaranteed, especially with significant upcoming changes
that will impact the economics of the facility.  While Long Beach
values the numerous environmental benefits afforded by SERRF, it is
imperative to the City that the facility is economically
sustainable as well.

Given these reasons, the City of Long Beach supports CARB’s 15-day
language pertaining to Amendments to the California Cap on
Greenhouse Gas Emissions and Market-Based Compliance Mechanisms,
and looks forward to working with CARB on a path towards
allowances.

Should you have any questions, please contact Diana Tang, Manager
of Government Affairs, at 562-570-6506 or
Diana.Tang@longbeach.gov.

Sincerely,



Patrick H. West
CITY MANAGER

cc:	California Air Resource Board Members