Comment Log Display

LACSD offers the following comments on the discussion concerning
Recycling and Waste Management Strategies in the Draft Scoping
Plan:

1.	Page C-123: Section RW-1 calls for a reduction of 1 MMTCO2 eq.
from the Solid Waste and Recycling Sector. As we and other
industry representatives have continually stated to CARB in the
past, the assumptions underlying this value are incorrect causing
the projected reductions from this sector to be too high.  The
draft Scoping Plan assumes that landfills are only able to capture
75% of the methane they generate in gas collection systems. This is
based upon a highly uncertain US Environmental Protection Agency
estimate 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. In fact, we believe that most California
landfills with gas collection systems operating in compliance with
air district regulations are capable of achieving 90%+ landfill gas
collection efficiencies.  Here at Sanitation Districts landfills,
we have determined collection efficiencies up to 99%.

In addition to faulty assumptions in determining fugitive methane
emissions from landfills, the Draft Scoping Plan fails to provide
a complete accounting of overall emissions from solid waste
management activities, but chooses only to focus on landfill
emissions.  The simplistic approach taken by CARB will lead to an
undue burden on landfill operators, misstate the true impact of
this sector on climate change and lose opportunities to identify
real reduction strategies. CARB needs to take a comprehensive
approach examining the complexity of all the sources within a
sector from a life cycle perspective, carefully examining all GHG
emissions and sinks.

A comprehensive evaluation should look at factors such as carbon
sequestration at landfills, recycling, composting, transportation,
and use of renewable energy. When considering the total life-cycle
analysis of the solid waste management industry, we believe that
the net GHG emissions from our industry are neutral or even
negative.  The assessment should be performed on the industry as a
whole, but even looking at individual components of the sector more
completely paints a different picture.  For example, landfills are
targeted solely for emission reductions because they are viewed as
a significant source of GHG emissions; however, if more appropriate
assumptions are made for collection efficiencies, and credits are
allowed for carbon sequestration that occurs at all landfills, GHG
emissions from this source would be considered carbon neutral or
negative.  Carbon sequestration in landfills is a well-established
fact, recognized by the IPCC, EPA, and CARB. In preparing the most
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 MMTCO2 eq. – vastly
exceeding the estimate by CARB for GHG emissions released by
California landfills.

This comprehensive life cycle approach is especially important in
the Draft Scoping Plan recommendation that local and regional
governments “change the carbon footprint of their jurisdiction’s
waste and recycling operations … as well as through the promotion
of waste reduction and recycling to community businesses and
residents.”  It makes sense for communities to tackle various
components of their waste management decisions, while working with
the State, but it is very important from an accounting standpoint
in the Draft Scoping Plan that no double counting occur between
the Local Government Sector, and the Recycling and Waste Sector. 
Local governments and communities in performing their waste
management evaluations should rely on a comprehensive life cycle
approach to develop an accurate picture of how waste reduction and
recycling should be promoted in the community.  An example was
provided above of accounting for carbon sequestration when
determining landfill GHG emissions. Another example would be the
management of green waste within a community.  From a GHG
perspective only, the Sanitation Districts have determined that
both composting and using green waste as an alternative daily
cover (ADC) at landfills provide GHG benefits, but using green
waste as an ADC provides more than a four fold reduction in GHG
emissions relative to greenwaste composting. Both are important
waste diversion techniques, but only a comprehensive life cycle
analysis can provide accurate GHG emission data to be considered
by decision-makers.

In conclusion, the Draft Scoping Plan provides a limited and
incorrect view of the Recycling and Waste Sector.  Although the
solid waste industry as a whole represents a small fraction, and
in some cases a de minimis amount of GHG emissions in the State’s
inventory, a comprehensive life-cycle assessment would likely
reveal the industry’s net emissions to be zero, or substantially
less.

2.	Page C-126: Composting of greenwaste and biosolids have the
benefits as stated but also have specific rules in several air
districts to comply with.  In the South Coast, for example, the
requirement to cover biosolids composting facilities caused this
rulemaking (Rule 1133.2) to be the most expensive VOC control
measure in SCAQMD’s history at that time.  ARB cannot
realistically expect significantly more composting projects to
develop in these areas given the already burdensome and costly
control measures in place.

3.	Page C-127: Anaerobic digestion generally requires transporting
a pumpable, mixable fluid to the digester. Tank-type digesters, in
many cases, will require that a municipal or industrial sewage
treatment plant be located nearby to treat the high-strength
liquid waste that accompanies the digestion process unless it can
be lagooned and evaporated.