Comment Log Display

Edgar & Associates represents many haulers, composters, anaerobic
digestion operators, recycling facilities, and landfills. Our
clients support the 90% of all organics from landfills by 2025
building on the implementation of AB 341 and AB 1826 to 2020, and
AB 1594 and SB 605 after 2020 to 2025. Cap-and-trade revenues will
need to be awarded to build the infrastructure which has shown to
be one of the most cost-effective GHG reduction strategies in order
to compete with cheaper landfills. Permits among the Cal-EPA
agencies for water, waste, and air need to be streamlined.

The SLCP Plan to considering measures to meet a goal of diverting
90% of organics from landfills through source reduction and
organics recycling by 2025, can be accomplished by recognizing and
successfully implementing the current goals for 2020. AB 341 has
set a statewide goal to recycle or compost 75% of the waste stream
by 2020. AB 1826 mandates that more than half of the commercial
organic waste be collected by 2020. 
The projected result of this organics diversion is 8,162,806 new
tons by 2020, and measured in avoided metric tons of carbon dioxide
(MTCO2e) is 4,383,249 MTCO2e by 2020. 

The AB 32 Scoping Plan First Update adopted in May 2014 calls for
5.0 to 7.5 million tons of food waste and green waste be diverted
by 2020 (50% to 75% diversion rate), which results in avoiding
between 3.03 to 5.62 MMTCO2e being avoided (copy attached). At
least 100 new or expanded compost and anaerobic digestion
facilities will be needed by 2020. Note that wood (1.73 million
tons) and compostable paper (1.28 million) were not included in
these AB 32 calculations by CARB. As CARB updates the Scoping Plan
this summer to accommodate the Governor’s Executive Order B-30-15
to provide a framework for achieving the 2030 target to achieve a
40% reduction below 1990 levels by 2030, CARB should harmonize AB
341, AB 1826 and SB 605 programs into the Scoping Plan Second
Update.

SB 605 - 90% Reduction by 2025: Building upon AB 341 and AB 1826 to
get to the 2020 goals, and recognizing green waste alternative
daily cover counting as disposal after 2020, the SLCP Plan goal of
diverting 90% of organics from landfills through source reduction
and organics recycling by 2025 is achievable. The organic waste
disposal from the commercial, residential, and self-haul sectors
when reduced to 10% of their 2014 levels reaches a total reduction
of 14,750,740 tons by 2025, and measured in avoided metric tons of
carbon dioxide (MTCO2e) is 7,922,080 MTCO2e by 2025.

Another 100 new or expanded compost and anaerobic digestion
facilities will be needed between 2020 and 2025. With regulatory
streamlining among the Air Boards and the Water Boards within
Cal-EPA, and with increased cap-and-trade revenue allocation
towards composting, anaerobic digestion and renewable natural gas
production facilities, the industry is poised to achieve these
goals much like achieving the AB 939 recycling goals of the
nineties

Evan Edgar, Principal Civil Engineer