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The BioEnergy Producers Association (BPA) is a coalition of private
companies and public agencies dedicated to the development and
commercialization of environmentally preferable industries that
produce renewable sources of power, fuels, and chemicals from
agricultural, forestry and urban biomass wastes and other
carbonaceous materials.  Our membership includes bioenergy firms,
electric utilities, and waste management companies.  

The BPA has reviewed the “Recycling and Waste” section of the
Climate Change Draft Scoping Plan, and requests CARB’s
consideration of additional measures for Landfill Methane Control.
 Landfill Methane can be controlled by disposing of carbon-based
materials that would otherwise be landfilled in the process of
producing liquid and electric energy using clean thermochemcial
conversion technologies.  

Specifically, the Recycling and Waste Sector Preliminary
Recommendation should mirror and complement strategies outlined
for the agricultural sector by encouraging the use of urban
biomass wastes for sustainable energy production.   Deployment of
bioenergy strategies is consistent with the Bioenergy Action Plan,
the Low Carbon Fuel Standard (LCFS), and AB 32 GHG reduction goals
for the following reasons:

Landfill Abatement Potential

The Draft Scoping Plan recognizes fugitive landfill methane gas
emissions as a major GHG precursor, and calls for measures to
reduce the volume of materials flowing to land disposal.  
Existing source reduction, recycling, and composting programs are
credited with attainment of the state’s 54% diversion rate, and
the Plan places principal reliance upon the expansion of these
programs to reduce disposal tonnages in the future, virtually
ignoring the potential to use these waste resources in the clean
production of liquid and electric energy.

Despite the success of its recycling and composting efforts,
California’s high disposal rate has remained virtually unchanged
for the past 20 years.  40 million tons of municipal waste were
landfilled in California in 1989, the year AB 939 was passed. 
This year, despite the progress of recycling, 42 million tons of
waste will be placed in the state’s landfills.  As the state’s
population is expected to grow by some 10 million people over the
next 25 years, this trend is expected to continue.

It is folly to adopt the position that the volume of material that
is being placed in California’s landfills can be significantly
reduced through source reduction, traditional means of recycling
and composting alone.  All methods of disposal must be
incorporated in any effective plan, and this includes the complete
disposal (i.e., destruction) of carbon-based wastes in the process
of producing the liquid and electric energy so desperately needed
by the state.

Approximately 70% of the residual materials placed in landfills
consist of various types of biomass, only a portion of which may
be feasibly composted or recycled.  In short, new tools are
needed.  For example, compostable organics (i.e. food and
vegetative wastes), comprise only about 25% of this stream. 
Similarly, there is no estimate of additional biomass materials,
such as paper, which may be recovered through intensified
commercial recycling efforts, although markets for the major
portion of this stream may have already been optimized, with
residuals having limited commodity market value.

In contrast, new biomass conversion technologies, such as
in-vessel hydrolysis/fermentation and thermal/fermentation
processes, have the potential to convert the full spectrum of
landfill-bound carbonaceous waste materials into renewable energy
products, including power, fuels, and chemicals.  Because of their
unprecedented potential to divert waste materials to beneficial
use, the development of clean technology bioenergy facilities is
an essential and necessary component of future landfill abatement
strategies.  

GHG Reduction Potential

The Draft Scoping Plan notes that commercial recycling and
composting programs “could have substantial greenhouse gas
benefits but their in-state reductions have not been quantified at
this time.”  Indeed, data on the effectiveness of current waste
management practices as climate change strategies are both
inconclusive and incomplete.

Composting operations, for example, have their own set of air
quality concerns, including VOCs and GHG precursors.  In fact, an
independent study recently completed by the Los Angeles County
Sanitation Districts1 concluded that placement of urban green
waste in landfills as alternative daily cover was superior to
composting these materials in terms of net GHG emissions.

The climate change benefits of recycling are generally assumed to
derive from the avoidance of virgin material extraction and
reintroduction of recovered materials with “intrinsic energy
value” back into the remanufacturing process, although the Draft
Scoping Plan admits that such benefits may not occur in
California.    Indeed, the majority of California’s recyclables
leave the state for distant domestic or foreign markets, with the
largest volume of these commodities, namely paper and plastics,
being shipped to China.  

The life cycle analyses on which recycling climate change benefits
are based seldom calculate the global GHG impacts of trans-Pacific
shipping, or of transferring the remanufacturing burden to
developing nations where environmental controls are minimal or
nonexistent.  These atmospheric industrial pollutants drift
eastward and find their way back to California in a matter of
days, contributing further to the state’s GHG reduction
challenge.

The CIWMB’s own studies point out the critical need to both
reevaluate and expand the range of technologies employed to meet
future landfill abatement and climate change objectives. For
example, a comprehensive life cycle analysis of waste management
practices completed in 2004 by the Research Triangle Institute2
concluded that new waste conversion technologies (acid hydrolysis,
gasification, and catalytic cracking) were superior to recycling
and composting with regard to energy balance, NOx emissions, and
carbon emissions.  Similarly, a 2006 study of thermal waste
conversion technologies prepared for the CIWMB by UC Riverside3
stated:

“If conversion technologies were able to process a significant
portion of California’s waste that is currently landfilled,
benefits could be realized in a number of areas.  These include
reductions in overall greenhouse gas emissions, fugitive landfill
gas emissions, and diesel truck emissions.  On the energy
production side, the avoided costs and impacts in exploration,
production, and transportation of traditional fuels could be
substantial.”

This same study concluded:

“Thermochemical technologies can process a wider variety of
feedstocks and can have a greater effect on landfill reduction. 
Thermochemical technologies can also produce a larger variety of
products, which can displace the need for non-renewable sources of
energy and fuels.  Other indirect effects include eliminating
diesel truck trips and reducing landfill gas emissions.”

Thermochemical conversion technologies are clean technologies
because nothing enters the atmosphere as a result of the
gasification (waste disposal) step.  The resulting synthesis gases
and waste heat from the processes can be converted to liquid and
electric energy.  The opposition to conversion technologies that
is influencing legislative and administrative policy in California
stems from those who refuse to accept that 21st century technology
can achieve environmentally superior waste-to-energy technologies;
from the traditional recycling industry which wants to suppress
competition for the state’s waste streams and from waste
management firms that view conversion technologies as threats to
landfills. 

It is time for the state to look past these short-sighted
positions and embrace these emerging technologies with the same
commitment as the federal government, other states and nations. 
More than 100 of these plants are now operating or will be
constructed in Europe and Asia during the next decade. 

California should be a leader in encouraging such technologies. 
However, private enterprise will continue to take these projects
elsewhere until the state adopts a practical, efficient and
supportive statutory and regulatory environment for their
implementation and operation.

Recommendation

The BioEnergy Producers Association supports the expansion of
California’s source reduction, recycling, and composting programs.
 At the same time, we urge that new clean-technology bioenergy
strategies be applied to the state’s growing post-recycled waste
stream in order to meet urgent landfill abatement and climate
change goals.  Timely deployment of waste-based biorefineries can
provide a vehicle for integrating California’s renewable energy,
AB 118, and AB32 policy objectives.

References:
1 Evaluation of Green Waste Management Impacts on GHG Emissions,
Alternative Daily Cover Compared with Composting.  Los Angeles
County Sanitation Districts, April 2008.
2 Life Cycle and Market Impact Assessment of Noncombustion Waste
Conversion Technologies.  Prepared for the CIWMB by the Research
Triangle Institute International, 2004.
3 Evaluation of Environmental Impacts of Thermochemical Conversion
Technologies Using Municipal Solid Waste Feedstocks.  Prepared for
the CIWMB by the University of California , Riverside, April
2006.