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[greenyes] CA Study of "Conversion Technologies"
Apologies for Cross-Postings

Pasted in below is a letter (without its attachments) just sent from the GrassRoots Recycling Network (GRRN) to the CIWMB regarding their upcoming studies of the Life Cycle Assessment and Market Impacts of "conversion technologies." For purposes of these studies, "conversion technologies" mean the processing, through non-combustion thermal, chemical, or biological processes, other than composting, of residual solid waste to produce electricity, alternative fuels, chemicals, or other products that meet quality standards for use in the marketplace. Processes include, but are not limited to, gasification/pyrolysis; hydrolysis (acid and enzyme); fermentation, distillation, and digestion; catalytic cracking; plasma arc; and steam sterilization.

Please let me know of other proposals that are being made in your areas regarding these technologies in the U.S., and other studies that have been done or are underway that assess the environmental or market impacts of these technologies.

Thanks!

If you would like a copy of the attachments to the GRRN letter, and/or would like to be included in an email discussion group about these issues, please email me.

If you would like more info or background on the CIWMB studies underway, please contact Fernando Berton at <FBerton@no.address>. If you would like an overview of these issues, go to: http://www.ciwmb.ca.gov/Organics/Conversion/

Gary Liss
**************************
August 18, 2003

Fernando Berton
CA Integrated Waste Management Board
1001 I Street
Sacramento, CA 95814

Re: Conversion Technologies Studies

Dear Fernando:

I am writing on behalf of the GrassRoots Recycling Network (GRRN). As you know, GRRN is a network of waste reduction activists and professionals dedicated to achieving a sustainable economy based on the principle of Zero Waste (for more info, see www.grrn.org). We see our task as encouraging a combination of community responsibility and industrial responsibility towards the way materials pass through our society. Where "waste" is currently produced, we would like the emphasis placed on better industrial design to eliminate its production, wherever humanly possible, rather than finding a technology to make the material disappear.

Thank you for the opportunity to provide input on the proposed methodology for the Life Cycle Assessment and Market Impact studies on emerging conversion technologies being done for the California Integrated Waste Management Board (CIWMB). Gary Liss reported that you had an active discussion of many issues at the focus group meeting on August 11, 2003. We are pleased that you are taking great care to make sure your research is asking the right questions, with appropriate methodologies that will best accomplish your objectives.

GRRN would like to highlight some key points of concern to our network:
* Air emissions - The study needs to broaden the list of air emissions evaluated to include all known emissions for all systems under consideration, regardless of whether data is available for all technologies on a consistent basis. The absence of data should be explicitly noted and indicate an area of precaution. In this respect we would draw attention to the fact that a huge discrepancy has been found between dioxin air emissions when collected in six hour testing (the usual method) and two-week tests (the dioxin emissions found can be 30-50 times higher). The latter methodology (AMESA) is now available on a commercial basis and should be specified as the appropriate method for gauging dioxin emissions from new sources in California.
* The studies should focus on residues from material recovery facilities (MRFs) and individual materials that are problems to reuse, recycle or compost and are currently landfilled. However, we are concerned that a huge capital (and political) investment in "converting" these materials could distract decision makers in government and industry from the primary task of designing packaging and products which can be reused, recycled and composted. For this reason, the studies should assume that no diversion credit is given for conversion technology systems.
* The evaluation of technologies should classify the wide range of technologies into technologies that operate above life temperatures (above ~200oF.), and those operating below that (e.g., composting and anaerobic digestion). At high temperatures acid gases are produced, toxic metals are liberated (as gases or fine particulate) from otherwise stable matrices and dioxins and furans (PCDDs and PCDFs) are generated and put into the air and one is left with problematic residues. As a consequence society is left with the huge burden of monitoring these facilities as well as disposing of these problematic residues.
* Emissions and cost data should only be used from commercial scale operating facilities. This should not be an academic exercise of theoretical information. Technologies without such data should be noted as not developed enough yet for commercial municipal applications, and not considered further in the studies.
* Identify any environmental impacts that are not clearly understood and that would be subject to the Precautionary Principle (as recently adopted by the City and County of San Francisco), if adopted by other cities and companies.
* The studies should not only compare the impacts of conversion technologies on "recycling and composting," but also on: eliminating waste and source reduction (and the significant upstream benefits of avoiding wastes from mining, manufacturing and distribution of products, the energy conservation and reduced greenhouse gas emissions benefits of waste prevention and recycling, and to ensure industry will still have an incentive to redesign products and packaging to eliminate waste and design them for reuse, recycling and/or composting.
Moreover, please find attached additional concerns that we ask you to address in the scoping of this project, as well as additional detail relative to those briefly referenced above.


We believe that some conversion technologies may help us to develop the Carbohydrate Economy that eliminates our society's reliance on scarce oil and gas supplies. However technologies used must be designed first and foremost to protect the public's health and safety, and the environment as well as ensuring that we remain focused on truly sustainable practices.

Thank you for including our concerns in the scoping for this project. We look forward to continuing to participate in the review of the results of this research, and the development of policies governing conversion technologies in California.

If you have any questions about our concerns, please do not hesitate to contact Gary Liss at 916-652-7850 or me at 608-232-1830.

Sincerely,
/s
David E. Wood
Executive Director


Gary Liss
916-652-7850
Fax: 916-652-0485

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