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The emissions reductions associated with Measure RW-3 High
Recycling/Zero Waste should be counted toward the AB 32 goal in
the October 2008 Proposed Scoping Plan (Plan). Specifically,
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." The Scoping Plan must be amended to include
Measure RW-3.  

The goal of Zero Waste is a direct link to reduced greenhouse gas
emissions. Furthermore, the Plan recommends no specific actions or
policies to implement RW-3, again an untenable oversight. We urge
CIWMB & CARB to take urgent action to ensure that the Plan is
revised to count RW-3 emissions reductions towards the AB 32 goal,
and to add specific actions and
policies to achieve RW-3 reductions, including: mandatory
commercial recycling; phase-out of diversion credit for green waste
alternative daily cover; comprehensive strategy to remove
methane-producing organic materials from landfill disposal; and
adoption of Extended Producer Responsibility framework legislation.