Today is the deadline for submitting comments to the ETAAC committee, and CAW has submitted a letter supporting recommendations J through N of the Industrial Sector (on page 89 of the report).

• Read our letter to the committee.
• See our previous blog entry for a description of these recommendations.
• Submit additional letters supporting these recommendations. (Letters should be sent to Steve Church at the ARB)
• Attend ETAAC's upcoming meetings on January 25th and February 11th.

The first formal meeting of the state’s Climate Action Team subgroup on Recycling and Waste Management will be taking place next week. The Recycling and Waste Management Subgroup is part of the Governor’s Climate Action Team, which is the primary vehicle for state agencies such as the Department of Conservation and the CIWMB to make policy recommendations for the implementation of AB 32.

This meeting is the starting point in the process for developing a proposal that could include a credit system for the production and utilization of recycled/composted materials, as well as host of other programs to remove barriers to composting and increase commercial and residential recycling.

Monday’s meeting will be an opportunity to urge the CAT subgroup to recommend to ARB a set of strong policies that will encourage the ARB to focus on waste reduction, recycling, and composting as greenhouse gas reduction measures.

The meeting of the newly expanded Recycling and Waste Management Subgroup (formerly “Landfill Subgroup”) will be held Monday at the Cal/EPA building, and the audio from the meeting will be webcast. Although this is only an introductory meeting and not much will actually be decided, this CAT subgroup process will be a good opportunity for recyclers, composters, and industries that use recycled materials to support including recycling in the development of the AB 32 Scoping Plan.

• Agenda
• Webcast (Audio Only)

Economic and Technology Advancement Advisory Committee

• January 18 2008 - Expansion of Recycling Section
• June 4 2007 - Ideas and Suggestions for Technologies to Reduce Climate Change Emissions in California
• November 30 2007 - Waste Reduction and Recycling in Draft ETAAC Report

ARB Mandatory Reporting

• May 16 2007 - Mandatory Reporting for Solid Waste Landfills
• August 7 2007 - Mandatory Reporting for Landfill Sector
• November 30 2007 - Landfill Sector Mandatory Reporting (Joint Letter from CAW, NRDC, Sierra Club California, & Enivornmental Defense)

AB 32 Scoping Plan

• October 1 2007 - Scoping Plan Suggestions

Cal/EPA Market Advisory Committee

• June 14 2007 - Market Advisory Committee Draft Reccomendations

ARB Early Action Measures

• January 23 2007 - Early Action Measures: Waste Reduction and Recycling
• May 7 2007 - Need for Early Action Measure Expansion
• September 24 2007 - Expanded List of Early Action Items

ARB Greenhouse Gas Emissions Inventory

• March 27 2007 - Best Available Science for Landfill Gas Protocol
• April 26 2007 - Landfill Carbon Sequestration in the Emissions Inventory
• Sept 7 2007 - Draft GHG Inventory

Environmental Justice Advisory Committee

On Friday June 1, the Market Advisory Committee released a draft of their recommendations for the potential design of a market system under AB 32 (available on our documents page). Among the many strategic recommendations for designing a market, the MAC recommends excluding all biologic processes, including fugitive methane from landfills.

The report suggests that due to the difficulties in monitoring biological emissions such as fugitive landfill gas emissions, the market cap should exclude all emissions from biological processes. However, despite fugitive landfill emissions not being included under the market cap, the MAC suggests energy produced from landfill gas would still be eligible for carbon offsets. The committee's recommendations explicitly state that "projects that capture landfill and digester gas could be incorporated in an offsets program or through other regulatory measures."

Landfill operators will be able to reap the benefits of an offset program from landfill gas to energy but experience no negative consequences for the increase in their fugitive emissions resulting from the additional organics disposed. CAW opposes this MAC recommendation:

• By allowing carbon offsets to be allocated for landfill gas, the landfill operator will have a direct monetary benefit to producing more landfill gas.
• Since the additional fugitive emissions from landfills would not be included in the cap, this would likely result in an increased demand for organics at landfills and subsequently a lower tipping fee for greenwaste at landfills.
• Lower tip fees at landfills will divert additional organics away from compost facilities. Composting is a significant greenhouse gas emission mitigation measure because it results in greater carbon sequestration in crop biomass, a decrease in the need for GHG-releasing fertilizers and pesticides, and a decline in energy-intensive irrigation.
• A net increase in GHG emissions may result because landfill gas capture systems only capture a fraction of the landfill gas generated. The IPCC estimates that lifetime efficiencies are as low as 20% for landfills.
• Most landfills are already required to capture and destroy their fugitive emissions. Giving offset credits for these systems would violate the additionally requirements of a market system. Companies should not be able to sell credits for something that they are legally required to do because it would not result in any further greenhouse gas reductions.

• The adoption of these recommendations directly conflicts with existing state waste reduction and recycling programs and policies. The Integrated Waste Management Act states that recycling and composting are to be prioritized over landfill disposal and that the state should maximize recycling and composting. These recommendations would take us a step backwards in waste reduction and composting.

Offsets from landfill gas to energy should not be supported until the ARB establishes that the offsets are additional and would result in a net decrease of GHG emissions from landfills and provide an overall environmental benefit to California.