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[GreenYes] Fwd: Recyclers Global Warming Council Comments on CA Market Advisory Committee Draft Recommendations on Carbon Cap-and-Trade

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, 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
( ) 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.


Gary Liss
Recyclers Global Warming Council**

* 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
Fax: 916-652-0485

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