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This letter is in response to the Air Resources Board solicitation
for stakeholder input on the development of an investment plan for
the auction proceeds from the AB 32 Cap-and-Trade program to reduce
greenhouse gas emissions.  Furthermore, AB 1532 and Senate Bill 535
provides a legislative framework that requires the investment plan
to fund greenhouse gas reductions through energy efficiency, clean
energy generation, efficient goods movement, water and land use,
waste reduction, and research/commercialization of new
technologies. The waste reduction objective within this framework
are concurrent with the State and the City of Oceanside’s own zero
waste goals and policies, both of which calls for a 75% recycling
rate by 2020.  As the City of Oceanside’s solid waste manager, I
strongly encourage the allocation of financial support to organics
processing and recycling market development as a primary step in
our State’s clean air goals. 
Increased capacity for organics (green waste and food waste)
processing and collection infrastructure can significantly reduce
landfill methane emissions.  Compost application results in
additional reduced emissions as compared to chemical fertilizers,
due to compost being less energy-intensive, water efficient and
beneficial to supporting improved soil sequestration.  Direct and
ongoing incentives for composting and digestion facilities through
this investment plan will provide the greatest opportunity in both
the short and long term.  Immediate investments in grants and loans
to capitalize new and expanded facilities would have a significant
impact in reducing our waste stream, while also reducing methane
emissions from the decomposition of these materials in our
landfills. 
Additionally, please consider incorporating increased investment
into recycling market development.  Expansion of recycling markets
is necessary in order to grow domestic outlets for recycled
materials.  Funding support for recycling markets would spur
economic development and investment in California recycling
infrastructure.  Recycling manufacturing avoids emissions from raw
materials extraction, primary processing, transportation, and
refining.  Recycling also promotes forest carbon sequestration, and
directly reduces manufacturing emissions by displacing virgin
materials which require more energy for processing, and generate
more waste.  Reintroducing discards with intrinsic energy value
back into manufacturing processes will create more local jobs by
supporting in-state processing and manufacturing with recycled
feedstock. 
I greatly appreciate your consideration of my comments.  
Thank you, 
Colleen Foster
Solid Waste and Recycling 
Water Utilities Department
City of Oceanside 
300 North Coast Hwy
Oceanside, CA 92054