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Dear Board,
Attached is a detailed (4 page) comment letter that we submitted
today at the public hearing on the aRB Draft Scoping Plan...
content is both attached as well as in this email.
Thanks for your serious consideration of our recommendations!
Sincerely,
Dan Noble
Executive Director

Mary Nichols, Chair
California Air Resources Board
1001 "I" Street
P.O. Box 2815 
Sacramento, CA  95812



RE: 	Comments on California Air Resources Board's Climate Change
DRAFT Scoping Plan 

The Association of Compost Producers (ACP), is a non-profit
association of public and private organizations dedicated to
building healthy soil, by increasing the quality, value and amount
of compost being used in California.  ACP applauds the leadership
of the State of California and the Climate Action Team, lead by
the California Air Resources Board (CARB) in developing a very
comprehensive Draft Scoping Plan for Climate Change in the State
of California.  ACP appreciates the opportunity to submit the
following comments on the California Air Resources Board's DRAFT
Scoping Plan.

1.	ACP is particularly pleased to support Scoping Plan Emissions
Reduction "Recommendation 15:  Recycling and Waste: Increase waste
diversion, composting, and commercial recycling, and move toward
zero-waste." (page 34).  This is because we agree with CARB that
composting and recycling is a critical link in creating a new
economy that manages carbon sustainably, in all its many chemical
compounds and solid, liquid and gaseous states. However, we feel
the Draft Scoping Plan should give more consideration to larger
impact measures than solely land fill gas capture (1 MMTCO2E in
2020; page 35).  As stated in the Scoping Plan Appendix C, there
is a 10 times greater potential for GHG emissions reductions by
recycling, composting and anaerobic digestion, , It appears that
Draft Recommendation No. 15 does not consider these significantly
greater GHG reduction potentials. 

 

Appendix C: Recycling and Waste Management-Other
Measures Under Evaluation
Table 34*
Reduction Measure	Potential 2020 Reductions MMTCO2E
Commercial Recycling	up to 6.5
Increase Production and Markets for Compost
(studies underway for data development)	3.1
Anaerobic Digestion 	2.2
Total by landfill gas avoidance potential	Up to 11.8
	* from: Climate Change Draft Scoping Plan Appendices, page
C-127-128

2.	Include these measures in Recommendation 15 of this Draft and
not just in the "Other Methods for Evaluation" in Appendix C. 
Currently, these are actions and activities that California
municipalities, utilities and companies have already developed and
are currently doing, and with increased focus, can expand quickly
with marginal additional investment.  This is especially true if
carbon trading moneys can be brought to bear, as they already
exist in other methane avoidance protocols.

3.	Ensure that the Scoping Plan does not explicitly or implicitly
exclude current compost operations from obtaining carbon credits
for additional landfill methane avoidance in the immediate future.
 The capping and methane capture of landfills may have at least
three unintended negative consequences to the above measures if
not properly written and implemented:  1) eliminating methane
avoidance credits for composting, 2) encouraging landfills to
accept more organic carbon to feed methane production and capture
system investments, and 3) creating an inefficient biogas
production industry in landfills vs. more GHG efficient management
technologies outside of landfills.  Emissions of CHG from landfills
is of great concern because it has been identified to be one of the
largest  by volume to address.  However, the recommendation should
support recycling options and processes that avoid placing organic
wastes in landfills, especially if greater GHG emission reductions
can be achieved with recycling, composting and anerobic
digestion.
This includes adopting carbon trading protocols for landfill
methane production avoidance via aerobic composting (or anaerobic
digestion):
a.	Already exist under the UN Clean Development Mechanism (CDM,
Kyoto) Protocols, 
b.	Are under development by CCX (Chicago Climate Exchange), and
c.	 Can be developed quickly by the California Climate Action
Registry (CCAR) for continued use by California composters.

4.	Work with CCAR to quickly develop a Landfill Methane Avoidance
Protocol (like the UN CDM/Kyoto, and CCX protocols).  Thus using
existing cap & trade methods to continue methane reductions in
addition to enhance land fill gas collection, but limit it to
existing carbon in landfills, not causing a draw of recyclable
carbon into landfills.  This protocol is especially useful for
landfills where it is not economic or technically feasible to
install landfill gas capturing systems. [While improved land fill
gas capture is important, enhancing landfill gas production over
other methods (i.e. dedicated energy recovery and/or compost
facilities) would likely enhance the need for landfills to
continue to attract and need "new" compostable and energy rich
organic material in them for years to come, to "feed" the new
capture and conversion system investments.  Landfills are known to
be very inefficient and not easy to control as functioning
bioreactors.  Transitioning to fully controllable bioreactors, by
way of wet anaerobic or dry combustion, will help direct
investment dollars toward a sustainable residuals bioenergy and
organic soil amendment economy, rather than toward relatively
inefficient landfill gas recovery investments.  

5.	Include Soil Carbon Sequestration Management in the Draft
Scoping Plan:  The compost industry helps build an economically
and environmentally sustainable carbon cycle by returning natural
organics to the soil.  As extensively researched and published by
the USDA Soil Quality Institute, (http://soils.usda.gov/sqi) soil
organic carbon plays a key role in managing sequestered organic
carbon to benefit overall watershed health by building and
maintaining soil quality and soil health.  Unfortunately, CARB’s
Draft Scoping Plan did not adequately address the central role
that sustainable organic carbon plays in resources management for
GHG management, i.e. sequestering and managing carbon in plant
materials and residuals.  Soils are mentioned only once in the
Draft Scoping Plan, stating that "…sound quantification protocols
are not yet developed" (page 36).  However, using the "Soil
Conditioning Index" work of USDA,
http://soils.usda.gov/sqi/concepts/soil_organic_matter/som_sci.html,
where it is stated that "Soil organic matter is a primary indicator
of soil quality and carbon sequestration," this deficiency could be
quickly remedied with some short term work using existing
knowledge.  This should be remedied immediately so that policies
flowing from the first Scoping Plan don't run counter to improving
the health of California's soils, upon which all our biological
carbon sequestrating agricultural, forest urban forest and
landscape biological resources critically depend.  

In addition, we would like to see the following elements included
in the final Scoping Plan:
•	By Including Composting in Recommendation 15 Californians also
Support Additional Environmental Benefits Beyond GHG mitigation: 
By returning carbon to soils and/or air (via composting and
bioenergy recovery), not only do we get over to 5 times the GHG
avoidance delivered by only landfill gas capture alone (by CARBs
own estimates), there are many additional and GHG complimentary
environmental benefits of compost that are not provided by
landfill gas capture, including:
o	Water conservation from compost building high organic content
soils on landscape and agriculture lands
o	Integrated organic materials movement and reuse infrastructure
investments and economic sustainability (by local users)
o	Organics fertilizers (compost) energy reduction, vs. solely
chemical nitrogen to soils, which have been shown by ARB Studies
to reduce GHG production ("ARB has begun a research program to
better understand the variables affecting emissions (Phase 1) and
based on the findings will explore opportunities for emission
reductions (Phase 2).")
•	Implement in all of CARB's Climate Change "rule making" for GHG
reduction regulations and rules that are performance based, not
best available technology (BAT) based.  The BAT method has proven
over the years (at both the national and local levels) to limit
technology innovation by causing environmental improvement
implementation to get "stuck" with, or blocked by, old
technologies.  This limits rather than enhances ongoing new
methods of development and implementation.  Continuous innovation
is a hallmark of market and performance based approaches, but not
BAT rules based approaches.
•	Include recommendations outlined in the CARB Economic and
Technology Advancement Advisory Committee (ETAAC) report
(http://www.arb.ca.gov/cc/etaac/ETAACFinalReport2-11-08.pdf)
directly in the current Scoping Plan, i.e. 
J.     Develop Suite of Emission Reduction Protocols for Recycling

K.     Increase Commercial-Sector Recycling 
L.     Remove Barriers to Composting 
M.    Phase Out Diversion Credit for Greenwaste Alternative Daily
Cover Credit 
N.    Reduce Agricultural Emissions through Composting 
These are consistent with CIWMB’s Strategic Directives
(http://www.ciwmb.ca.gov/BoardInfo/StrategicPlan/) which include
specific steps to minimize waste (SD 3), move toward producer
responsibility (SD 5) and support market development (SD 6).
Subdirective 6.1 addresses removal of 50% of organics in the waste
stream by 2020, addressing the largest category of disposed
materials, and contributing, with the other measures to 10X the
GHG reduction of simple landfill gas capture.  We would like to
see this incorporated into the plan.

In Conclusion:  
The governor’s Climate Action Team itself has identified Zero
Waste/High Recycling Programs as a "high-confidence" strategy with
significant GHG reduction potential of up to 11.8 million tons CO2
equivalent by 2020 (see:
http://climatechange.ca.gov/publications/factsheets/2005-06_GHG_STRATEGIES_FS.PDF,
and cited above in the Draft Plan Appendix C).  ACP believes this
>10 million tons CO2 equivalent by 2020 represents a conservative
estimate of the emission reduction potential of composting and
reuse/recycling to help contribute to our GHG reductions. 
Therefore, composting, along with other reduce, reuse and
recycling systems have been identified as valuable climate
protection factors by the Governor, as well as ETAAC and the
composting industry.  We strongly support the elevation of these
strategies into the body of the Scoping Plan for immediate
implementation by our industry in support of GHG reduction for our
State.

Thank you for your serious consideration of our recommendations.

Sincerely,


Dan Noble 
Executive Director
and
ACP Board of Directors:
Bob Engel, Engel & Gray Inc.
Kathy Kellogg-Johnson, Kellogg Garden Products
John Gundlach, Garick Corporation
Lorrie Loder, Synagro
Mike Moore, Orange Co. Sanitation District
Mike Sullivan, Sanitation Districts of Los Angeles County
Jeff Ziegenbein, Inland Empire Utility Agency

CC:  Climate Action Team