Comment Log Display

International Engineering Services, Inc. fully supports the efforts
of CARB to reduce short-lived climate pollutants.  The following
comments will address issues associated with methane generated from
solid waste.  

We fully support the diversion of 90% of organic waste from
landfill disposal by 2025.  To accomplish this a significant
portion of this waste will need to go to anaerobic digestion (AD)
for stabilization.   

-	Conventional composting will generate significant volumes of
methane if volatile feedstocks are introduced.  Food waste and
similar volatile feedstock should be ban from windrow, static pile
and other compost processes with the potential to produce VOC from
volatile feedstock. 

-	Digestate produced from AD must not be disposed of in a landfill.
 Best management practice (BMP) must be utilized in collection,
processing (cleaning and sized reduction) and digestion of
feedstock to insure production of digestate appropriate for land
application.   

-	Any AD digestate landfill disposed will be considered disposed
organic waste.  

-	Wastewater treatment plant biosolids will be considered organic
waste, and when disposed in a landfill will be considered disposed
organic waste.  This will also apply to biosolids used for landfill
alternate daily cover.    

-	All wastewater treatment plants should anaerobically digest
primary and secondary solids to reduce emission of VOC. 

-	Gasification of organic waste should be allowed after BMP capture
of marketable materials.  


Thank you for your solicitation of comments.