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Comment 12 for Short-Lived Climate Pollutant Strategy (slcpstrategy-ws) - 1st Workshop.
First Name: Larry
Last Name: Buckle
Email Address: Buckle@ies-eng.com
Affiliation:
Subject: Comments Regarding the Short-Lived Climate Pollutant Reduction Strategy Concept Paper
Comment:
Thank you for the opportunity to attend the ARB workshop on May 27th and to comment on the Short-Lived Climate Pollutant Reduction Strategy Concept Paper. I only have a few comments regarding reduction of fugitive methane emission resulting from biological degradation of organic materials. I agree and fully support the organics disposal reduction goals of 2020 and 2025. However the resultant emission reduction resulting from disposal avoidance alone could be missing much of the opportunity. As an example: If highly volatile food wastes are allowed to be composted they will likely go anaerobic resulting in VOC emission comparable with landfilling. To mitigate for highly volatile organic waste, food waste should only be anaerobically digested, where generated gasses are captured. If food waste or other organic wastes are aerobically or anaerobically digested, the resultant digestate should not be allowed to be landfill disposed. The resultant digestate will be similar to wood being landfilled. Wood can produce fugitive landfill emission. Adequate food waste pretreatment investment needs to be made such that resultant digestate is marketable. Pressure needs to be placed on the CPUC to attract greater volumes of organic based renewable energy into the natural gas and electricity distribution system. Again, thank you for this opportunity to comment.
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Date and Time Comment Was Submitted: 2015-06-01 14:41:23
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