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According to CARB's own estimates, there is an estimated 40 million
tons of unrecycled waste pouring into California's landfills each
year. This is roughly equal to the amount that was accumulating
before California's very successful recycling policies were
enacted. 

The CIWMB needs to pursue a more aggressive approach than merely
extending its rather mature methane capture and composting
solutions. Composting is not a solution for two reasons: 1) the
resulting compost does not meet a consistent purity standard to
make it marketable and 2) the demand for compost is so low that
these programs are not economically sustainable. California's
landfills already lead the nation in their design for capturing
methane. 

Most unrecyclable trash can be used for generating renewable
electricity or converting into carbon-neutral biofuels. Some of
our biggest landfills in our largest cities are scheduled to close
within the next decade necessitating trans-shipment to other sites
- sometimes hundreds of miles away. This is a perverse waste of
GHG emitting trucking and rail fuel when conversion technologies
sited at waste sorting 
facilities can instead cleanly reduce the volume going to
landfills by approximately 
85% (see independent 2005 UC/Riverside analysis (see
http://bioconversion.blogspot.com/2005/12/ca-ab-1090-111605-results-of.html
). 

"Zero waste" is an unattainable idealistic vision unless it
embraces conversion technologies as an extension of recycling.

Without question municipalities should receive diversion credit
for redirecting unrecycleable biomass from landfills to conversion
technologies that can cleanly produce bioenergy and bioproducts
from the refuse.

There should also be a recycling integrity clause in the Scoping
Plan that insures that all recycled waste is turned into products
within the U.S. to reduce and control global GHG emissions of our
recycling waste stream. Currently most recyclables are 
shipped (at great GHG expense) to China for conversion because of
that country's poor wages, lack of workers rights, and
unacceptably low pollution standards (see
http://biowaste.blogspot.com/2007/01/recyclings-
china-syndrome.html ).