CRRA sent the following comments to CIWMB Chair Brown (mbrown@no.address) and copied CIWMB
Board members (WChesbro@no.address
rmule@no.address cpeace@no.address gpetersen@no.address).
The content of the letter was also submitted to CARB at
http://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=scopingpln08&comm_period=A
Please feel free to cite the letter in your own comments, or use
content from the letter in your comments.
Peter Slote
Chair, CRRA Policy Committee
Margo
Brown, Chair, CIWMB
1001
I Street
Sacramento,
CA 95814
RE: Omission of Zero Waste
Emissions Reductions in AB 32 Scoping Plan
Dear
Chair Brown:
The California Resource
Recovery Association (CRRA) is a statewide non-profit trade group.
CRRA’s more than 450 members represent all aspects of California’s
reduce-reuse-recycle-compost economy.
CRRA is extremely
disappointed that the emissions reductions associated with Measure RW-3 High
Recycling/Zero Waste are not counted toward the AB 32 goal in the October 2008
Proposed Scoping Plan (Plan). Specifically, footnote #43 in Table 20 on
page 63, Section II.15 Recycling and Waste, states, "Reductions from RW-2
and RW-3 are not counted toward the AB 32 goal.” Furthermore,
the Plan recommends no specific actions or policies to implement RW-3
Zero Waste/High Recycling was
established as a "high-confidence" strategy with GHG reduction
potential of 10 million tons CO2 equivalent by 2020 in the Climate Action
Team’s Strategies Underway In California That Reduce Greenhouse Gas
Emissions. The linkage between CIWMB Strategic Directives and climate
protection was discussed extensively at the February 13, 2007 Board meeting
when CIWMB adopted its Strategic Directives. Thus, it is particularly
disappointing that CIWMB has failed to ensure that the Plan includes any
specific actions or policies supporting implementation of its own Strategic
Directives No. 6.1 (Reducing organics to landfill), and No. 5.2 (Extended
Producer Responsibility).
In its lead advisory capacity
to the California Air Resources Board (CARB) for developing the Recycling and
Waste Section of the Plan, CIWMB must ensure that the significant emissions reductions
available through High Recycling/Zero Waste measures are counted, and that
specific actions and policies are recommended.
CRRA hereby petitions CIWMB
to take urgent action to ensure that the Plan is revised to count RW-3
emissions reductions towards the AB 32 goal, and to add specific actions and
policies to achieve RW-3 reductions, including: mandatory commercial recycling;
phase-out of diversion credit for green waste alternative daily cover; and
adoption of Extended Producer Responsibility framework legislation.
I would welcome the
opportunity to meet with you and other Board members to discuss this matter.
Thank you for your
consideration and action.
From:
crra_members@no.address [mailto:crra_members@no.address] On Behalf
Of Gary Liss
Sent: Friday, November 14, 2008 11:29 PM
To: crra_members@no.address; GreenYes@no.address; ZeroWasteCommunities@no.address;
ZWBusiness@no.address; ZERI-US@no.address; p2tech@no.address;
p2@no.address; P2@no.address; GRC-CRRA@no.address
Cc: Gary Liss
Subject: [CRRA] Urgent: Action Needed in CA on Zero Waste and Global
Warming in next 2 weeks
2 weeks are left in public comment period on AB32 Plan to address global
warming in California. It's urgent that recyclers and Zero Waste
advocates comment on the issues as noted below. Please send in comments,
and send a copy to this listserve, so we all know that people are following
up!
Also, please plan to attend Nov 20 Air Resources Board meeting and testify on
the Plan (agenda item 08-10-2: AB 32 Scoping Plan to Reduce Greenhouse Gas
Emissions in California) at:
http://www.arb.ca.gov/board/ma/2008/ma112008.htm
THANKS!
For more info: http://www.arb.ca.gov/lispub/comm/bccommlog.php?listname=scopingpln08
To: <rgwcexcom_crra@no.address>,
<OrganicsOutOfLandfills@no.address>
From: "Gagliardi, Mark" <mgagliardi@no.address>
Date: Fri, 14 Nov 2008 18:24:09 -0800
Subject: [rgwcexcom_crra] CARB Proposed Scoping Plan - Last Stand for Zero
Waste
This is a heads-up that the next few weeks, leading up to CARB's expected
adoption of the Proposed Scoping Plan
(
http://www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm )
at its Dec 11-12 monthly Board meeting, is the critical last stand to
get Zero Waste recommendations into the final adopted Scoping Plan.
Of note:
1. So far, no public comment has been received on waste/recycling ~ 30
days into the 45-day public comment period:
http://www.arb.ca.gov/lispub/comm/bccommlog.php?listname=scopingpln08
2. CARB intends that its Nov 20 Board meeting <<will be the main forum
for hearing oral testimony on the Plan>> - see agenda item 08-10-2
(Public Meeting to Consider the Assembly Bill 32 (AB 32) Scoping Plan to
Reduce Greenhouse Gas Emissions in California) at:
http://www.arb.ca.gov/board/ma/2008/ma112008.htm
3. CRRA is developing a letter communicating its severe disappointment
that the emissions reductions associated with Measure RW-3 High
Recycling/Zero Waste are not counted toward the AB 32 goal in the
October 2008 Proposed Scoping Plan (Plan). Specifically, footnote #43
in Table 20 on page 63, Section II.15 Recycling and Waste, states,
"Reductions from RW-2 and RW-3 are not counted toward the AB 32
goal."
Furthermore, the Plan recommends no specific actions or policies to
implement RW-3. The CRRA letter will also petitions CIWMB & CARB to take
urgent action to ensure that the Plan is revised to count RW-3 emissions
reductions towards the AB 32 goal, and to add specific actions and
policies to achieve RW-3 reductions, including: mandatory commercial
recycling; phase-out of diversion credit for green waste alternative
daily cover; and adoption of Extended Producer Responsibility framework
legislation. The substantial content of this letter will be available
early next week.
BOTTOM LINE: PLEASE CONSIDER ATTENDING THE NOV 20TH CARB BOARD MEETING &
SUBMITTING PUBLIC COMMENT BASED ON THE FORTHCOMING CRRA
LETTER....CALIFORNIANS AGAINST WASTE HAS ALSO SUGGESTED THAT DIRECT
COMMUNICATION TO CIWMB &/OR CARB BOARD MEMBERS FROM ANYONE (ESPECIALLY
ELECTED OFFICIALS) WHO HAVE A RELATIONSHIP WITH SAID BOARD MEMBERS TO
ADVOCATE FOR INCLUDING ZERO WASTE RECOMMENDATIONS WOULD BE PARTICULARLY
EFFECTIVE. SO THIS IS THE TIME TO CASH IN THOSE CHITS IF YOU HAVE THEM.
Mark Gagliardi
City of Oakland
Phone/voice mail: 510-238-6262
Fax: 510-238-7286
e-mail: mgagliardi@no.address
web site: www.oaklandpw.com
www.zerowasteoakland.com
P.S & FYI - this is kind of old news, but Robin Boone testified at
CARB's regular monthly board meeting on 10-23-08. His report immediately
after the meeting was:
<<What I did today; first hearing on the Final Draft Proposed Scoping
Plan. I had two minutes. I was the only one of 15 testifiers to mention
recycling.>>
Item 08-9-4 (Status Report on AB 32 Implementation and the Scoping Plan)
is presented from page 50 - 125 of the meeting transcript at:
http://www.arb.ca.gov/board/mt/2008/mt102308.pdf
Public testimony begins at pg. 80, & Boone's testimony is on pp.
108-110.
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