| Comment | The Environmental Analysis needs to recognize baseline conditions
for organic waste management practices such as landfilling when
assessing the emissions from composting and anaerobic digestion
facilities. Page 62 (copied above) states that compost facilities
could potentially increase VOC and PM emissions, but does not
discuss the baseline conditions of these materials being
landfilled, with methane and other associated landfill operations
emissions. Since the SLCP measures are diverting food waste and
green waste from landfilling, these baseline conditions need to be
recognized where the net benefit of both greenhouse gas reductions
and criteria pollutants can be demonstrated when diverting green
waste and food waste from landfills to composting and/or anaerobic
digestion facilities.
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