Comment Log Display

Comments From:	Scott Walker, PE 
Date:			October 31, 2013

Thank you for considering the following comments on the discussion
draft document (these comments are copied in the attached .pdf
file).

1.	The prior Forest Sector Greenhouse Gas Inventory (1990-2004) has
been removed from the most recent Statewide Inventory (2000-2011)
and is indicated as currently under development. The prior
Inventory and protocols for the Forest Sector (including technical
support document excerpt dated May 2009) included discarded forest
wood product biogenic emissions from landfill, composting, and
biomass combustion facilities.  Wood product emissions in the prior
Forest Sector Inventory offset Forest carbon sinks, have potential
to be double counted in the Waste Sector, are likely to
significantly change with organic waste management diversion
measures identified in the Waste Sector Plan and CalRecycle AB 341
Strategies, and will impact the relative AB 32 Target benefits of
waste management measures. 

The discussion document should acknowledge the need to coordinate
the Waste and Forest Sectors and identify the process and timeline,
including stakeholder involvement, to ensure a science-based
objective analysis of net reduction in emissions, and better
understanding of the relative benefits of waste management
measures.  

2.	New direct measurement studies and monitoring results to date
from the Landfill Methane Capture Early Action Measure (adopted
2009) are available to improve understanding of the performance of
the measure in reducing emissions and federal NSPS/EG requirements.
  

Will the discussion document and Waste Sector Plan include
evaluation, with stakeholder involvement, of the results to date of
the Landfill Methane Capture measure and reflect those results in
estimates of net reduction in emissions for waste management
strategies?

3.	The most recent Greenhouse Gas Inventory (2000-2011) includes
methane and NO2 emissions estimates for composting in Biological
Treatment of Solid Waste. These estimates will change with waste
management strategies, warrant update of emission factors, and
addition of anaerobic digestion.

Will the discussion document and Waste Sector Plan include update
of these emission factors and reflect those results in estimates of
net reduction in emissions for waste management strategies?