Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

14. Recycling and Waste (p. 62-63 and Vol. 1 Supporting Documents
and Measure Detail p. C-158 to C-164)

While significantly improved from the first version, CARB’s
scoping plan should highlight even more aggressively the powerful
carbon reduction potential of zero waste and extended producer
responsibility: first, reducing waste by design in manufacturing
process, then reusing, recycling or composting products. We suggest
that the findings of the new report "Stop Trashing the Climate,"
released June 5, 2008,  (http://www.stoptrashingtheclimate.org/) be
considered for the Scoping Plan.  The report, by GAIA with the
Institute for Self Reliance and Eco-Cycle, brings together
information about recycling, plus source reduction, reuse and
composting. Further, it describes how scaling up recycling, reusing
materials and products, and shrinking the size of a community's
waste stream can greatly reduce greenhouse gas generation and
related climate damage:

"Incinerators and landfills are relics of an unsustainable past
that have no place in our green economy. The report, "Stop Trashing
the Climate" shows that zero waste -- that is, preventing waste and
strengthening recycling and composting -- is one of the fastest,
cheapest and most effective strategies for confronting global
warming."           Carl Pope, Executive Director, Sierra Club

While it is commendable that Californians are recycling as much as
they are, the statement that existing diversion rate from landfills
is 54 percent is a misleading statistic.  The critical statistic is
how much is landfilled today as compared to the 1990 base year. 
When the current disposal tonnages are used, Californians will see
that they are landfilling almost the same amount today as they did
then. Per capita waste disposal is down but we are still wasting
huge amount of raw materials.  Using the true disposal figures
shows that there is huge opportunity to both reduce what we
generate and increase what we compost, reuse and recycle.   

ETAAC submitted to CARB an excellent set of recommendations for
the waste sector but only some were included in the Plan. We
strongly urge CARB to include ALL the ETAAC recommendations for the
waste sector.

We believe there are many more tons of carbon reductions possible
from aggressive zero waste and extended producer responsibility
programs. Our top improvements to the Plan are:

1.	Mandate the collection of commercial recycling which can be
phased in by commodity starting with corrugated containers and
other paper, organics, metals and then specific plastics.
2.	Stop the use of alternate daily cover (ADC) made from
compostable material as this increases the chance of methane
generation and release, and eliminate recycling credit given for
ADC.
3.	Aggressively work to site more composting operations and
complete all needed studies to resolve the issues of VOCs from
composting.
4.	Support the EPR Framework legislation and once signed into law,
work quickly to implement the law.
5.	Move cautiously in any action that might increase methane from
open or closed landfills as any action to increase energy
development from landfills may actually increase fugitive releases
of methane and other VOCs into the atmosphere.  The Precautionary
Principle should be used in any action regarding landfill gases.
6.	Use current disposal tonnages rather than diversion tonnages as
the final arbiter of success.  

Inclusion of specific measures for these actions with emission
reduction numbers and deadlines should be attached to each action.

Landfill Issues – Organic Wastes, Alternate Daily Cover and
Methane Generation and Collection
 
Landfill waste disposal should be phased out by requiring
recycling and making manufacturers responsible for the end-of-life
disposition of their products. Wastes should be separated,
particularly organic wastes, for effective composting and to reduce
the risk of generating methane.  CARB should explicitly reject
carbon credits for landfill carbon sequestration.  Alternative
Daily Cover (ADC) that uses green waste or wood waste should not be
given recycling credits or counted as recycling. This actually
de-incentivizes diversion of green waste into composting and
methane energy capture.

While CARB’s plan supports separation of organic and compostable
materials CARB’s suggestion to capture and utilize landfill methane
gas should not be construed as support for continued dumping of
green waste into landfills. Landfill capture of methane is far less
efficient than what is possible with green waste separation. This
is especially crucial given that methane is a far more potent
greenhouse gas than carbon dioxide.  Some research shows that
attempts to capture and convert landfill gas to energy (LFGTE)
actually can cause more emissions than just flaring the gas under
certain conditions.  In addition, the common assumption that “the
majority of methane gas that escapes the landfill can be flared and
converted to CO2” may not be valid in many cases.  A common default
or “blanket” assumption that 75 percent landfill gas collection
rate may be invalid and is under review by CARB.  The International
Panel on Climate Change (IPCC) states that some landfill sites may
have less efficient or only partial gas extraction systems, and
there are fugitive emissions from landfilled waste prior to and
after the implementation of active gas extraction; therefore
estimates of lifetime recovery efficiencies may be as low as 20%.” 
The International Council for Local Environmental Initiatives
agrees with the IPCC: “a default estimate of the recovery
efficiency should be 20%.”  

To operate LFGTE economically, landfill operators must increase
the concentration of methane in landfill gas significantly while
degrading the efficiency of gas collection systems by leaving the
cap off longer, replacing vertical collection wells with flexible
horizontal pipes, and decreasing vacuum pressure.  This may result
in increasing net overall GHG emissions, instead of reducing them.

CARB’s underlying assumption is that methane gas has a global
warming factor of 21 (i.e. 21 times more potent than CO2).  But
that is the relative harm over 100 years.  The short-term harm
(important when considering the tipping point when global warming
reaches a point of no return) is much greater.  Over a 10-20-year
period, it is estimated that the relative harm of methane gas is
72-90 times greater than CO@ due to methane’s unique properties.
All this indicates CARB should exercise considerable caution in
making LFGTE assumptions and recommendations.


High Recycling / Zero Waste and Market Development 

•  CARB’s plan should stipulate mandatory commercial recycling
(even with recycling markets at their current bottom, because
credit problems are the issue, not lack of markets).  
Infrastructure exists in California to handle all the materials
collected, and in most cases, mandatory commercial recycling will
not require local governments to modify existing collection
contracts.  It should require the state to mandate collection or
ban the landfilling of paper, metal and certain plastics, as well
as green waste.

It has been almost twenty years since California signed AB 939
into law.  Since that time, businesses and institutions have had
ample time to implement commercial recycling, and yet these sectors
still generate more than half of what is disposed of in our
landfills.  The time for voluntary action is over.  CARB needs to
show the political will to truly reduce greenhouse gases by
mandating commercial recycling for all materials where even
negative value markets exist.

Composting, reuse and recycling facilities should be included in
local government critical infrastructure plans along with water and
sewage treatment plants.  All are necessary for a community to be
sustainable.  In many cases regional compost, reuse and recycling
facilities are an alternative to each community having their own
set of zero waste operations.  However, cities should be encouraged
to locate facilities close to the point of generation, especially
composting operations, so as to reduce transportation-related
energy consumption and to allow residents and businesses to use
their own compost locally rather than shipping in finished compost.
 We encourage cities to landbank for critical infrastructure
projects like compost facilities.

• We propose statewide installation of “Resource Recovery Parks”
to include facilities for reusing, recycling, composting, and
minimizing the discarding of materials. They can also incorporate
facilities for repair services, retail sales of reclaimed products
and landscaping supplies, organically composted gardens,
educational tours, and public amenities. Such a model park
currently operates in the city of Marina in Monterey County.

• Fees collected from the sale of carbon credits or other
greenhouse reduction financial mechanisms should be made available
in the form of grants, loans or tax credits to private or public
composting and reuse or recycling manufacturing facilities.

• Successful Zero Waste initiatives require effective outreach and
educational programs. CARB should utilize the legions of young
people who are not only are enthusiastic and care about waste
reduction, recycling and global warming but are also willing to go
out and do something about it. CARB should aid these individuals in
helping educate our communities about the issue. Recycling
ambassador programs throughout state and local government agencies
should be instituted so that students and other volunteers can go
door-to-door educating residents about the need for and the
benefits of recycling. In addition, new home owners, apartment
dwellers and other residents should receive information after
moving to a new residence that explains to them the recycling
policies in their neighborhood and encourages them to do so. People
are willing to do what it takes to pitch in, but if they have no
idea how to do it, they won't even begin. This type of outreach
should be a critical aspect of the CARB plan.

• Government purchasing power is very powerful. Along with
existing Environmentally Preferred Programs, a new program
discouraging the purchase of single use disposable items and
encouraging refillables and reusables needs to be implemented.  

• CARB is to be commended for stipulating “lifecycle tracking” of
manufactured products, giving priority to reusables and locally
manufactured items.

Conversion Technology

Sierra Club Policy does not support incineration of mixed solid
waste.  The Club is reviewing options of recovering energy from
source-separated parts of the solid waste stream, e.g., restaurant
cooking oil, sewage sludge, and food waste.  However, burning or
converting a material to a different state can require more energy
than the energy recovered.  Further, conversion technology
facilities require significant investments of funds, public and
private and dedicated waste streams and can discourage the
development of reuse or recycled markets for those same materials.
Developing new products from waste materials creates more jobs than
burning or “converting” those materials.  So like landfill gas, we
recommend the use of the Precautionary Principle before embarking
on new conversion facility development.