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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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