Comment Log Display

Margo Brown, Chair, CIWMB
1001 I Street
Sacramento, CA 95814

RE: Omission of Zero Waste Emissions Reductions in AB 32 Scoping
Plan

Dear Chair Brown:

The California Resource Recovery Association (CRRA) is a statewide
non-profit trade group.  CRRA’s more than 450 members represent all
aspects of California’s reduce-reuse-recycle-compost economy.

CRRA is extremely disappointed that the emissions reductions
associated with Measure RW-3 High Recycling/Zero Waste are not
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.”  Furthermore, the
Plan recommends no specific actions or policies to implement RW-3
 
Zero Waste/High Recycling was established as a "high-confidence"
strategy with GHG reduction potential of 10 million tons CO2
equivalent by 2020 in the Climate Action Team’s Strategies Underway
In California That Reduce Greenhouse Gas Emissions. The linkage
between CIWMB Strategic Directives and climate protection was
discussed extensively at the February 13, 2007 Board meeting when
CIWMB adopted its Strategic Directives. Thus, it is particularly
disappointing that CIWMB has failed to ensure that the Plan
includes any specific actions or policies supporting implementation
of its own Strategic Directives No. 6.1 (Reducing organics to
landfill), and No. 5.2 (Extended Producer Responsibility).

In its lead advisory capacity to the California Air Resources
Board (CARB) for developing the Recycling and Waste Section of the
Plan, CIWMB must ensure that the significant emissions reductions
available through High Recycling/Zero Waste measures are counted,
and that specific actions and policies are recommended.

CRRA hereby petitions CIWMB 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; and adoption of Extended Producer Responsibility framework
legislation.

I would welcome the opportunity to meet with you and other Board
members to discuss this matter.

Thank you for your consideration and action.

Sincerely,

Julie Muir, President

cc: CIWMB Board Members
      California Air Resources Board