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Comment 24 for Scoping Plan Update: The Proposed Strategy for Achieving California's 2030 Greenhouse Gas Target and Draft Environmental Analysis (scopingplan2030) - Non-Reg.

First NameEvan
Last NameEdgar
Email Addressevan@edgarinc.org
AffiliationCalifornia Compost Coaltion
SubjectComments on the Draft Environmental Analysis for the Proposed Strategy for Achieving Calif
Comment
The Environmental Analysis needs to recognize baseline conditions
for organic waste management practices such as landfilling when
assessing the emissions from composting and anaerobic digestion
facilities. Page 62 (copied above) states that compost facilities
could potentially increase VOC and PM emissions, but does not
discuss the baseline conditions of these materials being
landfilled, with methane and other associated landfill operations
emissions. Since the SLCP measures are diverting food waste and
green waste from landfilling, these baseline conditions need to be
recognized where the net benefit of both greenhouse gas reductions
and criteria pollutants can be demonstrated when diverting green
waste and food waste from landfills to composting and/or anaerobic
digestion facilities.

Attachment www.arb.ca.gov/lists/com-attach/36-scopingplan2030-VjUGY1Q2V1tWYlNj.pdf
Original File NameCCC 2017 Climate Change Scoping Plan Update Draft Environmental Analysis Comments 020617.pdf
Date and Time Comment Was Submitted 2017-02-15 12:36:06

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