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The USEPA and many others have documented that eliminating waste
and recycling more will have both a direct and significant indirect
impact on reducing greenhouse gas emissions. As a result, the ARB
should follow the lead of the CA Integrated Waste Management Board
in adopting Zero Waste as one of its key goals of the October 2008
Proposed Scoping Plan.

Footnote #43 in Table 20 on page 63, Section II.15 Recycling and
Waste, states,"Reductions from RW-2 and RW-3 are not counted toward
the AB 32 goal."  This is a serious error.  Zero Waste is one of
the most significant, quickest and most cost effective ways that
local governments can contribute to addressing climate change.  

The emissions reductions associated with High
Recycling/Zero Waste should be counted toward the AB 32 goal
in the Plan by amending the Plan to include Measure RW-3.  The
Plan should also recommend specific actions and policies to
implement RW-3, including: 

- mandatory commercial recycling; 
- phase-out of diversion credit for green waste alternative
daily cover; 
- and adoption of Extended Producer Responsibility framework
legislation. 

Gary Liss