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My name is Kay Martin and I am Vice-President of the BioEnergy
Producers Association.

The BioEnergy Producers Association (BPA) is a coalition of
private companies and public agencies dedicated to the development
and commercialization of environmentally preferable industries that
produce renewable sources of power, fuels, and chemicals from
agricultural, forestry and urban biomass wastes and other
carbonaceous materials.  Our membership includes bioenergy firms,
electric utilities, and waste management companies.  

The BPA has reviewed the “Recycling and Waste” section of the
Climate Change Draft Scoping Plan, whose recommendation is to
"increase waste diversion, composting, and commercial recycling,
and move toward zero-waste."   The most promising approach to
achieving this goal is to use the organic portion of the
post-recycled waste stream as a feedstock for the production of
advanced biofuels and green power.  However, the only mention of
renewable energy uses is "through deployment of anaerobic digestion
for production of fuels/energy."  

We respectfully request CARB’s consideration of additional
measures for Landfill Methane Control.  Landfill Methane can be
controlled by disposing of carbon-based materials prior to their
being landfilled, by sing them as feedstocks (disposing of them) in
the process of producing liquid and electric energy using clean
thermochemical conversion technologies.  

Specifically, the Recycling and Waste Sector Preliminary
Recommendation should mirror and complement strategies outlined for
the agricultural sector by encouraging the use of urban biomass
wastes for sustainable energy production.   Deployment of bioenergy
strategies is consistent with the Bioenergy Action Plan, the Low
Carbon Fuel Standard (LCFS), and AB 32 GHG reduction goals for the
following reasons:

Landfill Abatement Potential

The Draft Scoping Plan recognizes fugitive landfill methane gas
emissions as a major GHG precursor, and calls for measures to
reduce the volume of materials flowing to land disposal.   Existing
source reduction, recycling, and composting programs are credited
with attainment of the state’s 54% diversion rate (14% of which
receives this credit is actually green waste that is being place IN
landfills for use as daily cover), and the Plan places principal
reliance upon the expansion of these programs to reduce disposal
tonnages in the future, virtually ignoring the potential to use
these waste resources in the clean production of liquid and
electric energy.

Despite the success of its recycling and composting efforts,
California’s high disposal rate has remained virtually unchanged
for the past 20 years.  40 million tons of municipal waste were
landfilled in California in 1989, the year AB 939 was passed.  This
year, despite the progress of recycling, the state will place 40
million tons of post-recycled waste in its landfills.  

It is folly to believe that this volume of post-recycled material
can be eliminated through source reduction, traditional means of
recycling and composting alone, on which California's waste
disposal hierarchy now relies.  All methods of disposal must be
incorporated in any effective plan, and this includes the complete
disposal (i.e., destruction) of carbon-based wastes in the process
of producing the liquid and electric energy so desperately needed
by the state.

The state’s population is expected to grow by some 10 million
people over the next 25 years.  Unless more flexible legislative
and regulatory policies are put in place, enabling the use of its
waste resources for energy production, the state will landfill more
than one billion tons (that’s one billion) of municipal solid waste
during that time--and a major opportunity to achieve energy
independence, AB 32 GHG reduction goals and a Low Carbon Fuel
Standard (LCFS) will be lost.  

Approximately 70% of the residual materials placed in landfills
consist of various types of biomass, only a portion of which may be
feasibly composted or recycled.  In short, new tools are needed. 
For example, compostable organics (i.e. food and vegetative
wastes), comprise only about 25% of this stream.  Similarly, there
is no estimate of additional biomass materials, such as paper,
which may be recovered through intensified commercial recycling
efforts, although markets for the major portion of this stream may
have already been optimized, with residuals having limited
commodity market value.

In contrast, new biomass conversion technologies, such as
in-vessel hydrolysis/fermentation and thermal/fermentation
processes, have the potential to convert the full spectrum of
landfill-bound carbonaceous waste materials into renewable energy
products, including power, fuels, and chemicals.  Because of their
unprecedented potential to divert waste materials to beneficial
use, the development of clean technology bioenergy facilities is an
essential and necessary component of future landfill abatement
strategies.  

Although the market for the export of recycled materials to China
and other foreign countries (where there are substantially no
environmental controls on their processing, and where they are
turned into goods to be sold back into the United States, depriving
Americans of jobs), although this market has proved to be unstable,
the demand for environmentally preferable advanced biofuels and
green power, which can be produced domestically by Californians, is
just beginning to grow.

GHG Reduction Potential

The Draft Scoping Plan notes that commercial recycling and
composting programs “could have substantial greenhouse gas benefits
but their in-state reductions have not been quantified at this
time.”  Indeed, data on the effectiveness of current waste
management practices as climate change strategies are both
inconclusive and incomplete.

Composting operations, for example, have their own set of air
quality concerns, including VOCs and GHG precursors.  In fact, an
independent study recently completed by the Los Angeles County
Sanitation Districts1 concluded that placement of urban green waste
in landfills as alternative daily cover was superior to composting
these materials in terms of net GHG emissions.

The climate change benefits of recycling are generally assumed to
derive from the avoidance of virgin material extraction and
reintroduction of recovered materials with “intrinsic energy value”
back into the remanufacturing process, although the Draft Scoping
Plan admits that such benefits may not occur in California.   
Indeed, the majority of California’s recyclables leave the state
for distant domestic or foreign markets, with the largest volume of
these commodities, namely paper and plastics, being shipped to
China.  

The life cycle analyses on which recycling climate change benefits
are based seldom calculate the global GHG impacts of trans-Pacific
shipping, or of transferring the remanufacturing burden to
developing nations where environmental controls are minimal or
nonexistent.  These atmospheric industrial pollutants drift
eastward and find their way back to California in a matter of days,
contributing further to the state’s GHG reduction challenge.

The CIWMB’s own studies point out the critical need to both
reevaluate and expand the range of technologies employed to meet
future landfill abatement and climate change objectives. For
example, a comprehensive life cycle analysis of waste management
practices completed in 2004 by the Research Triangle Institute2
concluded that new waste conversion technologies (acid hydrolysis,
gasification, and catalytic cracking) were superior to recycling
and composting with regard to energy balance, NOx emissions, and
carbon emissions.  Similarly, a 2006 study of thermal waste
conversion technologies prepared for the CIWMB by UC Riverside3
stated:

“If conversion technologies were able to process a significant
portion of California’s waste that is currently landfilled,
benefits could be realized in a number of areas.  These include
reductions in overall greenhouse gas emissions, fugitive landfill
gas emissions, and diesel truck emissions.  On the energy
production side, the avoided costs and impacts in exploration,
production, and transportation of traditional fuels could be
substantial.”

This same study concluded:

“Thermochemical technologies can process a wider variety of
feedstocks and can have a greater effect on landfill reduction. 
Thermochemical technologies can also produce a larger variety of
products, which can displace the need for non-renewable sources of
energy and fuels.  Other indirect effects include eliminating
diesel truck trips and reducing landfill gas emissions.”

Thermochemical conversion technologies are clean technologies
because nothing enters the atmosphere as a result of the
gasification (waste disposal) step.  The resulting synthesis gases
and waste heat from the processes can be converted to liquid and
electric energy.  The opposition to conversion technologies that is
influencing legislative and administrative policy in California
stems from those who refuse to accept that 21st century technology
can achieve environmentally superior waste-to-energy technologies;
from the traditional recycling industry which wants to suppress
competition for the state’s waste streams and from waste management
firms that view conversion technologies as threats to landfills. 

It is time for the state to look past these short-sighted
positions and embrace these emerging technologies with the same
commitment as the federal government, other states and nations. 
More than 100 of these plants are now operating or will be
constructed in Europe and Asia during the next decade. 

California should be a leader in encouraging such technologies. 
However, private enterprise will continue to take these projects
elsewhere until the state adopts a practical, efficient and
supportive statutory and regulatory environment for their
implementation and operation.

Recommendation

The BioEnergy Producers Association supports the expansion of
California’s source reduction, recycling, and composting programs. 
At the same time, we urge that new clean-technology bioenergy
strategies be applied to the state’s growing post-recycled waste
stream in order to meet urgent landfill abatement and climate
change goals.  Timely deployment of waste-based biorefineries can
provide a vehicle for integrating California’s renewable energy, AB
118, and AB32 policy objectives.

References:
1 Evaluation of Green Waste Management Impacts on GHG Emissions,
Alternative Daily Cover Compared with Composting.  Los Angeles
County Sanitation Districts, April 2008.
2 Life Cycle and Market Impact Assessment of Noncombustion Waste
Conversion Technologies.  Prepared for the CIWMB by the Research
Triangle Institute International, 2004.
3 Evaluation of Environmental Impacts of Thermochemical Conversion
Technologies Using Municipal Solid Waste Feedstocks.  Prepared for
the CIWMB by the University of California , Riverside, April 2006.