Comment Log Display

Please accept our comments for this portion of the 2022 Scoping
plan Update. Thank you.

- The 2022 Scoping Plan SLCP section should not only incorporate
the August 2018 Paper "COMPOSTING IN CALIFORNIA Addressing Air
Quality Permitting and Regulatory Issues for Expanding
Infrastructure" co-written by CARB, CalRecycle, and CAPCOA", but
expand on it, particularly providing much needed guidance on the
permitting issues from air districts that will need to be addressed
to comply with the state's ambitious SB 1383 organic waste
diversion targets. The joint paper concluded with recommendations
to advance potentially viable options (Section VIII) which included
additional regional air quality modeling, landfill emissions
reduction credits, essential public service designation, and future
research opportunities. It would be ideal to provide such updates
and continue the collaborative process within the goals and
framework of the 2022 Scoping Plan Update. One other report since
the last Scoping Plan Update is the CalReycle August 2020 Progress
Report "Analysis of the Progress Toward the SB 1383 Organic Waste
Reduction Goals" which also stresses the existing permitting
difficulties air district face for composting facilities in the
wake of the fast-approaching SB 1383 implementation. 

- Regarding SB 1383, the 2022 Scoping Plan Update should provide
insight as to how air districts should treat a new or modified
organic facility's emissions that have either been diverted away
from landfill or organic disposal sites or result in a net decrease
from other emissions sources, such as the overall decrease in
transfer trips or VMTs, from a CEQA perspective of analyzing a
project's emissions against a significance threshold. More new or
expanded facilities will be needed to comply with SB 1383 targets
and this needs to be addressed. The Plan should also include CEQA
guidance for the control of odor emissions from such facilities and
possible mitigation strategies.