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Comment 10 for Recycling Comments for the GHG Scoping Plan (sp-recyc-waste-ws) - 1st Workshop.


First Name: Michael
Last Name: Wonsidler
Email Address: mwonsidler@hotmail.com
Affiliation:

Subject: 3 R's & Composting to reduce GHG's
Comment:
July 18, 2008

Mary Nichols, Chair
California Air Resources Board
1001 "I" Street
P.O. Box 2815 
Sacramento, CA  95812

RE: California Air Resources Board's DRAFT Scoping Plan as it
pertains to the recycling and waste management sector.

The California Resource Recovery Association (CRRA) is a statewide
non-profit trade group.  CRRA’s more than 550 members represent all
aspects of California’s reduce-reuse-recycle-compost economy. 

CRRA is disappointed that missing from CARB's draft Scoping Plan
(http://www.arb.ca.gov/cc/scopingplan/document/draftscopingplan.pdf)
are any of the following Zero Waste recommendations from Section 4.
IV. (Waste Reduction, Recycling and Resource Management) of the
CARB Economic and Technology Advancement Advisory Committee
(ETAAC) report
(http://www.arb.ca.gov/cc/etaac/ETAACFinalReport2-11-08.pdf): 
J.         Develop Suite of Emission Reduction Protocols for
Recycling 
K.        Increase Commercial-Sector Recycling 
L.         Remove Barriers to Composting 
M.        Phase Out Diversion Credit for Greenwaste Alternative
Daily Cover Credit 
N.        Reduce Agricultural Emissions through Composting 
 
In fact, the only draft Scoping Plan preliminary recommendation
related to Recycling and Waste is "RW-1 Landfill Methane Control"
which is presented in Table 19 on pg. 35 of the draft Plan
(http://www.arb.ca.gov/cc/scopingplan/document/draftscopingplan.pdf).
This lone recommendation represents a narrow-minded strategy to
mitigate the worst climate impacts of wasting AFTER failing to
reduce, reuse, recycle, and compost.   

IF California's commonly recyclable and compostable materials that
are currently disposed as mixed waste were INSTEAD recycled and
composted, THEN the GHG emission reduction would be over 25
million tons CO2 equivalence.  This has been determined using US
EPA's Waste Reduction Model (WARM) model and waste
characterization data published by the California Integrated Waste
Management Board (CIWMB), and has been verified by US EPA Region 9
staff.  

The prioritized ordering of the waste reduction hierarchy to
optimize resource conservation by reusing materials and repairing,
refurbishing, and rehabilitating existing products and buildings to
retain their form and function (and thus embodied energy) holds the
potential for:
•	substantially greater GHG reductions than recycling and
composting alone; and
•	creating ‘green collar’ jobs producing value-added contributions
to the state’s economy.

This above bullet-points are explained and documented further in
the recently-released report Stop Trashing the Climate:
http://www.stoptrashingtheclimate.org

Zero Waste (i.e., reduce-reuse-recycle-compost) is a significant
climate protection strategy which offers tens of millions of tons
of CO2 equivalence GHG emissions reductions annually for
California at low cost (compared to other options) using existing,
proven, environmentally sound methods.
CIWMB’s Strategic Directives were adopted as “the most effective
and efficient means to create a zero waste California.” The
Directives (http://www.ciwmb.ca.gov/BoardInfo/StrategicPlan/)
include specific steps to minimize waste (SD 3), move toward
producer responsibility (SD 5) and support market development (SD
6). Inexplicably, none of CIWMB’s Strategic Directives are part of
the draft Scoping Plan.

Thus, it is difficult to understand why CARB failed to include in
the draft Scoping Plan any of the ETAAC report's Waste Reduction,
Recycling and Resource Management  recommendations. It is
particularly difficult to understand this given that the
governor’s Climate Action Team has already identified Zero
Waste/High Recycling Programs as a "high-confidence" strategy with
significant GHG reduction potential of 10 million tons CO2
equivalent by 2020 (see:
http://climatechange.ca.gov/publications/factsheets/2005-06_GHG_STRATEGIES_FS.PDF).
 CRRA believes this 10 million tons CO2 equivalent by 2020
represents a conservative estimate of the emission reduction
potential of Zero Waste in California.

California is off to a good start toward climate protection via
Zero Waste, thanks to the California Integrated Waste Management
Act of 1990 (AB 939) which mandated 50% waste diversion by 2000. 
It is critical that the Scoping Plan recognize and include Zero
Waste California (i.e., reduce-reuse-recycle-compost) as the
significant climate protection strategy that it is.
 
Finally, CRRA is holding its annual conference and tradeshow next
month, August 3-6, 2008 in Burlingame, CA. The conference theme
and focus is "Carbonopoly: Climate Change is Not a Game We Can
Lose'’.  We will be discussing the Scoping Plan, the ETAAC report,
and more.  This would be a great opportunity to educate and engage
CARB Board members and staff on the significant GHG emissions
potential of Zero Waste in California.
 
The conference program can been viewed at:
http://www.crra.com/2008conf/sessions.html  

Thank you for your consideration.

Sincerely,

Michael Wonsidler

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-07-18 09:12:54



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