Comment Log Display

RE: California Air Resources Board's DRAFT Scoping Plan: (7)
Recycling and Waste Management Sector
 
Ecology Action of Santa Cruz is a nonprofit environmental
consultancy that delivers effective resource conservation
education services, technical assistance and program
implementation. Since Earth Day 1970 EA and agency partners have
created cutting-edge conservation programs, proven their
effectiveness, and established each program as a sustainable
community resource.

Ecology Action is pleased by the adoption of California’s AB 32
climate protection legislation. However, our review of the draft
Scoping Plan reveals that the current document falls short in the
crucial area of Zero Waste.
http://www.arb.ca.gov/cc/scopingplan/document/draftscopingplan.pdf

In addition to our many conservation programs, Ecology Action has
recently launched the CLIMATE SOLUTIONS PROGRAM, a bold leadership
initiative to mobilize the entire Monterey Bay Area to radically
reduce our carbon footprint. Waste reduction and recycling will
play a vital role in achieving the goals of the program to reduce
greenhouse gas emissions. 

In order to achieve these vital protections, Ecology Action
strongly urges the California Air Resources Board to incorporate
the following integral Zero Waste recommendations from Section 4.
IV. (Waste Reduction, Recycling and Resource Management) of the
CARB Economic and Technology Advancement Advisory Committee
(ETAAC) report:
http://www.arb.ca.gov/cc/etaac/ETAACFinalReport2-11-08.pdf

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 
 
Our review indicates that the only preliminary recommendation
related to Recycling and Waste in the current draft Scoping Plan
is "RW-1 Landfill Methane Control" which is presented in Table 19
on pg. 35 of the draft Plan.
http://www.arb.ca.gov/cc/scopingplan/document/draftscopingplan.pdf

Although our organization recognizes the importance of Landfill
Methane Control, this lone recommendation represents an inadequate
and shortsighted strategy to mitigate the worst climate impacts of
wasting AFTER failing to reduce, reuse, recycle, and compost.  By
choosing instead to incorporate a comprehensive Zero Waste
strategy (reduce-reuse-recycle-compost) before waste is generated,
we believe a greater overall impact can be achieved. 

Zero waste effectively preempts substantial greenhouse gas (GHG)
emissions before they are emitted, rather than controlling them
after they are generated. These avoided emissions through Zero
Waste represent a significant source of immediate, permanent and
systemic GHG reductions and a far superior economic and
environmental approach to accomplishing AB 32 goals.

Our organization is concerned that CARB has not chosen to include
any of the ETAAC report's Waste Reduction, Recycling & Resource
Management recommendations in the draft Scoping Plan. 

Using the US Environmental Protection Agency (EPA) Waste Reduction
Model (WARM) and waste characterization data published by the
California Integrated Waste Management Board (CIWMB), and verified
by US EPA Region 9 staff, IF California's commonly recyclable and
compostable materials that are currently disposed as mixed waste,
were INSTEAD recycled or composted, THEN the resulting GHG
emission reduction would be over 25 million tons CO2e.  

The prioritized ordering of the zero waste reduction hierarchy (to
reduce, then reuse, then recycle or compost) further optimizes
resource conservation by reusing materials and repairing,
refurbishing, and rehabilitating existing products and buildings
to retain their form and function (and thus embodied energy),
representing additional potential for:
•	substantially greater GHG reductions achieved through reduction
and reuse than recycling and composting alone; and 
•	considerable GHG reductions through recycling or composting of
items at the end of their life rather than trashing waste; and
•	the creation of ‘green collar’ jobs producing value-added
contributions to the state’s economy.

CIWMB’s Strategic Directives were adopted as “the most effective
and efficient means to create a zero waste California,” all of
these directives are noticeably absent from the draft Scoping
Plan. These Directives
http://www.ciwmb.ca.gov/BoardInfo/StrategicPlan/ include specific
steps to minimize waste (SD3), move toward producer responsibility
(SD5) and support market development (SD6). 

Moreover, the governor’s Climate Action Team has already
identified Zero Waste/High Recycling Programs as a
"high-confidence" strategy with significant GHG reduction
potential of 10 million tons CO2e by 2020 (see:
http://climatechange.ca.gov/publications/factsheets/2005-06_GHG_STRATEGIES_FS.PDF).
 

Zero Waste is thus a significant climate protection strategy which
offers tens of millions of tons of CO2e GHG emissions reductions
annually for California at low cost (compared to other options)
using existing, proven, environmentally sound methods. These
important findings are documented further in the recently-released
report Stop Trashing the Climate:
http://www.stoptrashingtheclimate.org

Based on these data, Ecology Action believes that 10 million tons
CO2e by 2020 represents a conservative estimate of the emission
reduction potential of Zero Waste in California.

California is off to a good start toward climate protection via
Zero Waste, thanks to the California Integrated Waste Management
Act of 1990 (AB 939) which mandated 50% waste diversion by 2000. 
It is critical that the Scoping Plan recognize and include Zero
Waste California (i.e., reduce-reuse-recycle-compost) as the
significant climate protection strategy that it is.

Thank you for your consideration.

Sincerely,

Virginia Johnson
Excecutive Director