Comment Log Display

The Recyclers Global Warming Council (RGWC) of the California
Resource Recovery Association (CRRA) represents interests within
the CRRA and overall resource recovery industry to address the
issue of climate protection through Zero Waste strategies: reduce,
reuse, recycling, composting and product stewardship.  The CRRA is
the oldest and one of the largest non-profit organizations in the
United States dedicated to reducing waste, pollution, and
greenhouse gas (GHG) production through Zero Waste strategies.

RGWC appreciates the opportunity to provide input on the Draft 2030
Target Scoping Plan (Plan).  The published draft Plan includes many
worthwhile recommendations, particularly regarding organics. We
wholeheartedly endorse the proposals regarding organics and support
the ban of 75% of them from landfills, as now required by law in
SB1383. The Scoping Plan should now detail how ARB will support
CalRecycle in implementing the SB1383 organic ban, including
supporting funding for composting and anaerobic digestion
facilities with Cap and Trade funding. 

We also recommend that the Plan include more specific actions such
as:
•	Recycling Market Development – Invest in direct incentives and
the Recycling Market Development Zone program to grow in-state
markets for recycled materials. Recycled content manufacturing
avoids emissions from raw materials extraction, primary processing,
transportation, and refining.  Recycling also promotes forest
carbon sequestration, and directly reduces direct manufacturing
emissions by displacing virgin materials which require more energy
for processing, and generate more waste.  Re-introducing discards
with intrinsic energy value back into manufacturing processes also
creates more local jobs by supporting in-state processing and
manufacturing with recycled feedstocks.
•	Local Climate Actions Plans – Increase support for and incentives
to local governments to implement local climate action plans. Local
actions complement statewide measures and may be more cost
effective and provide more co-benefits than relying exclusively on
top-down statewide regulations to achieve the State’s climate
stabilization goals.
•	Limit waste-based energy technologies – Require any feedstocks
under consideration for waste-based energy be addressed
individually, using full life-cycle analyses to compare to source
reduction, reuse, recycling and composting alternatives. The Waste
Management Sector Plan developed by the ARB and CalRecycle
acknowledges that “recycling, composting and anaerobic digestion,
and biomass conversion result in even lower GHG emissions” than MSW
Thermal facilities, since these facilities compete with recycling,
composting and anaerobic digestion. Limit any high-temperature
thermal processing technologies to uniform, controlled feedstock
such as agricultural scrap. Exclude mixed municipal solid waste, as
its use only facilitates continued resource depletion by
institutionalizing waste as an unsustainable “commodity” feedstock
for energy production.  
•	Establish an extended producer responsibility (EPR) framework -
Prioritize products with high toxicity, and difficult to reuse,
recycle or compost products, particularly high-GHG commodities such
as carpets in EPR frameworks.  EPR programs for those types of
products could have significant GHG emissions reduction impact with
low implementation cost for state and local governments and can
give producers a financial incentive to design products that close
the loop by being easy to repair, reuse, recycle and/or compost.


Thank you for considering RGWC’s recommendations.