Comment Log Display

-----Original Message-----
From: Mike Mohajer [mailto:mikemohajer@yahoo.com]
Sent: Sunday, February 24, 2008 4:10 PM
To: Mary Nichols; CARB Board Members
Cc: James Goldstene; Steve Church; Margo Reid Brown; Wesley
Chesbro; Jeffrey Danzinger; Rosalie Mule; Cheryl Peace; Gary
Petersen
Subject: 2/28/08 CARB Meeting, Item # 08-2-6 ---- Report of the
Economic and Technology Advancement Advisory Advancement
Committee


Madam Chair and Members of the Board,

On behalf of the Los Angeles County Integrated waste Management
Task Force (Task Force), I want to thank you the California Air
Resource Board (CARB) for the opportunity to comment on the
February 11, 2008 final report entitled Technologies and Policies
to Consider for Reducing Greenhouse Gas Emissions in California,
which was prepared by the CARB's Economic and Technology
Advancement Advisory Committee (ETAAC) and released to the public
by your Board on February 18, 2008. I also want to commend the
ETAAC's Members for their considerable efforts in preparation of
the subject report and its recommendations on such a short time
frame established by the California Global Warming Solution Act of
2006 (AB 32). Such a short time frame may be the cause for a number
of recommendations by the ETAAC in regards to our state integrated
solid waste management (ISWM) system which have been formulated
without any scientific basis and/or a balance objective to ensure
a net reduction in greenhouse gas (GHG) emissions. The following
provides a brief list of our initial concerns which are being
provided on an interim basis due to the short time frame since
this matter is set for your Board consideration on February 28,
2008. 

Pursuant to Chapter 3.67 of the Los Angeles County Code and the
California Integrated Waste Management Act of 1989 (AB 939), the
Task Force is responsible for coordinating the development of all
major solid waste planning documents prepared for the County of
Los Angeles and its 88 cities in Los Angeles County with a
combined population in excess of 10 million.  Consistent with
these responsibilities, and to ensure a coordinated and
cost-effective and environmentally-sound solid waste management
system in Los Angeles County, the Task Force also addresses issues
impacting the system on a Countywide basis.  The Task Force
membership includes representatives of the League of California
Cities-Los Angeles County Division, the County of Los Angeles
Board of Supervisors, the City of Los Angeles, the waste
management industry, environmental groups, the public, and a
number of other governmental agencies.





     I. The Task Force strongly supports recycling as an important
element of our ISWM system and recognizes its value in reducing our
dependence on disposal options. However, without having a full and
complete economic and environmental life-cycle analysis for this
technology, it is scientifically not possible to measure
reductions or increases in GHG emissions resulting from recycling
activities. Additionally, the California recycling industry is
very complex and extends beyond the California and the U.S.
boundaries to foreign countries. A number of Pacific Rim countries
play a major role in providing a market for our recyclable
materials. However, environmental laws and regulations in some of
these countries are non-existent as compared to California. It
should also be recognized that there are no jurisdictional
boundaries that would limit the movement of air contaminants
(including GHG) from these countries to California negatively
impacting our air quality and well being of our residents.This is
a critical concern which further substantiate the need for the
state to take the lead in conducting a complete life-cycle
analysis for our recycling option as it has been recommended by
the Task Force for many years.



Based on the foregoing and without any consideration by the ETAAC
for the economic impacts on local governments, the Task Force
respectfully disagrees with the report recommendations for
increases in the recycling rate by an additional 25 percent by
2012 as currently proposed by Senate Bill 1020 (Padilla).


 

     II.  The Task Force has a long track record of supporting
initiatives that promote producer responsibility because of its
major role in reducing commercial/manufacturing waste as well as
its positive impact on the reduction of energy consumption and
potential reduction in GHG emission. As such, we appreciate the
report's acknowledgement of the subject but at the same time
disappointed by the lack of any analysis by the ETAAC. Producer
responsibility impacts all aspects of our ISWM system, and
therefore, it warrants much more consideration.





     III.  Without conducting any analysis or estimation of GHG
emissions, the report incorrectly claims that composting would
avoid the generation and emission of methane gas as compared to
other disposal options. While the Task Force is in support of
composting, we do not believe the development of composting
facilities in metropolitan/urbanized areas is a valid ISWM option
unless composting activates are conducted in enclosed facilities
that operate under negative pressure to control odors and ensure
air quality in protecting health and safety of neighboring
residents. Additionally, a complete economic and environmental
life-cycle analysis on the composting option needs to be conducted
to verify the validity of the recommendations.



For many years, the Task Force has been an advocate for the state
to take a proactive role in developing markets for composted
products. We are pleased that the ETAAC has arrived at the same
conclusion.





     IV. The Task Force disagrees with the report's claim that
greenwaste is not an effective material for use as a landfill
alternative daily cover (ADC). Prior to its approval by the
appropriate regulatory agencies, a series of field testing and
demonstration activities were conducted to substantiate that
greenwaste when used as ADC meets all performance and health and
safety criteria established by the California Integrated Waste
Management Board. As such, the report's claim is unfounded.



The Task Force also strongly opposes the report's recommendation
to phase out the diversion credit for use of greenwaste as a
landfill ADC on the basis that such a use would divert green
materials from composting activities. Again, such a claim is
unfounded and it is contrary to the report's finding (Chapter 4,
Pg 4-17) that currently over 12 million tons of compostable
organics are being disposed in landfills on an annual basis and
would be available for the composting option.





     V. The Task Force is very pleased with the ETAAC findings as
discussed in Chapters 4, 5 and 6, and Appendix IV of the report
that the existing barriers, including but not limited to
legislative and regulatory, have significantly hindered the
development of conversion technologies in California and that they
need to be addressed.



The Task Force has been a strong supporter of conversion
technologies and played a major role which resulted in the
enactment of AB 2770 in 2002. AB 2770 specifically required the
California Integrated Waste Management Board to conduct a study,
including life-cycle analysis, to verify the viability of these
technologies as an element of our ISWM system and provided a
funding in the amount of $1.5 million for the required study. The
result of the 3-year study which was conducted in concert with
campuses of the University of California at Davis and Riverside
substantiated the viability of these technologies as an ISWM
option while producing renewable energy to reduce our dependence
on fossil fuel and reducing GHG emission. Unfortunately, the
ETAAC's report failed to make any reference to the findings of the
subject study .



Since 2003, the Task Force has further expanded its activities
with the County of Los Angeles for the development of a pilot
demonstration facility in Southern California. As a part of this
effort, the Task Force has also visited a number of existing
conversion technology facilities in Europe and Japan to insure the
viability of these facilities for California. While our findings
further substantiate the viability of these facilities, we
continue to maintain our position that the state must take the
leadership as well as a proactive and visible role in removing the
existing legislative and regulatory barriers to the development of
these technologies in California.



Based on the results of the AB 2770 study and our site visits and
investigation, there are over 200 conversion technology facilities
currently operating in Europe and Japan using municipal solid waste
as their feedstock. As such, we were dismayed by the report's
recommendation (Chapter 6, pp 6-8 & 6-20) that conversion
technology facilities using post-recycled solid waste residuals
need to be significantly treated differently as compared to those
facilities that use "agricultural waste" as feedstock. Needless to
say, we are opposed to the said proposal. The criteria should be
based on performance and compliance with required rules and
regulations and not on a "government policy" to pick a
technology/feedstock winner.





The Task Force is looking forward to the opportunity to work with
the CARB and other appropriate agencies to ensure an
environmentally and economically viable ISWM system that is
protective of our citizens' health and safety as well as our
natural resources. 



Thank you again for the opportunity to submit these initial
comments. Should you have any question, please contact me at
909-592-1147.



Regards,


MIKE MOHAJER, Member
LA County Integrated Waste Management Task Force
mikemohajer@yahoo.com
P.O.Box 3334, San Dimas, CA 91773-7334


cc: Each Member of the California Integrated Waste Management
Board
     Each Member of the Los Angeles County Integrated Waste
Management Task Force