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Comment 8 for Scoping Plan Update Discussion Draft and Workshop Comments Log (draft-update-sp-ws) - 1st Workshop.


First Name: Peter
Last Name: Slote
Email Address: pslote@oaklandnet.com
Affiliation: CA Resource Recovery Association (CRRA)

Subject: AB 32 Scoping Plan – Waste Management and Zero Waste
Comment:
October 25, 2013

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

Re: AB 32 Scoping Plan – Waste Management and Zero Waste

Dear Chair Nichols,

CRRA is California’s statewide recycling association.  It is the
oldest and one of the largest non-profit recycling organizations in
the United States. Our members work for cities, counties and
municipal districts, as well as hauling and recycling companies,
material processors, non-profit organizations, state agencies, and
allied professionals.

CRRA appreciates the opportunity to provide input on the AB 32
Scoping Plan (Plan).  The published review draft of the Plan
includes many worthwhile recommendations. We recommend that the
Plan prioritize the following:

1.	Divert organic wastes to address short-lived GHG methane
emissions.  Take specific and tangible actions reduce landfilling
organics, including establishing a defined timetable for requiring
phase-out of organics disposal, expanding in-state organics
processing capacity (composting and anaerobic digestion).  Doing so
is necessary to achieve waste reduction goals and reduce GHG’s from
avoided landfill methane emissions, and reduced synthetic
fertilizer and water usage from use of finished compost. 

2.	Limit waste-based energy technologies.
a.	Eliminate consideration of cap-and-trade and Renewable Portfolio
Standard credits for MSW Thermal facilities. The Waste Management
Sector Plan developed by the ARB and CalRecycle acknowledges that
“recycling, composting and anaerobic digestion, and biomass
conversion result in even lower GHG emissions” than MSW Thermal
facilities, since these facilities compete with recycling,
composting and anaerobic digestion.
b.	Include incineration in cap-and-trade. Waste incineration
facilities should be covered entities with compliance obligations
under cap-and-trade.
c.	Require any feed stocks under consideration for waste-based
energy be addressed individually, using full life-cycle analyses to
compare to source reduction, reuse, recycling and composting
alternatives
d.	Limit any high-temperature thermal processing technologies to
uniform, controlled feedstock such as agricultural scrap. Exclude
mixed municipal solid waste, as its use only facilitates continued
resource depletion by institutionalizing waste as an unsustainable
“commodity” feedstock for energy production.  High-temperature
thermal processing uses require large energy inputs to capture only
a fraction of the embodied energy in wasted material - net energy
output is unproven and disputed.  The safe containment of hazardous
outputs produced by these facilities is unproven; disposal of toxic
by-products and emissions to air, land and water are significant
public health concerns.

3.	Adopt cap-and-trade compliance offset protocols for composting
and anaerobic digestion.  The Climate Action Reserve has adopted
protocols for voluntary trading markets, but the Air Resources
Board has no for AB 32.  Protocols would improve the financial
viability of facilities, further incentivizing waste reduction and
in-state landfill methane greenhouse gas (GHG) reductions.

4.	Establish waste sector emissions reduction goals for total
emissions (i.e., direct plus indirect – 75% reduction by 2020), as
well for specific materials (e.g., reduce waste carpet emissions by
75%).  Doing so targets not only reductions in downstream
emissions, but also the more significant upstream emissions.   

5.	Establish an extended producer responsibility (EPR) framework. 
Prioritize high-GHG commodities, products with high toxicity, and
difficult to recycle products under an established EPR framework. 
EPR has significant GHG emissions reduction impact with low
implementation cost by giving producers a financial incentive to
design products that close the loop by being easy to repair, reuse,
and recycle.

6.	Focus on waste reduction, especially for food and packaging
waste. CalRecycle can provide statewide leadership to change
unnecessarily wasteful individual and institutional behavior, using
community-based social marketing techniques to overcome obstacles.


7.	Provide a consumption based view of California’s greenhouse gas
emissions. Consumption inventories, linked with materials
management efforts, provide more accurate and nuanced understanding
of end-of-life issues within the full product lifecycle. Focusing
solely on “waste management” limits decision-maker and public
support by understating product impacts.

8.	Include an alternative analysis of methane emissions,
emphasizing the short-term benefits of immediate methane reduction
to limit temperature increases. Demonstrate the volume of methane
emitted using its actual atmospheric life rather than standardizing
to carbon dioxide.  

9.	Finally, we are concerned about the logic of counting all
biomass conversion emissions as biogenic. The Biomass Conversion
technical paper says, “[w]hile these facilities result in direct
GHG emissions (mostly as carbon dioxide) when biomass is burned,
the majority of these emissions are biogenic, and not counted as
discussed above.”  Biomass conversion is an anthropogenic process
and accelerates natural biogenic emissions.  Note that the
Recycling Emissions Reduction Factors indicate a much lower factor
for dimensional lumber than EPA’s Waste Reduction Model.  In fact,
WARM’s factor is about ten times greater than the RERF.

CRRA appreciates the opportunity to provide input to this important
project.  Thank you for your consideration of our comments.

Tracie Bills
President


CRRA, founded in 1974, is California’s statewide recycling
association. It is the oldest and one of the largest non-profit
recycling organizations in the United States. CRRA is dedicated to
achieving environmental sustainability in and beyond California
through Zero Waste strategies including product stewardship, waste
prevention, reuse, recycling and composting. CRRA advances local,
regional and state wide waste reduction efforts which result in
critical environmental and climate protection outcomes. CRRA’s
members represent all aspects of California’s
reduce-reuse-recycle-compost economy. Our members work for cities,
counties and municipal districts, as well as hauling companies,
material processors, non-profit organizations, state agencies, and
allied professionals.

Attachment: www.arb.ca.gov/lists/com-attach/11-draft-update-sp-ws-VzRVIV0uV2UKU1Mw.pdf

Original File Name: CRRA comments to CARB AB 32 Scoping Plan 10-25-13.pdf

Date and Time Comment Was Submitted: 2013-10-25 09:38:56



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