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CCC has been submitting these same comments for over one-year where
cost-effectiveness of AB 32 programs should receive greater
consideration for investments.

The LOA recommended that the Governor may want to increase or
decrease funding for specific programs in the future that will
maximize GHG emission reductions. We look forward to CARB’s
leadership on determining GHG reduction metrics by commissioning an
update to the 2008 Study titled “A Cost-effectiveness Analysis of
AB 32” authored by Stanford University. 

It would be timely for California Air Resources Board adopt,
update, and amend a cost-effectiveness study of AB 32 like the one
presented by Stanford University.  Data from such a study will show
that investments in emerging organics waste management technologies
for the production of renewable natural gas and compost will make
significant and efficient progress towards accomplishing AB 32’s
mandate.

The CCC has encouraged CalRecycle to take advantage of the flow of
information from the Organics Grant Program to analyze the
aggregate data received to provide an assessment of the metrics
associated with greenhouse gas reductions from organics management
approaches. The Cap-and-Trade program raised $850 million for the
2014-2015 Budget with $30 million allocated to recycling and
composting, $200 million to low carbon transportation, and $20
million to improving agricultural efficiency. The allocation was
based upon the investment priorities set by the Governor and his
Climate Action Team which promoted three key sectors that reduce
greenhouse gases: Sustainable Communities & Clean Transportation,
Energy Efficiency & Clean Energy, and Natural Resources & Waste
Diversion.