Comment Log Display

The current draft of the Scoping Plan does not attribute any
greenhouse gas savings to waste reduction, recycling, and
composting even though local governments recognize that recycling
and composting cost-effectively and significantly reduce
greenhouse gas emissions. San Francisco’s Climate Action Plan, for
example, gets 14% of its projected greenhouse gas emission
reductions from the waste sector.  On a statewide level, a 25%
reduction in disposal would result in a reduction of at least 5
million tons of CO2 emissions. Zero waste could result in a
reduction of at least 10 million tons of CO2 emissions. Waste
reduction and recycling reduces emissions across sectors,
including mining, forestry, agriculture, transportation,
manufacturing, electricity, and disposal.

The appendices acknowledge the contribution from commercial
recycling alone can be as high as 6.5 MMT, which is significantly
higher than the potential reductions from landfill methane
capture.  The appendices also acknowledge a potential reduction of
3.1 MMT from increased composting. Anaerobic digestion also has a
potential of 2.2 MMT.  While anaerobic digestion is an important
and effective way to reduce emissions, we do not believe it should
be lumped in with waste-to-energy, since many waste-to-energy
programs do not make the best, most efficient use of waste
materials. While not quantified, extended producer responsibility
and environmentally preferable purchasing are also valuable
mechanisms for increased reductions.

ARB should, as a minimum, adopt the recommendations of the ETAAC
committee (Economic and Technology Advancement Advisory
Committee). These recommendations include:

•	Mandatory commercial recycling
•	Mandatory multi-family recycling
•	Disposal limits for readily-recyclable materials like cardboard
•	Emission reduction / offset protocols for manufacturing with
secondary materials, avoiding methane at landfills, reducing GHG
emissions from agriculture, and upstream GHG reductions of
recycling.
•	Remove barriers to composting by addressing regulatory hurdles,
providing financial incentives for composting and use of compost,
and increase market demand through local and statewide procurement
efforts.
•	Eliminate diversion credit for greenwaste used as alternative
daily cover.
•	Reduce emissions from synthetic fertilizers/pesticides and
energy-intensive irrigation by increasing agricultural application
of compost, including through financial incentives and
demonstration projects.

The ARB also needs to:
o	Ensure the effective and comprehensive implementation of
already-adopted Early Action Measures on landfill gas collection.
o	Improve GHG inventory and other landfill emissions models
through mandatory reporting and better quantification of fugitive
emissions.