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I am writing on behalf of the Calif. Assn. of Recycling Market
Development Zones (CARMDZ), which represents 36 special districts
covering over half of the state -- with at least 15 of those zones
including disadvantaged communities.  RMDZs partner with CalRecycle
to offer specialized assistance to processors and manufacturers
utilizing recycled materials collected in California, cutting GHGs
and landfilling, and generating sustainable, high quality jobs with
materials that would otherwise be landfilled or go off shore.  The
priority of such work has been recognized in CalRecycle's strategic
plans, but these programs have been under-resourced for nearly a
decade.

The clear and continuing commitment in the DRAFT Second Investment
Plan to prioritize infrastructure development for organic materials
is "right on the money", since proper management of organics is
undoubtedly critical to reducing generation of methane.  That said,
CARMDZ feels that it should also be a continuing priority of the
next investment plan to support infrastructure development for
other recycled materials (carpet, plastics, mattresses, etc.),
particularly since this was a key Waste Sector Scoping Concept
previously established by ARB.

Currently, up to 80% of recycled materials are exported to China or
other offshore markets, and Chinese factories are still up to 70%
coal fired.  Investing now and through the next investment plan in
domestic facilities for recycling-based manufacturing will
significantly reduce GHGs generated from California materials; will
create stable jobs in disadvantaged and other communities; and will
help to implement California's ambitious 75% recycling by 2020
goal, which is a structural pathway to institutionalized GHG
reduction statewide.

Investing GHG dollars in recycling AND compost facilities will also
leverage private investment in innovative, evolving technologies,
and can utilize a variety of funding mechanisms besides grant
programs, including GHG Reduction and RMDZ loans, and broader
incentives such as "recycling incentive fees", which reward
recycling based manufacturers on a per pound basis for
incorporating recycled materials into finished products.

Thank you for the opportunity to give input to the Second
Investment Plan, and for your consideration of this feedback.