Comment Log Display

Solid Waste Industry for Climate Solutions
Allied Waste Services
County Sanitation Districts of Los Angeles County
National Solid Waste Management Association
Norcal Waste Systems
OC Waste & Recycling
 Republic Services
Riverside County Waste Management Department 
 Waste Connections
Waste Management

August 1, 2008


To CARB via on-line submittal at:
http://www.arb.ca.gov/lispub/comm2/bcsubform.php?listname=sp-recyc-waste-ws&comm_period=1


Subject: Climate Change Scoping Plan – June 2008 Discussion Draft

Dear California Air Resources Board:

The Solid Waste Industry for Climate Solutions (SWICS) is an
informal coalition of both public and private solid waste and
recycling service providers.  Our goal is to ensure that climate
change policy makers are provided with the most accurate and
comprehensive information regarding our industry and our
operations that may generate or reduce greenhouse gas emissions.  
On behalf of SWICS, we are pleased to take this opportunity to
comment on the Climate Change Scoping Plan – June 2008 Discussion
Draft.  We understand that CARB will be accepting additional
comments on the Appendices to the Draft Scoping Plan until August
11, 2008.  SWICS may make additional comments on these appendices,
but requests additional time until August 18, 2008 due to their
belated release.

SWICS members do not object to reasonable and responsible
reporting of greenhouse gas (GHG) emissions. Our following
comments discuss the significant issues surrounding solid waste
management that must be resolved prior to inclusion of this sector
in a regulatory framework for the control and reduction of
greenhouse gas emissions.  These issues include:

1)	A preoccupation with landfill emissions to the exclusion of
negative and positive GHG impacts of other solid waste management
activities;

2)	A failure to incorporate a life-cycle assessment of the GHG
impacts of solid waste management and recycling services;

3)	Little recognition that solid waste management and recycling
are essential public services, and that associated GHG emissions
are already very low and have decreased steadily over the past 30
years. 

4)	No inclusion of carbon mass balance and life cycle impacts in
the solid waste operations reporting protocol;

5)	No inclusion of carbon storage in the estimation of GHG
emissions from individual landfills and no recognition of the GHG
impacts from changes in stored carbon associated with other solid
waste and recycling activities (e.g., paper recycling,
composting); and

6)	Little differentiation between biogenic and anthropogenic CO2
emissions in proposed reporting, accounting and regulatory
programs.

Draft Scoping Plan Focuses on Landfill Emissions 

SWICS is pleased that the projected GHG reductions to be achieved
by the Solid Waste and Recycling Sector under the draft plan have
been reduced to 1 MMTCO2e from earlier estimates of as much as 2-4
MMTCO2e.  Nonetheless, SWICS believes these projections are too
high as they are based on conservatively modeled landfill GHG
emissions with high levels of uncertainty, that reflect neither
the net reduction of GHG emissions from landfill carbon
sequestration, nor the indirect reductions associated with
beneficial use of landfill methane and recycling activities.  When
considering the total life-cycle analysis of solid waste and
recycling services, SWICS believes that the total GHG emissions
from our industry are neutral or even negative.

The Draft Scoping Plan focuses exclusively on landfills and
assumes landfills are only able to capture 75% of the methane they
generate in their gas collection systems.  As SWICS has repeatedly
pointed out, this assumption is based on a highly uncertain US
Environmental Protection Agency (EPA) estimate of the average
collection efficiency of landfill gas systems nationwide. 
Furthermore, this assumption does not reflect the more aggressive
regulatory system that exists in California, nor does it reflect
our drier climatic conditions, both of which affect landfill gas
generation and collection efficiencies.  As we have previously
commented, most California landfills with gas collection systems
operating in compliance with Air District requirements are capable
of achieving 90%+ landfill gas collection efficiencies.  The
projected reductions in the Draft Plan associated with increased
landfill regulation are based on a 75 % gas collection efficiency
when a much higher efficiency likely already exists.  Thus, the
projected benefits of increased landfill regulation are likely to
be significantly overstated.  We recommend that if CARB wants to
promote even deeper reductions than are already occurring, then
CARB should allow methane destruction offsets to be generated at
any landfill that can demonstrate greater than 75% collection and
destruction.

We support reporting of greenhouse gas emissions when a source is
capable of providing accurate and specific accounting of its
emissions and those emissions can be placed within the context of
the operations as a whole.  We are working to develop an accurate
and transparent protocol that may be used in California and
nationwide.  The recently revised and updated SWICS landfill
methane and sequestration protocols that are attached to this
letter are the first attempt to do this.  We believe the SWICS
protocols improve and refine EPA and UN Intergovernmental Panel on
Climate Change (IPCC) modeling, and should be considered by CARB as
a first step to the development of better protocols for estimating
GHG emissions from landfills.  Once completed, CARB should
consider the model developed by Bogner and Spokas from the
landfill research supported by the California Energy Commission:

http://www.energy.ca.gov/2007publications/CEC-999-2007-039/CEC-999-2007-039.PDF

CARB has recently completed a comprehensive revised inventory of
greenhouse gas emissions.  The roughly 350 landfills in that state
were found to emit approximately 5.62 MMTCO2e of the total
statewide emissions of 484.40 MMTCO2e in 2004 – or about 1.16
percent of total statewide emissions.  But, as noted above, these
emission estimates are overstated due to the reliance on the
assumption that California regulated landfill gas collections
systems are only 75% efficient – and by ignoring the carbon
storage benefits of landfills.

Using the SWICS protocol for estimating GHG emissions from
California landfills, would result in total estimated landfill
emission at less than 3.0 MMTCO2e – or less than 1% of California
emissions.  But, even that would be an overstatement if the
estimate failed to recognize landfills as carbon storage sinks
that effectively reduce CO2 emissions, as is done by both U.S. EPA
and the IPCC.  The recent CARB inventory of GHG emissions
acknowledges that landfill carbon storage is equivalent to about 5
million tons of carbon per year.  If converted to CO2 equivalents
this would be equivalent to approximately 19 MMTCO2e – meaning
that total landfill carbon storage vastly exceeds the emissions
estimate of carbon released by either CARB or SWICS for California
landfills.  Focusing exclusively on the overstatement of GHG
emissions from landfills is bad public policy, and not supportable
by either good science or international GHG protocols.

The Scoping Plan lacks a comprehensive view of Solid Waste and
Recycling Activities

SWICS believes that the GHG reduction benefits associated with
recycling and renewable energy production are well known and
understood.   Life cycle assessments by U.S. EPA and its
contractors, referenced in this comment letter, document the
benefits of recycling and energy Recovery from waste.  We urge
CARB to recognize these sources of information and incorporate
them into the Final Scoping plan.

In addition, Waste Management (WM) commissioned a report by ICF
International that both documents the benefits of recycling – and
explores the difficulty of assigning “credit” to any one party
associated with recycling activities (Attached).  However, the
difficulty in translating recycling benefits into tradable “offset
credits,” should not limit CARB from promoting increased recycling
in the Scoping Plan as an important tool for achieving GHG
reductions.

Currently there is no widely accepted protocol that accurately
accounts for greenhouse gas emissions from solid waste management
operations on a site-specific basis.  This includes fugitive
emissions from landfills, emissions from compost facilities,
emissions/sinks associated with recycling and materials recovery
programs, and offsets from waste to energy operations. 
Development and acceptance of such reporting protocols is the
first priority, and must be accomplished prior to inclusion of
solid waste management and recycling activities into any reporting
or regulatory framework.

SWICS supports the reasonable and responsible development of a
unified GHG regulatory system for solid waste and recycling. 
While we are one of many voices calling for consistency in
approaches to regulating GHG emissions and sinks in our industry,
our plea for unification of programs and approaches has been less
than successful to date.  More than half the states in the United
States and most Canadian provinces have contemplated some type of
Climate Change initiative. 
Unfortunately, none of these initiatives are truly coordinated. 
In fact, every reporting platform we have seen developed or that
is in development at present is different from every other in some
important respect including the initiatives under the California
Climate Action Registry (CCAR), The Climate Registry (TCR), the
California Air Resource Board (CARB) the State of New Mexico, the
State of Washington, the State of Oregon, and the U.S.
Environmental Protection Agency (US/EPA) – just to name a few.   


Currently, the CARB has mandatory reporting requirements that only
require the reporting of GHG emissions from landfill flares,
landfill gas to energy emissions, biomass conversion technologies,
and waste-to-energy facilities – despite the fact that the vast
majority of these emissions are biogenic in nature. 

Recognition that solid waste management and recycling are
essential public services and that GHG emissions are very low and
have decreased steadily over the past 30 years.

With respect to decisions regarding solid waste management and its
potential inclusion in any GHG regulatory framework, policy makers
must be cognizant of the essential public service provided by the
management, recycling and disposal of solid waste.  Numerous
policy and regulatory programs promote best practices in solid
waste management.  This has led to substantial reductions in
greenhouse gas emissions over the past 30 years because of
improved landfill design, increased recycling, waste-to-energy,
and improved waste collection and transportation efficiencies.  

In fact, if other sectors of our economy had reduced greenhouse
gas emissions to the extent accomplished by the solid waste
industry, America would have exceeded the requirements of the
Kyoto Treaty.  For example, Weitz et al. (attached) estimate that
the actual level of greenhouse gas emissions produced by the solid
waste management and recycling sector is about 25 percent of the
levels emitted 30 years ago, and less than 20 percent of what
would have been emitted if waste management practices had
continued along the 1974 technology path.
Reductions are not achieved without cost, and the costs associated
with solid waste management are directly passed on to the general
public.  Additionally, costs associated with GHG regulation
impacting the solid waste and recycling sector will impact all
cities and municipalities whose job it is to collect and dispose
of waste. As such, we urge CARB to work closely with municipal
governments and their service providers in fashioning a greenhouse
gas program that reasonably and responsibly impacts the provision
of these essential services.

The solid waste industry as a whole represents a small fraction,
and in some cases a de minimis amount of greenhouse gas emissions.
 If GHG sinks associated with solid waste and recycling services
are fully incorporated into a life-cycle assessment of our
industry, we believe that net emissions will be substantially less
than zero.  Few other industries can make such an assertion. 

The Complexity of Solid Waste Operations Must be Reflected in the
proposed GHG Regulatory Framework Taking into Account Lifecycle
Impacts

The regulation of GHG emissions from a single source (landfills)
without taking into account the totality of the management system
is counterproductive and could result in an increase rather than a
decrease in emissions.  

Reporting requirements must incorporate the complexities of all
sources within a sector from a life cycle perspective.    Failure
to accurately quantify GHG emissions and sinks from all solid
waste management technologies and operations will lead to an undue
burden and an improper result.  If reporting is left to a
simplistic approach, CARB risks misstating the sector’s true
impact on climate change and losing the opportunity to identify
real reduction strategies. 

Recycling, effective long-term carbon storage practices, and
reduced well-to-wheels transportation fuel carbon intensity should
be recognized in emissions reporting and reduction strategies.

Attached to this letter is a pdf chart titled “Solid Waste and
Recycling Life-Cycle.”  The chart is from US EPA’s “Solid Waste
Management and Greenhouse Gases: A Life-Cycle Assessment.”  As
highlighted in the large green-dashed box, the solid waste and
recycling industry encompasses far more than just landfills.  The
solid waste industry processes millions of tons of residential and
commercial recyclables in our recycling facilities.   The solid
waste and recycling industry offers communities and businesses
more effective and affordable recycling options as well as
providing manufacturers and end users with the secure, consistent
stream of high-quality raw materials they need to maintain
operational efficiency -- taking the reduce-reuse-recycle concept
into virtually every venue we serve. In residential areas, we are
creating sustainable recycling programs through working
partnerships with local communities and municipalities. As
marketers of post-consumer and post-industrial commodities, we are
providing fiber, non-fiber, scrap metal, textiles, electronic scrap
and plastics to end-users of recycled materials worldwide.

The significant impact of recycling and other greenhouse-gas
saving activities such as waste-based energy, carbon storage are
not recognized by the CARB Scoping Plan.

The development of a Scoping Plan that incorporates a more
comprehensive view of solid waste and recycling activities will
lead to greater insight and better policy decisions.  We therefore
propose that any GHG regulatory framework incorporate the
following:

·	Recyclable materials including estimates of greenhouse gas
emissions avoided resulting from the diversion of recycled waste; 


·	Carbon sequestered by the landfills and other solid waste and
recycling activities, expressed as CO2 equivalents, and,

·	Renewable energy or fuel generated by waste operations, either
at the landfill, at biomass facilities, or at waste-to-energy
facilities.

The Scoping Plan should not rely solely on unsubstantiated
generalized estimates of fugitive emissions from landfills or
emissions from our solid waste and recyclable material collection
vehicles without consideration of the emission and reductions
associated with the multitude of activities we conduct and
services we provide.  Rather than focus solely on landfills, SWICS
strongly recommends that CARB develop a comprehensive approach to
solid waste and recycling in the Scoping Plan.  

For example, by following the procedures outlined in the U.S.
EPA’s “Solid Waste Management and Greenhouse Gases: A Life-Cycle
Assessment of Emissions and Sinks”
(http://www.epa.gov/climatechange/wycd/waste/SWMGHGreport.html),
it is possible to show that most modern waste management practices
result in virtually zero (or better) net greenhouse gas emissions. 
Thorneloe et al. have written a paper (attached) that describes how
EPA’s Decision Support Tool can be applied to communities to
determine emissions.  This paper shows that the solid waste
management activities of a community of average size (population:
750,000) with 30 percent recycling and residual disposal to a
landfill with landfill gas to energy has virtually a zero carbon
footprint.  That is, if all of the emissions sources and sinks are
taken into account, the solid waste management and recycling
activities of an average size community with these attributes are
essentially carbon neutral.  These attributes are very similar to
that of the solid waste management and recycling systems in many
states today.  
We are aware that there may be a desire to focus on only a
particular waste management method (e.g., landfills).    However,
closing the door to a comprehensive evaluation of the net carbon
footprint of an entire industry is not appropriate.  For example,
composting is considered by some to be the most preferable method
of handling organic wastes – despite that there are no understood
or accepted protocols for estimating GHG emissions from composting
and other organic waste management and recycling activities.  

CARB must recognize and encourage the comprehensive assessment of
all of the emission sources and sinks associated with the solid
waste and recycling industry due to its particular complexity.  If
CARB fails to encourage assessment of all greenhouse gas emissions
sources and sinks in its regulatory scheme, we never will find
better ways to achieve the underlying goal of lessening the impact
of greenhouse gas emissions entering our environment.   

A number of our SWICS members have completed (or are completing)
entity-wide reporting of GHG emissions to the California Climate
Action Registry.  For example one SWICS member, Waste Management
(WM), has recently completed its 2006 inventory of greenhouse gas
emissions from its California facilities.   Many SWICS members are
in the process of identifying the information sources, data
collection methods and data systems required to conduct a
company-wide greenhouse gas emissions inventory – with a goal to
collect 2009 data for completing an inventory by 2010.  The 2006
report of SWICS member’s California CO2 emissions are available
on-line at (and is summarized in the attached table):

http://www.climateregistry.org/CARROT/public/reports.aspx 
(enter name of reporting entity)

In addition to reporting direct and indirect CO2 emissions in
California as required by CCAR, WM also provided voluntary
supplemental reports including:

·	WM processed recyclable material and associated GHG reductions
based on US EPA’s WARM model 

·	SWICS-based estimates of landfill emissions and sinks

·	Estimates of avoided fossil fuel emissions from renewable energy
generation at landfills and biomass power plants

As an example and as summarized in the attached table, WM’s
largest source of California greenhouse gas emissions is from its
4000-vehicle fleet in that state.  WM’s landfills, using the SWICS
protocols, are a distant second.  WM’s other direct and indirect
emissions are very small.  However, the potential greenhouse gas
reduction from the recyclable materials collected and processed in
California and the amount of carbon sequestered in WM’s California
landfills during 2006 greatly exceeded WM’s total emissions.  The
results of other reporting entities (e.g., Republic Services,
etc.) are similar in nature and consistent with that of WM’s.  If
consideration and recognition is given to the GHG reduction
benefits of recyclable materials, energy recovery and landfill
carbon sequestration, the solid waste industry’s operations could
be considered a significant net carbon sink.  

Carbon sequestration should be reflected in the estimation of GHG
emissions of individual landfill sites and other activities that
store carbon

The U.S. Environmental Protection Agency recognizes that landfills
act as greenhouse gas sinks in sequestering anthropogenic CO2e. 
Similarly, in preparing the recent inventory of emissions, CARB
has determined that annual carbon storage in California landfills
is equivalent to about 5 million tons of carbon per year.  If
converted to CO2 equivalents this would be equivalent to
approximately 19 MMTCO2e – vastly exceeding the estimate by either
CARB or SWICS for GHG emissions released by California landfills. 
This carbon stored in landfills would have been released as CO2 to
the atmosphere were it not for placement in an anaerobic landfill
environment.  We urge CARB to recognize carbon sequestration from
a variety of sources, including landfills, forest and agricultural
soils, and through composting.  

A well-designed and operated landfill achieving 92 percent methane
capture and oxidation could be considered virtually a “carbon
neutral” landfill the basis of an overall life-cycle assessment
over the lifetime of the landfill – from initial operations
through the end of post-closure care.  That is, with a 92 percent
collection efficiency, the amount of lifetime fugitive landfill
emissions would be roughly offset by the amount of lifetime
landfill carbon storage.  SWICS members are committed to ensuring
that the landfills we operate achieve the maximum amount of
methane collection and destruction (including maximum energy
recovery) that is economically feasible.  In many cases we believe
we are already achieving overall 92 percent methane collection and
destruction efficiency at many of our landfills in California.

CARB should recognize the important role of landfills in storing
carbon and preventing CO2 emissions that would have otherwise
occurred.  This carbon storage, or “sequestration,” is important
because it removes carbon from the natural carbon cycle
indefinitely, reducing net emissions of GHGs.  The effect of this
process on overall U.S. GHG emissions is very significant as it
offsets more than 50 percent of landfill methane emissions (as
estimated by US EPA), and exceeds, in absolute magnitude, the
emissions from 47 of the 54 source categories in the US EPA’s
nationwide GHG inventory.

Both the IPCC and US EPA recognize and account for carbon
sequestration of un-decomposed wood products, food scraps and yard
trimmings disposed of in landfills for purposes of preparing
national inventories.  SWICS recommends that CARB, should it
decide to apply reporting requirements to MSW landfills, to
likewise incorporate carbon sequestration into the landfill GHG
emissions calculation methodology it adopts for use.  Just as
methane oxidation in cover and methane collection and combustion
are included in the estimation of landfill emissions, so too
should carbon sequestration be an integral component of the
landfill mass balance calculations.  This will ensure
completeness, transparency and consistency with the national
inventory guidelines of both IPCC and the US EPA.  It will also
ensure a complete characterization of all human-related GHG
emissions and sinks for landfills.

We have attached the following report to this letter prepared by
ICF International (“Landfill Gas Storage and Greenhouse Gas
Inventories, ICF International, 2007”) that further documents the
reality of carbon storage or sequestration in landfills.  

Accounting for Biogenic and Anthropogenic Emissions 
Any GHG reporting and regulatory scheme must take into account the
difference between biogenic and anthropogenic greenhouse gas
emissions and sinks.  Emissions produced from biomass sources are
distinctly different than anthropogenic fossil fuel sources of
emissions and should be reported and counted accordingly.  At the
least, biogenic sources of emissions should be treated as carbon
neutral and anthropogenic sinks of carbon should be encouraged. 
CARB’s Draft Scoping Plan should clearly provide that emissions
and sinks of CO2 equivalents should be bifurcated into
anthropogenic and biogenic CO2 to understand the true impact of
human activities on Climate Change.
The Western Climate Initiative (WCI) is currently in the process
of proposing a GHG reporting and regulatory framework for its
members – including California.  While the reporting framework may
require the reporting of biogenic emissions, it appears that WCI
will not be subjecting biogenic emission to the proposed Cap and
Trade Framework.  CARB should follow suit and clearly articulate
in the Scoping Plan that biogenic emission of GHG (principally
CO2) will not be subject to regulation or Cap and Trade.

Thank you for consideration of our comments. Many SWICS members
are currently working towards defining their carbon footprints
through the California Climate Action Registry or other reporting
platforms.  Calculating and reporting greenhouse gas emissions
from the solid waste and recycling industry will be a
time-consuming and complex process, but SWICS members are
committed to establishing protocols that provide accurate and
comprehensive accounting of our industry’s activities.  We are
equally committed to working with CARB and its WCI partners to
establish an accurate and meaningful GHG regulatory program. 
 
We look forward to working with you.
 
Sincerely,


Anthony M Pelletier, P.E.Regional Engineer, West RegionAllied
Waste Industries925-201-5807Tony.Pelletier@awin.com	Frank Caponi,
P.E.Supervising EngineerCounty Sanitation Districts of Los Angeles
County(562) 699-7411  x2460fcaponi@lacsd.org
Edward W. Repa, Ph.D.Vice President Environmental ProgramsNational
Solid Waste Management Association(703) 299-5139 ext.
11erepa@erefdn.org	Rachel OsterLegislative and Regulatory
SpecialistNorcal Waste Systems, Inc.(415)
875-1223roster@norcalwaste.com
Kevin H. Kondru, P.E.Manager, Environmental ServicesOC Waste &
RecyclingOffice: (714) 834-4056Kevin.Kondru@iwmd.ocgov.com	David
ZeigerArea Compliance ManagerRepublic Services, Inc.(510)
262-1669Zeigerd@repsrv.com
Hans KernkampGeneral Manager - Chief EngineerRiverside County
Waste Management Department(951) 486-3200Kernkamp, Hans
HKERNKAM@co.riverside.ca.us	Tom Reilly, P.E.Regional Engineering
ManagerWaste Connections, Inc.(925)
672-3800TomR@WasteConnections.com
Charles White, P.E.Director of Regulatory AffairsWaste
Management/West916-552-5859cwhite1@wm.com	


Attachments:
1.	WM Recycling Offset paper by ICF
2.	Current MSW Industry Position and State-of-the-Practice on LFG
Collection Efficiency, Methane Oxidation, and Carbon Sequestration
in Landfills, Prepared For: Solid Waste Industry for Climate
Solutions (SWICS)
3.	The Impact of Municipal Solid Waste Management on Greenhouse
Gas Emissions in the United States, Weitz et al., JAWMA, September
2002
4.	Moving from Solid Waste Disposal to Materials Management in the
United States, Thorneloe et al., October, 2005
5.	Waste Management Greenhouse Gas Emission and Sinks For
California -- 2006
6.	Landfill Carbon Storage and Greenhouse Gas Inventories,
prepared by Randall Freed, Sarah Shapiro, Brad Hurley, ICF
International
7.	Solid Waste and Recycling GHG Life-Cycle