Comment Log Display

To whom it may concern, 

Interra’s concern is that CalRecycle has given all indications that
it intends to use GHG Reduction Grant and Loan funding to support
projects that actually increase GHG emissions. 

Specifically, the GHG Grant program appears poised to fund
composting projects that process green waste. When presented with 
evidence that demonstrates the counterproductive effects of
allowing green waste composting, Interra hopes CalRecycle and ARB
will ensure that only projects that can demonstrate verifiable
emission reductions will be eligible for funding.

Interra fully supports the diversion of organic waste from
landfills. However, where it can be shown that alternative
processes have higher GHG emissions than landfilling, those
alternatives should not be considered, let alone implemented, just
for the sake of diverting the materials from landfills.

The crux of our position comes from an analysis done by the US EPA,
which was used to create the 2006 WARM model and continues in the
2012 WARM model. Essentially, the US EPA recognized in 2006 that
Food Waste and Green Waste have very different baseline emissions.
Thus, when CA EPA / ARB released their 2011 report relying on the
2006 Model, it was an error to apply the same CERF to both Food and
Green Waste. A CERF assumes a baseline scenario, and those two
feedstock sources have far different baseline emissions. Allowing
all composting projects to rely on the -0.42 CERF figure grossly
overstates the GHG benefits of Green Waste Composting and provides
a tool for policy makers to support those projects over other uses
of green waste (including landfilling in CA) that have lower
life-cycle GHG emissions.

From the EPA Report - “[t]he net GHG emissions from composting are
lower than landfilling for food discards (composting avoids CH4
emissions), and higher than landfilling for yard trimmings
(landfilling is credited with the carbon storage that results from
incomplete decomposition of yard trimmings).”(USEPA, Executive
Summary: Background and Findings, Solid Waste Management and
Greenhouse Gases: A Life-Cycle Assessment of Emissions and Sinks,
3rd Edition, ES-13 (2006), available at
http://www.epa.gov/climatechange/wycd/waste/downloads/execsum.pdf.)

Thus, green waste composting should not be eligible for funding as
it fails the first criteria - reducing GHG emissions. We hope that
such activities are excluded from funding and that ARB continues to
work with CalRecycle and interested parties to develop a more
accurate CERF for green waste composting projects. 

Sincerely, 
Kenny Key
VP, General Counsel
Interra Energy, Inc.