Comment Log Display

The City and County of San Francisco Department of the Environment
submits the following comments on the Waste Management Sector of
the AB 32 Scoping Plan Update.  We appreciate many valuable
recommended actions proposed in the Sector Plan.  Overall we
strongly encourage not to incentivize landfilling, incineration, or
“thermal/conversion” technologies and prioritizing incentives for
anaerobic digestion and composting as well as reuse, recycling, and
remanufacturing.  More specifically, we strongly encourages that
the AB 32 Scoping Plan:
•	Prioritize mandating source separated collection of food scraps,
starting at least with commercial food scraps, to maximize carbon
emission reductions through edible food reuse, animal feed, and
anaerobic digestion and/or composting; and prioritize a ban on
landfilling organic materials.  Start phasing in the landfill ban
with landscape plant debris as 23 other states have already done,
then commercial food organics as states such as Massachusetts are
doing in 2014, and then residential food organics. San Francisco
has mandated the source separation for composting collection of all
organic materials since 2009, with all sectors participating.
Landfill bans or other mandates for composting collection have
proven to be the most effective policies in diverting organics from
landfills.  Therefore, CalRecycle and CARB need to prioritize the
adoption of these regulations in order to achieve the 2020 goals of
AB 32 and AB 341.
•	Prioritize incentives for diversion of organic and recyclable
materials from disposal (landfills and incinerators) into reuse,
recycling, anaerobic digestion (AD) and/or composting as they are
proven technologies that provide significant carbon emission
reduction benefits compared to landfilling or incineration.  San
Francisco has found that 90% of the entire discard material stream
(“waste”) can be reused, recycled or AD/composted and CalRecycle
studies have found 2/3rds of disposed material is recyclable or
compostable.  Yet millions of tons of recyclable or compostable
materials are still disposed. The biggest obstacle to increased
diversion and resulting reduction in carbon emissions is the direct
economic competition from landfilling.  Emission reduction benefits
shown from compost use reducing fossil fuel derived fertilizers,
pesticides, irrigation and carbon sequestration, should be
accounted for as well as used anaerobic digestion gas to offset
fuel emissions.  In addition to mandated collection and disposal
bans, increased financial incentivizes are needed to support and
develop the collection, processing and marketing infrastructure for
beneficial diversion to effectively compete against disposal,
including local reuse and remanufacturing such as wood
remanufacturing a higher and better use that biomass burning.  
•	Do not incentivize landfill gas used for energy as that will
effectively subsidize the landfilling of organic materials and can
run counter to efforts to divert organic materials from landfill
into more carbon beneficial   anaerobic digestion and/or
composting. Landfills should be required to convert their captured
gas into energy but not subsidized and given further competitive
cost advantage over diversion from landfill. Increased landfilling
of organics will increase emissions of greenhouse gases even with
landfill gas capture systems and thereby increase global warming
pollution, undermining the intent of AB 32.
•	Do not incentivize incineration (including “thermal or
conversion” technologies) of organic materials as that effectively
subsidizes the burning of organic materials and can run counter to
efforts to divert organic materials to more proven carbon
beneficial anaerobic digestion and/or composting. Incineration
results in increased carbon emissions compared to anaerobic
digestion and composting that sequester carbon with the land
application of compost or digestate. Burning materials made from
non-renewable resources should not be considered renewable energy.

•	Do not exempt incineration or landfill gas from the cap-and-trade
program.  Exempting incineration (thermal or conversion) or
landfills from cap-and-trade would give these facilities a
competitive advantage over higher value diversion programs and
facilities resulting in increased net carbon emissions.

Thank you for the opportunity to comment.