[greenyes] CA Study of "Conversion Technologies"

[Gary Liss <gary@no.address>]

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