Comment Log Display

September 11, 2014


Ms. Mary Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re: City of Long Beach Comments on Proposed Changes to the Cost of
Implementation Fee Regulation

Dear Chairwoman Nichols:

On behalf of the City of Long Beach, I write to reiterate
opposition to the California Air Resources Board’s (CARB) proposed
changes to the Cost of Implementation Fee Regulation, as they apply
to waste-to-energy facilities. Long Beach had previously submitted
a letter to express our concerns to this proposal during the
unofficial comment period in June.

As demonstrated in the 2012 report entitled, CalRecycle Review of
Waste-to-Energy and Avoided Landfill Methane Emissions,
waste-to-energy facilities reduce greenhouse gas emissions, when
compared to landfills.  Waste-to-energy facilities also have the
capacity to reduce municipal solid waste (MSW) volume by 90
percent, and produce baseload energy as a byproduct.  In
comparison, landfills do not have the capacity to reduce waste
volume prior to burying the materials.  Waste-to-energy facilities
are essential to bridging the gap between traditional landfills and
the next generation of MSW processors.

Amending the adopted COI Fee Regulation to capture waste-to-energy
facilities disincentivizes the use of this technology.  Though
California has adopted an aggressive Cap and Trade Program to
reduce greenhouse gas emissions to 1990 levels by 2020, State
regulations still make landfills the economically preferable
option.  If waste-to-energy facilities are forced to pay additional
fees that are not required of landfills, then the price discrepancy
between these two MSW processing options will grow even larger.  By
2018, it may be economically infeasible to operate the
waste-to-energy facility in Long Beach.

Shutting down the waste-to-energy facility in Long Beach will
negatively impact the goals of the State’s Cap and Trade Program. 
Inevitably, greenhouse gas emissions will increase as landfilling
increases.  Waste generated by over 500,000 residents and business
in Long Beach, in addition to waste from various cities including
Los Angeles, Culver City, Torrance, and Compton will instead go
landfills where nearly 100 percent of the waste volume will be
buried. 
Long Beach does not view increased landfilling as a positive
result.  The City strongly prefers that State regulations treat
landfills and waste-to-energy facilities equitably, or at least
continue to provide allowances to waste-to-energy facilities
consistently throughout the implementation of the Cap and Trade
Program so that Long Beach can continue operating our
waste-to-energy facility.  It is essential for there to be an
economically viable environment for this facility to operate in, so
that it may continue to be a part of State discussions to help
further reduce greenhouse gas emissions in California.

Given these reasons, the City of Long Beach opposes the proposed
COI Fee Regulation amendments, as they apply to waste to energy
facilities.  Long Beach urges the Board to reject staff’s
amendments and keep this section of the regulations as is.

Sincerely,



Mayor Robert Garcia
City of Long Beach

cc:	Members of the California Air Resource Board