Comment Log Display

The governor’s Climate Action Team (CAT) has identified Zero
Waste/High Recycling Programs as a "high-confidence" strategy with
significant GHG reduction potential of 10 million tons CO2
equivalent by 2020:
http://climatechange.ca.gov/publications/factsheets/2005-06_GHG_STRATEGIES_FS.PDF


The Draft Scoping Plan's Emission Reduction Measure #15 in Section
II. B. 15. (Recycling and Waste) states: "Increase waste diversion,
composting, and commercial recycling, and move toward zero-waste". 
However, there are no preliminary recommendations related to
increasing waste diversion, composting, and commercial recycling,
and moving toward zero-waste.


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 with a
CO2 equivalent emissions reduction potential of 1 million tons
(1/10 of the 10 million tons reduction potential of Zero
Waste/High Recycling Programs previously identified by the CAT).
The draft Plan’s lone preliminary recommendation, "RW-1 Landfill
Methane Control", represents a narrow, back-end strategy to
mitigate the worst climate impacts of wasting AFTER failing to
reduce, reuse, recycle, and compost.  


It appears to be a significant omission oversight that missing
from the draft Scoping Plan are any of the following
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 


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 by the
California Resource Recovery Assn. (CRRA) 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. 

According to research conducted by the Institute for Local
Self-Reliance for every 10,000 tons per year of discarded
materials: composting creates 4 jobs, recycling creates 10-25 jobs
and reuse creates 25-300 jobs, compared to only 1 job created by
landfill disposal or incineration:
http://www.ilsr.org/recycling/recyclingmeansbusiness.html


Additionally, we urge that any “biomass” waste conversion
technologies under consideration be addressed on an individual
basis and in a full life-cycle comparison to source reduction,
reuse, recycling and composting alternatives. Many of these waste
conversion technologies have highly questionable net energy
balances, especially high temperature material destruction
processes applied to non source-separated, mixed feedstocks. 


Furthermore, the California Integrated Waste Management Board
(CIWMB) which is a full-fledged member of the CAT has adopted
Strategic Directives as “the most effective and efficient means to
create a zero waste California”:
http://www.ciwmb.ca.gov/BoardInfo/StrategicPlan/


The Directives include specific steps to minimize waste (SD 3),
move toward producer responsibility (SD 5), and support market
development (SD 6) - including reducing methane-producing organics
sent to landfills by 50% from current levels by 2020. It appears to
be a significant omission oversight that none of CIWMB’s Strategic
Directives are included as recommendations in the draft Scoping
Plan.


In conclusion, the draft Scoping Plan needs to be corrected to
include recommendations that support the Plan’s Emission Reduction
Measure #15 in Section II. B. 15. (Recycling and Waste) which
states: "Increase waste diversion, composting, and commercial
recycling, and move toward zero-waste". 

Additions to the Plan which will provide such corrections are
readily available to CARB from existing resources:

•	The Climate Action Team’s Zero Waste/High Recycling Programs
recommendation referenced above, which  has been identified by the
CAT as a "high-confidence" strategy with significant GHG reduction
potential of 10 million tons CO2 equivalent by 2020
•	The five ETAAC report Waste Reduction, Recycling and Resource
Management  recommendations listed above
•	The CIWMB’s Strategic Directives referenced above


California leads the nation in climate protection via Zero Waste,
thanks to the California Integrated Waste Management Act of 1990
(AB 939) which mandated 50% waste diversion by 2000. 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 using existing, proven, environmentally sound methods. 
It is critical that the Scoping Plan recognize and include Zero
Waste strategies as the significant climate protection strategies
that they are by including specific recommendations that advance
reduce-reuse-recycle-compost in California.