Comment Log Display

Two issues: 

1. Landfill capture rate: still 75% (wrong figure according to
multiple scientific studies, EPA and CA studies show 36% and
Canadian Clean Fuel Program adopted the 36% figure to match
science). Changing landfill capture rate of methane from 75% (1997
EPA incorrect number) to 36% (correct scientific number, EPA 2023,
NASA/JPL Nature 2020, numerous other studies) properly values and
appropriately incentivizes California food waste AD plants. The 75%
is also dangerous because it sets incorrect standard and precedent
for CI calculation in SB 1440. Canadian CFR has referenced the
latest science and determined landfill capture rate of 36% (see
slide 19 of presentation in this link:
https://drive.google.com/file/d/1OoJXYAsApJI7MDH4PyU1lGjWMLHKfonQ/view?usp=drive_link)

2. Food scraps: definition that is considered landfill diverted
includes only post consumer food waste in solid form (only what's
in trash cans). If food waste is in liquid form, doesn't count
(ketchup or salad dressing or soda that goes to landfill). If food
waste comes from a distribution center or food manufacturing
facility, doesn't count, even though this waste goes to landfill.
All food waste regardless of source should be assigned the
statewide average of total fraction that goes to landfill. We
should not cherry pick sources that are all in or all out of
landfill destiny, particularly since all food waste is regulated by
SB 1383 regardless of source. The attached document has suggested
redlines on the definition to conform with SB 1383 and treat all
food waste the same with a suggestion to simply revise the
statewide fraction of food waste landfilled that should be adjusted
to account for those sources that have lower landfilling rates than
those sources that have higher landfilling rates. Now it's binary,
either landfilled 97.5% or not at all and this is not reality.