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Comment 1 for Recycling Comments for the GHG Scoping Plan (sp-recyc-waste-ws) - 1st Workshop.
First Name: Scott
Last Name: Miller
Email Address: millercs@roadrunner.com
Affiliation: BioEnergy BlogRing
Subject: Permit Conversion Technologies to achieve substantial GHG benefits
Comment:
According to CARB's own estimates, there is an estimated 40 million tons of unrecycled waste pouring into California's landfills each year. This is roughly equal to the amount that was accumulating before California's very successful recycling policies were enacted. The CIWMB needs to pursue a more aggressive approach than merely extending its rather mature methane capture and composting solutions. Composting is not a solution for two reasons: 1) the resulting compost does not meet a consistent purity standard to make it marketable and 2) the demand for compost is so low that these programs are not economically sustainable. California's landfills already lead the nation in their design for capturing methane. Most unrecyclable trash can be used for generating renewable electricity or converting into carbon-neutral biofuels. Some of our biggest landfills in our largest cities are scheduled to close within the next decade necessitating trans-shipment to other sites - sometimes hundreds of miles away. This is a perverse waste of GHG emitting trucking and rail fuel when conversion technologies sited at waste sorting facilities can instead cleanly reduce the volume going to landfills by approximately 85% (see independent 2005 UC/Riverside analysis (see http://bioconversion.blogspot.com/2005/12/ca-ab-1090-111605-results-of.html ). "Zero waste" is an unattainable idealistic vision unless it embraces conversion technologies as an extension of recycling. Without question municipalities should receive diversion credit for redirecting unrecycleable biomass from landfills to conversion technologies that can cleanly produce bioenergy and bioproducts from the refuse. There should also be a recycling integrity clause in the Scoping Plan that insures that all recycled waste is turned into products within the U.S. to reduce and control global GHG emissions of our recycling waste stream. Currently most recyclables are shipped (at great GHG expense) to China for conversion because of that country's poor wages, lack of workers rights, and unacceptably low pollution standards (see http://biowaste.blogspot.com/2007/01/recyclings- china-syndrome.html ).
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Date and Time Comment Was Submitted: 2008-07-02 17:20:58
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