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Comment 31 for Recycling Comments for the GHG Scoping Plan (sp-recyc-waste-ws) - 1st Workshop.
First Name: Ann
Last Name: Schneider
Email Address: Ann.Schneider@sierraclub.org
Affiliation: Sierra Club
Subject: Maximize Recycling as Early Action
Comment:
Dear CARB: Thank you for your work and for your comments that you have heard that you need to expand recyclings place in the list of actions California needs to do to reduce our impact on Global Warming. 1. Your report talks about a 54% diversion in Calif. Sadly while we might be at 54% diversion, we are today, landfilling almost the same tonnage statewide as we did in 1990, the year AB393 set as base year. We can not use population growth and a growing economy as an excuse to basically bury as much today as we did 18 years ago. That is why we advocate for zero waste as all materials landfilled are "wasted" and none belong in a landfill. All materials should be cycled back as nature does. So please change your report to reflect diversion and disposal and don't just pass it off as ok because our population has grown. 2. ETAAC Recommendations include a terrific range of additions that were not reflected in the draft Scoping plan. Please add all the ETAAC recommendations. I would prefer to see mandatory recycling of specific materials from all commercial and industrial sources, like all metals, all paper, all glass, most plastics and all biodegradable organics like food waste and greenwaste. We are 18 years into AB9393 that mandates behaviors on local governments. It is now time to get all businesses and residents to be held to the same law. 3. Extremely critical is to eliminate the credit local governments and landfill operators receive for using greenwaste, volume reducing it and then using it as "Alternate Daily Cover (ADC)" and getting recycling credit under AB939. The law needs to be changed immediately to eliminate ADC as recycling. This is shame recycling. In my capacity as Chair of the Sierra Club Zero Waste Committee I hear from angry residents, who upon hearing that their clean greenwaste is being buried in the landfill. They feel that their government and their hauler are lying to them and that all recycling is a lie. Then they stop participating in programs that local governments have worked so hard to create. It takes years of retraining to turn an angry former recycler back into a true "green" or "blue-green" recycler. So shame recycling is very, very bad for all recycling, not just greenwaste. 4. All greenwaste, foodwaste and food contaminated paper should be banned from disposal in landfills. And we need a "WWII-like Marshall Plan" to construct composting facilities to handle all of California's biodegradable organic materials and return the valuable compost to our denuded soils. This will benefit our farmers, our residents; reduce our need for fertilizers, pesticides, water consumption etc. AND it will get these materials out of landfills so they stop turning into methane that even with collection systems releases into the atmosphere along with hitchhiking VOCs and HAPs. This is critical. We need CARB and CIWMB to convene and quickly resolve the best management practices for composting so VOCs and HAPs are not released during the composting process. Don't make this a huge we must study ad nauseum action. Just get it done and get these facilities sited throughout the state. 5. Identify technologies that can generate energy during the composting process. But ensure that the final product is a viable soil amendment and not slag. 6. Use carbon funds to fund the composting market develop needed to site new composting facilities or expand existing facilities. 7. Do not advocate for "Landfill Gas-to-Energy (LFGTE) until all the science is in. Since methane is 25 to 120 times worse (given timeframe used) than carbon dioxide, the risk of turning landfills into biodigesting landfills in order to maximize methane generation for fuel is too great. We are too close to the climate tipping point to risk biodigesting landfills with out 100% proof that the can stop all fugitive gas releases of methane from the landfill. My Committee does not believe that full recovery is possible, contrary to the US EPA belief that 70% can be captured. We believe that it will be closer to 20% over the life of the landfill. And worse, rather than taking decades for fugitive gas releases, we believe it will speed up methane releases while increasing the gas concentrations of methane and piggybacking VOCs and HAPs. Please rethink CARB Scoping Plan assumptions. Please use the precautionary principle and do no harm. Work to ensure that data is available to all parties from independent sources, not from the landfill operators who have a vested interest in keeping organics in landfills, and making methane to sell to energy producers. 8. The Draft Scoping Plan did not include a list of what California considers acceptable alternative energy. I do know that California does not EXCLUDE waste-to-energy (WtE) from the Renewable Energy Standards/Portfolio. We ask that you exclude WtE from the RES and state portfolios. We ask that you exclude LFGTE from the RES/portfolio. WtE should be excluded as it competes with recycling and only gets one more "life" from a material. And it loses all the embodied energy that created that material from virgin materials extraction, to processing, to manufacturing/assembly, to market and all the related transportation energy inputs. Reuse and recycling retains the embodied energy over and over again. LFGTE should be excluded at the very least until it can be proven that it doesn't create more fugitive gases. And it should be excluded because biodegradable materials should not be placed in landfills. They should go to composting and if a process can also recover energy then that process should be part of the RES/portfolio. 9. Landuse - Reuse, recycling and composting operations are low margin businesses. And they require a lot of space. This makes them at a disadvantage to other forms of landuse like high tech offices or retail. As recycling businesses get pushed out away from population centers, transportation costs and energy consumption/GHG gases goes up, (just like affordable housing). Local government General Plans and SMART Growth legislation should recognize the need for reuse operations, recycling and composting as critical infrastructure (like water treatment and sewage treatment plants) and set aside land to keep these businesses close to population centers and points where the reuse/recycling/green & food wastes are generated. Landbanking for reuse/recycling and composting operations should be set aside for future use or identified as required infill. I look forward to seeing the appendices and to see the next version. At least I hope there will be one more version before the Scoping plan goes to the Air Resources Board in November. That would give "us" recyclers a chance to see if our concepts made sense to CARB staff. 10. Source reduction efforts should be expaned with CAL EPR being the leader. No plastic water bottles should be provided at public meetings, instead glasses with tap water should be used. This is what San Francisco now requires and the Sierra Club followed suit for all our meetings. This helps in reducing water transportation costs; supports the local water district, very important during droughts and reduced water consumption; reduces exploitation of water in communities where bottled water plants are sited; and reduces plastic waste. Small steps, big impact. Thanks for all your work. Sincerely, Ann Schneider Chair, National Zero Waste Committee Sierra Club Millbrae, CA
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Date and Time Comment Was Submitted: 2008-07-31 22:03:20
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