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[GreenYes] Air emissions from composting facilities

To ZWForum, GRRN
This message is from our well respected and long time solid waste lobbyist for Sierra Club California (SCC)  Bill Magavern (Bill is now SCC's Director). 
Bill sent this out to the Sierra Club California/Nevada Energy and Global Warming Committee who in cooperation with the national ZWCom on waste issues, has been working on comments to the Calif Air Board on global warming actions and greenhouse gas reduction recommendations. 
I am posting this to the national group as we might expect these concerns to pop up in any region that has poor air quality.
Ann Schneider
Chair, Sierra Club
National Zero Waste Committee
----- Forwarded Message -----
From: "Bill Magavern" <Bill.Magavern@no.address>
Date: Fri, 2 May 2008 17:32:28 -0700

The article below explains why I don’t want us taking sides in the composting vs. clean-air battle until we’ve heard from our air quality comm. (and I have contacted the chairs about this).



INSIDE Cal/EPA - - May 2, 2008


An interagency conflict between the waste board and the San Joaquin Valley air district over a proposed district

rule to cut emissions from composting facilities has prompted the state air board to intervene in an attempt to reach a

compromise. The district’s forthcoming rule to help fight smog in the region is seen as conflicting with the waste

board’s vision of increasing composting to help meet the state’s greenhouse gas (GHG)-reduction targets.

The rule may also create a divide between environmental groups that advocate for more recycling and

composting and those that believe protecting local air quality is more important.


The potential controversy underscores the difficulties different state and local agencies have in pursuing

environmental regulations that may conflict with each other. While the California Integrated Waste Management

Board is under pressure to divert more organics from dumps through composting to address global

warming, this priority may conflict with the air district’s mandate to reduce smog-forming emissions in the



The valley air district is advancing proposed Rule 4566, which seeks to cut volatile organic compound (VOC)

emissions from composting facilities. The district committed to seek the rulemaking in its 2007 ozone plan, which is

a component of the Air Resources Board’s larger statewide implementation plan (SIP). The SIP outlines how

regions will attempt to meet federal and state air quality standards.


The district April 10 and April 17 held public workshops in Fresno to discuss its proposed rule, which it plans

to consider for adoption in early 2009. A copy of a district staff report is available at See page 4 for



San Joaquin officials are seeking to reduce up to 9 tons per day of VOCs from “green waste” composting

facilities in the region. Green waste refers to organic wastes such as food, wood, food processing by-products, and

plant materials.


Due to the valley’s abundant agricultural markets, the region has been seen as a prime location for composting



CIWMB late last year began raising concerns about the district’s rule and how it may interfere with CIWMB’s

efforts to reduce organics that are landfilled, thereby reducing GHG emissions.


CIWMB last year adopted a “strategic directive” aiming to reduce the amount of organics in the waste stream

by 50% by 2020. This is seen as significantly reducing GHG emissions by avoiding decomposition of waste in



To address this potential conflict between the two agencies, one ARB staffer at an April 22 CIWMB meeting

indicated that ARB is “currently looking to take a more proactive role” to help CIWMB and the district find a way

to address both the valley’s emission reduction needs and CIWMB’s efforts to reduce GHG emissions through

increased composting.


“We are getting ready to send out a notice to air pollution control officers to work with your staff on a

composting technical working group to find out what are common sense ways to approach this,” the ARB staffer



Earlier in the meeting, CIWMB member Wes Chesbro said he attended the valley district’s workshops on

the rule, at which district officials expressed a strong desire to work with CIWMB. However, he added that the

district is still proceeding with many “unanswered questions,” referring to a dispute between the two agencies

over the science behind estimates of VOC emissions from composting, as well as the GHG benefits of more



A copy of CIWMB comments to the district is available at See page 4 for details.


Earlier this year, CIWMB staff released a new study analyzing composting emissions, in hopes of convincing

valley air officials that VOCs are actually lower than emissions that would result from organics going into a landfill.

“I do think the message is getting across, [but] we need to do more with ARB and Cal/EPA,” Chesbro said at

the meeting. Cal/EPA “was created for the purpose of mediating these cross-medium conflicts.”


A district source confirmed that a new working group consisting of ARB, the district, CIWMB, and various

stakeholders will begin meeting in May to attempt to “get consensus on what the science really is.”


The source added that the compost emissions data that CIWMB cites is drastically different than previous VOC

emissions studies that the district is basing the rule on. Specifically, CIWMB is citing a new emissions factor from a

Modesto study conducted last year, the district source said. “We want to look at that. Compared to previous emission

factors, this one was way off.”


The source added that the district still believes composting facilities could be very significant sources of VOC

emissions, noting that community groups at the recent workshops urged the district to strengthen the proposed rule

to protect air quality.


Environmentalists have been critical of air pollution impacts from composting in the Central Valley, especially

because the district is currently designated as in “serious non-attainment” of the federal 8-hour ozone standard.

An environmentalist said groups strongly support VOC reductions from composting in this rulemaking,

however, they are open to discussing with CIWMB opportunities to ensure that composting operations do not cease

in California.


Meanwhile, the environmental group Californians Against Waste, which actively lobbies CIWMB to promote

recycling and composting, is siding with CIWMB in the VOC science debate. The group is also raising concerns

that the district’s rule may shut down existing compost facilities and prevent the siting of new operations in the


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