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Comment 26 for Recycling Comments for the GHG Scoping Plan (sp-recyc-waste-ws) - 1st Workshop.


First Name: Brent
Last Name: Eidson
Email Address: beidson@sandiego.gov
Affiliation: City of San Diego

Subject: Producer Responsibility/Organic Materials/Conversion Technologies
Comment:
p. 34-35 draft Scoping Plan
Although landfill methane control is an important measure to
reduce fugitive greenhouse gas emissions, more emphasis should be
placed on preventing the generation of these gases by reducing
upstream emissions associated with extracting, transporting, and
processing raw materials and diverting more materials from
disposal at the end of their useful life.  The plan should also
include measures to quantify the GHG reductions associated with
waste reduction and recycling activities.  If emission credits can
be earned for these activities, it must be determined who receives
credit at which point in the process. 

The plan should include more specific measures for producer
responsibility. The burden on local government to responsibly
manage the disposal of non-recyclable and hazardous products is
considerable and subsidizes the continued production of these
products.  Shifting this burden back to the manufacturers will
create the incentives for producers to redesign their products and
recycle more of them at the end of their lifecycle.  

Organic material generates methane when buried in a landfill. 
There should be more incentives to compost this material and apply
it to the land and more disincentives to disposing it in a landfill
or using it as alternative daily cover.  This would reduce the need
for fertilizer and the emissions associated with its production and
application, and increase carbon sequestration in the soil.  In
addition, compost amended soil has the added benefit of reducing
the need for irrigation.   


ETAAC Final Report comments – Waste Reduction, Recycling and
Resource Management
p. 4-14 to 4-21.  ESD generally supports the measures outlined for
Waste Reduction, Recycling, and Resource Management.  These
measures would have the added benefit of preserving existing
landfill capacity, avoiding the need to transport waste longer
distances for disposal as local disposal facilities reach
capacity.     

p. 4-15.  Local governments are not in the position to develop
protocols for life-cycle assessments related to solid-waste
decisions.  This should be developed at the state level for
utilization by local government and costs should be considered.   


p. 4-16.  A flat, across the board increase in diversion rates
would be costly for local governments.  However, mandatory
recycling requirements for commercial sectors and multi-family
residences should be considered.  A threshold of 4 cubic yards
might be difficult to measure since standard dumpster sizes are in
multiples of three (3 cy, 6 cy, 9 cy, etc.)

p. 4-20 – 4-21.  Conversion technologies should be examined for
full life-cycle impacts when compared to source reduction, reuse,
recycling, and composting. 

There is insufficient information on landfill methane control
measures. List all control measures being proposed, feasibility of
implementation, potential GHG reduction for each measure, and
economic modeling of each measure.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-07-30 11:28:24



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