First Name | Diana |
---|---|
Last Name | Tang |
Email Address | diana.tang@longbeach.gov |
Affiliation | City of Long Beach |
Subject | City of Long Beach Opposition to Proposed Changes to the COI Fee Regulation |
Comment | September 11, 2014 Ms. Mary Nichols, Chair California Air Resources Board 1001 I Street Sacramento, CA 95814 Re: City of Long Beach Comments on Proposed Changes to the Cost of Implementation Fee Regulation Dear Chairwoman Nichols: On behalf of the City of Long Beach, I write to reiterate opposition to the California Air Resources Board’s (CARB) proposed changes to the Cost of Implementation Fee Regulation, as they apply to waste-to-energy facilities. Long Beach had previously submitted a letter to express our concerns to this proposal during the unofficial comment period in June. As demonstrated in the 2012 report entitled, CalRecycle Review of Waste-to-Energy and Avoided Landfill Methane Emissions, waste-to-energy facilities reduce greenhouse gas emissions, when compared to landfills. Waste-to-energy facilities also have the capacity to reduce municipal solid waste (MSW) volume by 90 percent, and produce baseload energy as a byproduct. In comparison, landfills do not have the capacity to reduce waste volume prior to burying the materials. Waste-to-energy facilities are essential to bridging the gap between traditional landfills and the next generation of MSW processors. Amending the adopted COI Fee Regulation to capture waste-to-energy facilities disincentivizes the use of this technology. Though California has adopted an aggressive Cap and Trade Program to reduce greenhouse gas emissions to 1990 levels by 2020, State regulations still make landfills the economically preferable option. If waste-to-energy facilities are forced to pay additional fees that are not required of landfills, then the price discrepancy between these two MSW processing options will grow even larger. By 2018, it may be economically infeasible to operate the waste-to-energy facility in Long Beach. Shutting down the waste-to-energy facility in Long Beach will negatively impact the goals of the State’s Cap and Trade Program. Inevitably, greenhouse gas emissions will increase as landfilling increases. Waste generated by over 500,000 residents and business in Long Beach, in addition to waste from various cities including Los Angeles, Culver City, Torrance, and Compton will instead go landfills where nearly 100 percent of the waste volume will be buried. Long Beach does not view increased landfilling as a positive result. The City strongly prefers that State regulations treat landfills and waste-to-energy facilities equitably, or at least continue to provide allowances to waste-to-energy facilities consistently throughout the implementation of the Cap and Trade Program so that Long Beach can continue operating our waste-to-energy facility. It is essential for there to be an economically viable environment for this facility to operate in, so that it may continue to be a part of State discussions to help further reduce greenhouse gas emissions in California. Given these reasons, the City of Long Beach opposes the proposed COI Fee Regulation amendments, as they apply to waste to energy facilities. Long Beach urges the Board to reject staff’s amendments and keep this section of the regulations as is. Sincerely, Mayor Robert Garcia City of Long Beach cc: Members of the California Air Resource Board |
Attachment | www.arb.ca.gov/lists/com-attach/3-feereg2014-Am4FbARrADRQCQBi.pdf |
Original File Name | Long Beach Comments_COI Fee Regulation_Opposition_9-11-14.pdf |
Date and Time Comment Was Submitted | 2014-09-11 18:19:22 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.