Apologies for Cross-Postings
To:
<climatechange@no.address>
From: Gary Liss <gary@no.address>
Subject: Recycling Comments on Market Advisory Committee Draft
Recommendations on Carbon Cap-and-Trade
Cc: ricanthony@no.address, modemo@no.address, MattCotton@no.address,
bnelson@no.address (Bob Nelson), Gary Liss
<gary@no.address>
June 15, 2007
Winston Hickox, Chair
Cal/EPA Market Advisory Committee
California Air Resources Board
1001 I Street
Sacramento, CA 95814
Re: Market Advisory Committee Draft Recommendations on Carbon
Cap-and-Trade
Dear Chair Hickox:
The Recyclers Global Warming Council is a Technical Council of the CA
Resource Recovery Association (see
www.CRRA.com), the
nation's oldest state recycling organization. The Recyclers Global
Warming Council was organized earlier this year to highlight the
significant role reducing, reusing, recycling and composting discarded
materials can play in reducing greenhouse gases.
We are writing in support of the letter submitted by Californians Against
Waste (CAW). In particular, we note that the report recommends
landfill gas capture projects be eligible for carbon offsets. Since this
would result in a strong financial incentive for landfilling organic
materials, offsets from landfill gas capture should not be allowed.
Reducing waste, reuse, recycling and composting reduces more pollution,
saves more energy and reduces GHG emissions significantly more than
landfilling or incineration. For every ton buried in a municipal
waste landfill, 71 tons are buried upstream from mining, manufacturing
and distribution wastes associated with those products. The EPA
WARM model
(
http://www.epa.gov/climatechange/wycd/waste/calculators/Warm_home.html
) highlights these upstream implications for reuse and recycling.*
We urge that the final MAC report include a recommendation for providing
offsets for reducing waste, reuse, recycling and composting, and
eliminating offsets for landfilling.
Sincerely,
Gary Liss
Secretary
Recyclers Global Warming Council**
Notes:
* The WARM model does not factor in the upstream benefits of reduced
fertilizer use, reduced pesticide use and reduced use of energy intensive
irrigation water when compost products are used in agriculture. The
WARM model also uses a flawed assumption of 75% recovery rate of landfill
gases. The benefits of recycling would be even more dramatic if
they used a 20% recovery rate as indicated by the Intergovernmental Panel
on Climate Change.
**The views expressed above by the Recyclers Global Warming Council do
not necessarily reflect the views of the CRRA, CRRA members or other CRRA
Technical Councils.
Gary Liss
Gary Liss & Associates
4395 Gold Trail Way
Loomis, CA 95650-8929
916-652-7850
Fax: 916-652-0485
gary@no.address
www.garyliss.com
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