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