First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comment on Recycling and Waste |
Comment | 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. |
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Date and Time Comment Was Submitted | 2008-11-19 19:07:38 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.