Comment Log Display

 Greetings CARB, 

Juliette P. Bohn Consulting (JBC) strongly supports the strategies
put forth by CARB to reduce short-lived climate pollutants.  The
SLCP reduction strategies are well thought out, and will set
California on a path to achieve significant climate change
mitigation within our lifetimes. This is a very exciting prospect,
and I am grateful for the vision and follow-through of the CARB
staff in developing such a strategic approach.

I want to encourage you to stand your ground fearlessly in regards
to the elimination of organic materials from landfills by 2025.
Putting food waste in landfills creates environmental problems,
economic loss, and social missed-opportunities. Organic waste
diversion and utilization is some of the absolute the lowest
hanging fruit in terms of achieving immediate and permanent GHG
emissions reductions. Furthermore, proven solutions exist to
prevent, reduce and utilize the entire organic waste stream. 

By banning organics from landfills, individuals, businesses,
institutions and local governments will be required to adjust
consumption, donate more food to food banks (reducing food
insecurity), and haul food waste to feed pigs and worms (supporting
local businesses). Furthermore, as a direct result of the this
policy, project developers will no longer have to compete with
cheap landfill tipping fees and can obtain financing and build new
organic waste processing systems under a sustainable business
model. New yard waste and food waste compost systems will be built,
and anaerobic digesters will be constructed at dairies, landfills,
waste water treatment plants / other facilities that have a large
demand for heat and/or electricity and/or a large fertilizer demand
(e.g., food manufacturers, grocery store distribution centers,
casinos, schools, flower farms etc.). Digesters will also be
developed as stand-alone units producing renewable vehicle fuel
(RCNG) supporting the goals of the CA Low Carbon Fuel Standard. 

Additionally, jobs will be created, new economic ripple effects
will be generated in local economies, the agriculture sector will
be supported, and carbon will be sequestered in our soils.  There
is no end to the positive environmental, economic and social
impacts that food waste diversion and utilization will have when
implemented across California. 

For this reason I strongly encourage CARB to fully and quickly
implement the SLCP strategy of eliminating organics from landfills
in the next 10 years. With regulatory cooperation, public - private
partnerships, and thoughtful development approaches, new facilities
can be constructed within a year's time - and sufficient processing
capacity can easily be developed over the next 5-10 years. 

One final comment on this topic: please make sure that digested
residuals do not go back into landfills due to contamination. These
materials still contain volatile compounds as well as valuable
nutrients and carbon sequestration benefits when returned to the
soils. Digester and compost systems vary in terms of the efficacy
of contamination removal and material stabilization. Systems that
can create market-ready soil amendments should be prioritized so
that the intent of this policy is not subverted or diluted. 

Thank you for your consideration of the above comments and thank
you for your fearless leadership with regards to eliminating
organics from landfills as well as other strategies to reduce SLCPs
as fast as possible. 

Sincerely, 

Juliette