Comment Log Display

COMMENTS:  EXPANDED LIST OF AB32 EARLY ACTIONS

Prepared by:  Community Recycling and Resource Recovery, Inc.

	
Collaborative research to understand how to reduce GHG emissions
from nitrogen land application

Community Recycling supports this measure as an additional early
action and recommends that it include consideration of the use of
compost as a means of reducing the use of chemical fertilizers and
related emissions.  Our company currently owns and operates the
largest compost facility in California. Permitted to accept 3692
tons per day for organic windrow composting, over 98% of the
resulting compost is sold to agricultural markets. We also operate
over 3600 acres of adjacent farmland, including a 640 acre vineyard
and corn, wheat and alfalfa crops, which.  Much of this farmland
had badly depleted soil when originally purchased and our practice
of using compost on our own farmland has allowed us to
substantially increase crop yields and dramatically reduce
commercial fertilizer use.

Many studies have already documented the beneficial impact of
compost in reducing fertilizer, water, and herbicide use.  One
study, the Life Cycle Inventory and Life Cycle Assessment for
Windrow Composting Systems by the New South Wales Department of
Environment and Conservation (with the University of New South
Wales), focused in part on the beneficial impacts of compost on
vineyards in Austrailia.  That area of Australia is very similar
in climate and soil to the California Central Valley and a Climate
Action Team report identified California vineyards as one area of
the economy in danger due to drought conditions brought on by
climate change.

Community Recycling looks forward to participating as a
stakeholder in your planned collaborative research activities and
discussions.  We would also be pleased to assist in any future
research efforts by making farmland available for additional
studies, including recently acquired land with depleted soils.

Tire Inflation Program

We support these recommendations and already have a full time
person at our maintenance facility checking tire inflation all day
as vehicles come across the truck wash area. We use a nitrogen tire
filling process which helps maintain the inflation pressure
settings more accurately.

Smartway Truck Efficiency

Both Community Recycling and our sister company Crown Disposal
Company have already implemented actions to reduce GHG emissions
from our fleets of trucks and trailers, including those that
reduce aerodynamic drag and rolling resistence.  We support these
types of strategies as discrete early actions.  We are watching
very carefully the technological development of trailer side
skirts and gap fairings and will implement them when they are
adequately developed.  We would be happy to further discuss these
trailer technologies with you as regulations are prepared by ARB
staff.

Thomas H. Fry, President
Community Recycling and Resource Recovery, Inc.