Resolution No. 09948 1 RESOLUTION NO. 9948
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3 A RESQLUTION OF THE CITY COUNCIL OF THE CITY OF
VERNON APPROVING AND AUTHORIZING .THE EXECUTION OF A
4 LETTER IN SUPPORT OF COMMENTS DEVELOPED BY THE LOS
ANGELES COUNTY SOLID WASTE MANAGEMENT COMMITTEE
5 REGARDING THE CALIFORNIA INTEGRATED WASTE
6 MANAGEMENT BOARD'S LNTERIM REPORT FOR THE LIFE
CYCLE ASSESSMENT OF ORGANICS DIVERSION .ALTERNATIVES
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g WHEREAS, the City of Vernon (the "City") is a municipal
9 corporation and a chartered-city of the State of California organized
1-0 and existing under its Charter and the Constitution of the State of
11 California; and
12 WHEREAS, the Los Angeles County Solid Waste Management
13 Committee (the "Committee") has requested the City's support of
14 comments the Committee has developed for submission to .the California.
15 Integrated Waste Management Board (the "Board") regarding an Interim
16 Report for Life Cycle Assessment of Organics Diversion Alternatives,
17 which is entitled "Facilities Data Collection Approach and Results-for
18 the Life Cycle Assessment and Economic Analysis of Organic Waste
19 Management and Greenhouse Gas Reduction Options," dated March 27, 2009
20 (the "Interim Report"); and
21 WHEREAS, the primary concern in the Interim Report is the
22 determination that greenwaste Alternative Daily Cover does not qualify
23 as a legal and viable diversion alternative, although .there are
24 significant benefits of greenwaste being utilized as an Alternative
25 Daily Cover material at landfills including: reducing landfill
26 operating costs, conserving landfill capacity, and providing an
27 environmentally sound diversion option; and
2g WHEREAS, an additional concern of the City is that it
1 receives diversion. credit for AB 939 compliance for greenwaste being
2 utilized as Alternative Daily Cover material; and
3 ..WHEREAS', by memo dated April 27, 2009, the Director of
4 Health & Environmental Control concurred with the Committee°s
5 evaluation of the Interim Report and recommended that the City issue a
6 letter in support of the comments developed by the Committee with
7 regard to the Board'S Interim Report for-the Life Cycle Assessment of
8 Organics Diversion Alternatives ("Life Cycle'Assessment").
9 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF-THE
10 CITY OF VERNON AS FOLLOWS:
11 SECTION 1: The City Council of the City of Vernon hereby
12 finds and determines that the recitals contained hereinabove are true
13 and correct.
14 SECTION 2: The City Council of the City of Vernon hereby
15 states its. support of the comments developed by the Committee in
16 regards to the Board's. Interim Report for the Life Cycle Assessment
17 and directs the Mayor, or his designee, to send a letter of support,
18 in substantially the form .attached hereto as Exhibit A and
19 incorporated by reference, to Margo Reid Brown, the Chairman of the
20 Board.
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1 SECTION 3: The City Clerk of the City of Vernon shall
2 certify to the passage of this resolution, and thereupon and
3 thereafter the same shall be in full force and effect.
4 APPROVED AND ADOPTED this 11th day of May, 2009.
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6 ~/y~,~,,., s-
Name: Hilario.Gonzales
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8 Title: Mayor./ _
9 ATTEST:
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11 ANUELA-GIRO ity Clerk
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1 STATE OF CALIFORNIA )
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COUNTY OF LOS ANGELES )
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4 I, MANUELA GIRON, City Clerk of the City of Vernon, do hereby
5 certify that the foregoing Resolution, being. Resolution No. 9948, was
6 duly adopted by the City Council of the City of Vernon at a regular
7 meeting of the City Council duly held on Monday, May 11, 2009 and
8 thereafter was duly signed by the Mayor or .Mayor Pro-Tem of the City of
9 Vernon.
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12 MANUELA GIRON, ty Clerk
13 (SEAL)
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EXHIBIT A
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4305-Santa Fe.Avenue, Vernon, California 90058
e Telephone (323) 583-8811
DRAFT
April 28, 2009
Ms. Margo Reid Brown, Chair
California Integrated Waste Management-Board
1001 I Street
Sacramento, CA 95812-2815
Support of Comments Regarding Interim Report. for Life Cycle Assessment of Organics
Diversion Alternatives
Dear Ms. Brown:
The City of Vernon appreciates the opportunity to provide input on the development of solid
waste decision making and policies. Please note that the City is in support of the comments
developed by the Los Angeles County Solid Waste Management Committee in regards to the
California Integrated Waste Management Board's interim report for the Life Cycle Assessment
of Organics Diversion Alternatives. A copy of the Los Angeles County Solid Waste Committee
comment letter is attached for reference.
Thank you for your consideration. If you have any questions, please contact Lewis Pozzebon,
Director of Health and Environmental Control at (323) 583-8811 Ext. 229.
Sincerely,
Hilario Gonzales
Mayor
Attachment
Xc: Anthony Gonsalves
E.xcCusiveCy Indust~iaC
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4305 Santa Fe Avenue, Vernon; California 90058
Telephone (323) 583-8811
May 11, 2009
Ms. Margo Reid Brown, Chair
California Integrated Waste Management Board
1001 ~ Street
Sacramento, CA 95 $12-2815
Support of Comments Regarding Interim Report for Life Cycle Assessment of organics
Diversion Alternatives
Dear Ms. Brown:
The City of Vernon appreciates the opportunity to provide input on the development of solid
waste decision making and policies. Flease note that the City is in support of the comments
developed by the Los Angeles County Solid Waste Management Committee in regards to the
California Integrated Waste Management Board's interim report for the Life Cycle Assessment
of Organics Diversion Alternatives. A copy of the Los Angeles County Solid Waste Committee
comment letter is attached for reference.
Thank you for your consideration. If you have any questions, please contact Lewis Pozzebon,
Director of Health and Environmental Control at (323) 583-8811 Ext. X29.
Sincerely,
'
Hilario Gonzales `
Mayor
Attachment
Xc: Anthony Gonsalves
E.xcCusiveCy IndustriaC
LOS ANGELES COUNTY
SOLID WASTE MANAGEMENT COMMITTEE/
INTEGRATED WASTE MANAGEMENT TASK FORCE
9.00 SOUTH FREMONT AVENUE, ALHAMBRA,'CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
wwwaacountyiswmtf.org
GAIL FARBER
CHAIR
April 20, 2009
Ms. Margo Reid Brown, Chair
California Integrated Waste Management Board
1001.1 Street
Sacramento, CA 95812-2815
Dear Ms: Brown:
COMMENTS REGARDING INTERIM REPORT FOR -LIFE CYCLE ASSESSMENT OF
ORGANICS DIVERSION ALTERNATIVES
On behalf of the Los -Angeles .County Solid :Waste ,Management. Committee/
Integrated Waste Management Task Force, t want to thank the California Integrated
Waste `Management Board (Waste Board) for-the opportunity to comment on the interim
:report for the Life. Cycle- Assessment. of .Organics Diversion- Alternatives, entitled
"Facilities Data Collection Approach and Results for the Life .Cycle- Assessment and
Economic Analysis of Organic Waste Management and Greenhouse Gas Reduction
Options," dated .March 27, 2009.
Pursuant to Chapter-3.67 of the Los Angeles County Code and the California Integrated
-Waste Management Act of 989 (AB 939,. as amended), the: Task. Force is responsible
for coordinating the development of all major solid waste planning documents prepared
for the County. of Los Angeles and the 88 cities within with a combined population in
excess of ten million. Consistent with these- responsibilities, .and to ensure a
coordinated and cost-effective and. environmentally sound solid waste management
system in Los Angeles County, the Task Force also addresses issues impacting the
system on a Countywide basis. The l"ask Force membership includes representatives
of the- League of California Cities-Los. Angeles County Division, the County of
Los Angeles Board of Supervisors, the City of Los. Angeles, .the .waste management
industry, environmental. groups, the public, and a number of .other governmental
agencies.
r
Ms. Margo Reid Brown
April- 20, 2009
Page 2
We have reviewed the interim report and offer the following comments/concerns.
1. Greenwaste Alternative Daily Cover
The study is fundamentally .flawed in dismissing the .use of greenwaste
Alternative Daily Cover (ADC) as a legal- and viable diversion alternative
and equating it with disposal. .Assembly Bill 1647 (Bustamante, 1996)
made a distinction between greenwaste used as ADC and that of disposal
.and recognized the significant .benefits of greenwaste ADC in reducing
operating costs, conserving ,landfill capacity, and providing, an
environmentally sound diversion option. In fact, the preliminary findings of
a study currently being conducted by the Center for the Study of
Sustainable. Use of. Resources. at Columbia University indicates that-
- windrow composting has higher adverse effects in .comparison to
greenwaste ADC (copy enclosed).
It's imperative that greenwaste ADC remains a legal and viable diversion
alternative since it's among the highest environmentally<sound option. It
promotes a healthy and .diverse- solid- waste infrastructure to manage he
sheer volume of greenwaste generated and prevents the State from
becoming over dependent on a few' arbitrarily chosen options. .This
diversity allows the marketplace to remain cost competitive, limits risks
due to fluctuation in the marketplace, and promotes a progressive
marketplace. -
In addition, to enable decision makers to make informed decisions
regarding organic waste management and evaluate the true costs of
various options, the interim report should be expanded to .include the
environmental and- economic consequences of eliminating the use- of
greenwaste ADC as a viable diversion .alternative,. such as, but not limited
to:
• Increasing soil mining for use as-ADC;
• Decreasing the decomposition rate of the solid waste disposed- in
the landfill;
• Transportation impacts (e.g., increased traffic congestion, air
pollution, and greenhouse gas emission) as a result of transporting
greenwaste to out-of region composting facilities; and,
Ms. Margo Reid Brown '
April 20, 2009
Page 3
• Transportation impacts (e.g:, increased traffic congestion, air
pollution, and greenhouse gas emission) as a result of transporting
the compost material to end users.
The above- impacts must be evaluated since they are acute to Southern
California where greenwaste ADC. has been a .vital diversion alternative
due to inadequate .processing capacity .for greenwaste and a limited
market for compost.
2. Emerging Technologies as a Diversion Alternative
The interim report limits its scope of technologies to anaerobic digestion,
biomass-to-energy; and waste-to-energy.. As indicated in RTI
International's February 2, 2009, presentation, one goal is to "develop
transparent, consistent, .and objective data to characterize alternatives on
an equal ,basis". If that is the case, then all technologies, including the
broad range_ of conversion technologies, :must be considered on a level
playing field. Therefore, the interim- report-must be expanded to recognize
the findings of:
The Waste Board's own three-year study on conversion
technologies conducted pursuant to AB 2770, Chapter 740 of the
2002 State Statutes;-
. • The .conversion technology efforts by the County of -Los Angeles
(www: SoCalConversion.org);
. • The State Bioenergy Action Plan; and,
• The State Interagency Bioenergy Working Group.
Selectively choosing technologies. limits progress and development of
"green" technologies in California and is in direct contrast to many of the
.State's progressive environmental and energy goals and the State's goal
to create highly skilled jobs.
3. Greater Sampling Population
The number of facilities surveyed is too small- to .provide meaningful and
representative data for the study. For example, of the 155 landfills,
185 chippinglgrinding facilities, and 50 composting facilities in California,
only 23, 6, and 16 .facilities, respectively, were selected as survey
candidates. Of this limited pool of potential participants, only a handful of
Ms. Margo Reid- Brown
April 20, 2009
Page 4
facilities responded to the survey. In order for the interim, report to provide
accurate greenhouse gas emission data and cost savings, if any, from. the
data collected, the- sampling effort must be carefully .reevaluated to
determine whether this very small sample size will yield statistically
accurate data.
The Task Force appreciates your consideration and respectfully requests a written
response to this letter as well as the August 21, 2008., and December 8, 2008, letters
{copies enclosed) regarding the same subject as expeditiously as .possible. If you have
any questions, please contact Mr. Mike Mohajer of the Task Force at (909) 592-1147.
Sincerely,
Margaret Clark,-Vice-Chair
Los Angeles County Solid Waste Management Committee/
.Integrated Waste Management Task Force and .
Mayor, City of Rosemead
LL:cw
P:\Sec\TaskforCe\Organics LCA
Enc..
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda Adams
Each Member of the California Integrated Waste Management Board
California Integrated Waste Management Board (Mark Leary, Ted, Rauh,
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The League of California Cities, Los Angeles County Division
Each Member of the County of Los Angeles' Board of Supervisors
Each City Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of'Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
} p y^
~e3 S~$ I ~ rv~ti
Interim Progress Report of Center for Sustainable Use of Resources (SUR),
Earth Engineering Center of Columbia University
SUR`Pro}ect Title: Comparison of Use of Green Wastes as Alternative Daily
Cover in Regulation Landfills and by Composting in Open Windrows and In-
vessel Systems
Report by N.J. Themelis; LCA study by Rob van Haaren; co=PI: Morton Barlaz
Summary of results to date -.March 23, 2009-
This study is part of a SUR project to identify the best available technology for
processing green wastes. It consists of two parts: an in-depth study ofthe tonnages of
green wastes processed. by various aerobic composting methods and amulti-criteria
analysis (MCA) to identify the best of these methods; and a comparison. of the
.environmental- impacts of using green wastes as feedstock for aerobic composting or as
Alternative Daily-Cover (ADC) in regulation landfills.
The BioCyele-Columbia study of 2006 data showed.that 22.7 million tons of the.
organic fraction of MSW in the U.S. were composted or mulched, that is about 5.5%
of the total MSW generated. This number is 1.7 million tons greater than the 2004
estimate. The tonnages processed by various aerobic composting methods
(windrow, static aerated pile, in-vessel) were not documented in the BioCycle
survey. However, it is known that the dominant, and least costly, method is windrow
composting. Also,.there is insufficient data on the tonnage of food wastes processed
but EPA-has estimated that only 0.7 million tons of food wastes were composted in
2006. Including the food fraction in the feedstock to the composting process is
beneficial for the subsequent use'of the compost product, because of its high
nutrient content. However it is not recommended for open air windrow composting
because of undesirable odors.
The MCA study of SUR consists of assessing environmental impacts, investment and
operating costs and associated effects, such as odors and use of land, in order to
determine the best available aerobic composting technology. The environmental
impact assessment is carried out by means of a Lifecycle Analysis (LCA) using the
Eco-indicators-99 methodology of the SimaPro software that was developed in the
E.U. by Pre Consultants and is used widely in Europe and the U.S. This program is
described in detail at www.pre.nl/simapro.html.
The inventory of emissions needed to carry out the LCA study was developed by
combining life-cycle inventories from published papers and emission studies for
1
windrow composting and also for regulation landfills. However, the dataset for air
and water emissions of the Gore-technology (aerated static pile) has not been
completed as yet..The Gore-Tex technology is less costly than in-vessel composting
and is increasinglybeingus~d in U.S. composting facilities.
The chart of Figure 1 below shows the results of the environmental impact,
assessment of three green-waste composting methods: Windrow Composting (WC),
Alternative Daily Cover (ADC) and In-vessel aerobic Page: 2
composting (INS. The .horizontal zero-line on the y-axis denotes that bars above
this line-represent adverse. effects on -the environment and bars below beneficial
effects. The: units on the y-axis of the SimaPro graph are called "ecopoints". The
Ecopoint score is a measure of the overall environmental impact of a particular-
product or process. Very roughly, the total environmentaiimpact by all
anthropogenic activities in the E.U.; divided by the E.U. population, is considered to
be equal to 100 Ecopoints per person.
Originally, this system was developed for. assisting the Swiss government to compare the
total effect of different .types of environmental impacts. For example, starting from he
top of the 1'eft bar on Figure 1, the dark blue bar denotes acidification. and eutrophication
effects, the light-blue bar climate change, the yellow respiratory effects, and the light
brown bar avoided use of fossil fuels. In order to compare effects in different categories,
weighing factors are used which may be somewhat subjective. Forexample, the release
of 1 kg of NO3 (eutrophication) in water may be comparable to the release of 5 kg of
CO2 into the atmosphere (climate change). However, the most important use of these
graphs is the comparison of the effects between each method. For example, acidification
is 8 times more severe in windrow composting as in in-vessel aerobic composting
because in the latter the composting gases are captured and cleaned in biofilter systems.
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Figure 1. Comparison of environmental impacts of windrow composting, ADC use in
regulation landfills, and in-vessel composting of green wastes. The functional unit for
the LCA comparison is one ton of green wastes.
It can be seen from Figure 1 that, according to the LCA, windrow composting
method has higher adverse effects than use of green wastes as Alternative Daily
Cover (ADC). The principal reason for the beneficial effect of using green wastes as
ADC is that one ton of shredded yard wastes replaces nearly six tons of soil that,
according to-EPA regulations for sanitary landfills, must be used as daily cover on
the surface of a working cell. The regulation requires a 15-cm .(six-inch) daily cover
of soil. Several California landfills use a 23-cm (9-inch) ADC cover of yard wastes in
place of soil.
It is evident that much less effort, and use of motorized equipment, is needed to
shred and spread one ton of green wastes than by digging up and spreading six tons.
of soil. The use of green wastes ADC has the additional advantage that it increases
the capacity of a landfill cell because the nine inches of shredded green waste cover
per day are eventually compacted into less than one inch, while there is relatively
little compaction of the six inches of soil that must be used daily, as per EPA
3
regulation. Therefore,: the use of green wastes ADC results in saving. of landfill space
and, consequently, land used for landfilling.
A beneficial factor for both windrow and in-vessel composting is-that the compost
product can be used as aloes-quality fertilizer. This study estimated that one'metric
ton of green wastes replaces 16 kg of N-Fertilizer, 2.4 kg of P-Fertilizer and 6.4 of K-
Fertilizer, both in windrow composting and in-vessel aerobic composting.. The
principal advantage- of in-vessel over windrow composting is that the latter is not fully
aerobic: Parts. of the composting material within the core of the pile reacts anaerobically
emitting a .gas similar to landfill .gas but at a much lower quantity. This gas is not
captured and. therefore results in high ratings in the acidification/eutrophication, climate
change, and respiratory ailments categories.
The ADC scenario was based on astate-of-the-art sanitary landfill that collects
leachate from the MSW and captures landfill gas within five years after starting a
landfill'ce1L Therefore, no water emissions were included in this scenario. The fossil
fuel benefit results from the avoided soil excavation and from LFG collection. Green
wastes are used instead of soil as daily cover of.the landfill, An estimated 82%
fraction of the methane generated in such a cell is collected by the-LFG recovery
system. and is used in a gas engine to generate electricity (thus avoiding the use. of
fossil fuels).
In the in-vessel composting scenario, the energy used to compost and cure one ton
of green waste is-lower than the avoided use of energy for producing an equivalent
amount of fertilizers. Therefore, the overall effect is positive for the environment, in
terms of net fossil fuel use.
It is expected that the 1VICA and LCA studies of SUR will be completed by May 2009.
NJT, March 24, 2009
4
LOS ANGELES COUNTY
SOLID WASTE .MANAGEMENT COMMITTEE:=-
INTEGRATED WASTE MANAGEMENT TASK FORCE
900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacou ntyiswmtf.o rg
GAIL FARBER
CHAIRPERSON
December 8; 2008
Ms. Margo Reid Brown, Chair
California Integrated-Waste Management Board.
1001 I Street
Sacramento, CA 95812-2815
Dear Ms. Brown:-
DISCUSSION OF ORGANICS POLICY ROADMAPS 1 AND II
CALIFORNIA-INTEGRATED WASTE MANAGEMENT BOARD MEETING
AGENDA ITEM 8, DECEMBER 16; _2008 -
0n behalf of the Los Angeles County Solid .Waste Management Committee/Lntegrated
1/Vaste Management Task Force, we respectfully request the California. Integrated.
,Waste.. Management Board.. (Waste Board) respond to -our August 13 and 21, 2008
.letters (copies. enclosed) expressing- significant concerns regarding. the Waste Board®
direction to rely primarily on composting to reduce organics in the waste. s#ream (50?
by 2020), rather than adopting adiversified -and. pragmatic strategy. By adopting
strategies in addition to composting (which has significant shortcomings including siting
difficulties; the need for large acreage of land; odor, .air quality/greenhouse gas
emission, and water quality concerns; lack of markets for end products due to product
inconsistencies; and permitting/regulatory hurdles), California® solid waste
.infrastructure would- be better insulated: from shifting. and .often. uncontrolled factors such
as those relating to global .markets..
Pursuant to Chapter 3.67 of the -Los Angeles County Code and the California Integrated
Waste .Management Act of 1989 (AB 939, as amended), the Task. Force is responsible
for coordinating the development of all-major solid waste planning .documents prepared
.for the County of ,Los Angeles. -and the 88 .cities within Los Angeles County with a
combined population. in excess of 10 million. Consistent with these responsibilities, and
to ensure a coordinated and :cost-effective and .environmentally-sound solid waste
management system. in Los Angeles County., the Task Force also addresses issues
impacting the system on a countywide basis. The Task Force membership includes
representatives of the League of California Cities-Los Angeles County Division, the
County of Los Angeles Board of Supervisors, the .City of Los <Angeles, the waste .
Ms. Margo Reid Brown .
December 8, 2008
Page 2
management ..industry, .environmental groups, the public, and a number of .other
governmental agencies.
On December 9,.2008, the Waste BoardC~ Strategic Policy Development Committee will-
be discussing Agenda Item C (Waste Board Item 8), Organics Policy. Roadmaps I and
II. According #o the staff report, the Waste Board will be continuing its discussions from
June. 2008. Based on our review of the staff report, we were disheartened to learn that
our comments expressed in letters dated August 13 and 21, .2008 were. not addressed,
let alone responded to. As detailed in these letters, the Task Force requests the Waste
Board to:
1. Define the terms "Organic." and "Compostable Organic" since they are not
defined by statute, regulation or the Waste Board Strategic Directive 6.1.
Defining these terms is critical to the overall conversation especially since there
is wide disagreement within the. Waste Board itself on .what these terms mean.
For example,. the staff report -for this Item indicates organics account for 23
million tons of the disposal waste stream .(approximately 55?) while the June 17;
2008- (Item 10) staff report states Organic materials comprise over 30? of the
waste stream deposited in California landfills.?Further, based on the Statewide.
Waste Characterization Study- released by the Waste Board in December 2004,
the "organic" fraction- of solid waste disposed in California landfills ranges
between 70 and 80 percent. Therefore, clear and distinct definitions. are needed
to avoid. confusion-among the legislature and regulatory bodies, regulated
communities, and local governments which ultimately bear the cost of meeting
the 50? organic reduction goat by 2020 as stipulated by the -Waste Board
Strategic Directive 6.1.
Furthermore, it is also very important that the Waste Board identify which organic
waste stream category it is targeting for reduction. Based on the Waste Board
December 11, .2007, Agenda Item 15, it appears that the goal is ;focused on
composting/diverting source separated streams, such as green waste, food
waste; manure, etc:, and not the total. "organics" currently being disposed of in
landflls. If the latter is true; jurisdictions in California may be faced with achieving
a mandatory hack doorC~iversion rate of approximately 85 percent by 2020.
2. Gonsiderthefindings of State and local- efforts confirming that-conversion
technologies (green?high tech technologies utilized in Europe and Japan
which convert post-recycled- solid waste into renewable energy, useful
products, and -green fuels) are capable of managing organic material in an
environmentally sustainable manner. According to the Waste Board! own
Ms. Margo Reid Brown
December 8, 2008
.Page 3
three-year. study. on conversion technologies .(prepared at .the request of the
Legislature, .Assembly Bill. 2770.; 2002 ,Statutes) and numerous other- parallel
studies, conversion technologies have been demonstrated to have numerous
tangible benefits, including reducing .greenhouse gas .emissions, waste
. aransportation, and landfill: disposal; displacing fossil fuels. by producing fuel,
energy, and .other;. products; .and, creating green-collar jobs. By including
coriversion technologies in the [tool boxy it will help ensure the attainment. of fhe
desired organic reduction goal. Otherwise, the Waste Board will continue. to be
focused on [soft?solutions such as forming more committees and conducting
unnecessary duplicative studies and solely emphasizing afavored-technology.
Such a direction is not consistent with Governor Schwarzenegger~
statement/position that. d"urning waste products into energy is good for the
stateCS .economy; local job creation, and our environment. By implementing
biomass programs in California, we will help fight. critical. waste-disposal -and
.environmental problems., including the risk of wildfires., air pollution from open
field burning, and greenhouse gas emission from landfills.?
3. Work closely with local jurisdictions in formulating State policy to reduce
green waste- alternative daily cover (ADC). The use of greenwaste as ADC..
has numerous environmental and economic benefits, including: preventing the
mining and wasting of clean-soil that would have otherwise been used as daily
cover; conserving landfill capacity, by avoiding an additional cover material layer
and the ability of green waste to compact and decompose over time; creating
markets for the beneficial use of green waste; maintaining a local ouflet fer the
beneficial use of greenwaste; and strengthening the curbside collection
infrastructure. for greenwaste. These benefits are ,especially important in
Southern California: since there is inadequate `processing capacity for green.
-waste and a limited market for compost made from greenwaste due to difficulties
encountered in permitting/developing these'types of facilities.. This is particularly
acute in urban areas due to lack of suitable. land, stringent air quality regulations,
-and community reluctance towards the proximity of such facilities. Even if such
facilities were developed .elsewhere, greenwaste would still need to be
transported overlong distances, leading to higher trash rates and added traffic
congestion and air pollution.
Although .the formulation of State. policy to reduce .green waste: ADC would
significantly impact cities. and counties,` to date, .the Waste Board.-has largely
ignored seeking input from them. For example, the ADC Policy- Workgroup
convened by the Waste Board earlier this year to .formulate ADC
recommendations to the Waste Board was comprised of selected members from
Ms. Margo Reid Brown
December 8, .2008
Page 4
the private sector and environmental interest groups with virtually no local
government representation. Thus, it is imperative. that .the Waste Board be
inclusive in its solicitation for input rafher than ~elective~nput.
Due to the gravity of the :concerns expressed, °we respectfully request a written
response to this letter as well as the-August 13 and 21,. 2008 letters as expeditiously as
possible. If you have any questions, please contact Mr. Mike Mohajer of the Task Force
at (909) 592=1147.
Sincerely,
Margaret Clark, Vice-Chair
Los Angeles County .Solid Waste Management Committee/
Integrated Waste Management Task Force and
Council Member, City of Rosemead
LL:
P:\eppub\ENGPLAN1LindalRegslOrganics. Policy Roadmaps I and Il:doc
Enc.
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda Adams
Each Member of the California'Integrated Waste Management Board
California .Integrated Waste Management Board (Mark Leary,. Ted Rauh;:
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The League of California Cities, Los Angeles County Division
Each Member of the County of Los AngelesCBoard of Supervisors-
Each City Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
.Gateway Cities Counsel of Governments
Southern California Association of Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Cos Angeles County Integrated Waste Management Task Force
LOS ANGELES COUNTY
~ ~ SOLID WASTE MANAGEMENT COMMITTEE-'
INTEGRATED WASTE MANAGEMENT TASK FORCE
900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1.331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacou ntyiswmtf.org
DEAN D. EFSTATHIOU
CHAIRMAN
August 13; 2008
Ms. Margo Reid Brown, Chair
California Integrated Waste Management Board
1001. I Street
.Sacramento, CA 9581:2-2815
Dear Ms. Brown:
DISCUSSION OF POTENTIAL OPTIONS FOR THE ORGANIC DIVERSION- FACILITIES
SITING PROJECT (STRATEGIC DIRECTIVE 6.1)
On behalf of the Los Angeles County Solid Waste Management. Committee/Integrated
Waste Management-Task Force, I would like to commend the California Integrated Waste
Management Board (Waste Board.) for its efforts in .promoting environmentally beneficial
alternatives. to reduce the disposal of organics. However; `as listed below, we fiave a
number. of concerns regarding- the Waste BoardC~ Directive 6.1 and its staff report for
Item 11 of the June 17, 2008, Waste Board meeting.: On-June 10, 2008, this item was
'considered by the .Waste BoardC~ Strategic Policy Development Committee without
addressing concerns expressed. by stakeholders.
Pursuant to Chapter 3.67 of the Los Angeles County Code and the California Integrated
Waste Management Act of 1989 (AB 939, as amended),.the Task Force is responsible for
.coordinating the development ofall major solid waste planning documents prepared for the
County of Los Angeles and the 88 cities within Los Angeles County with a combined
.population in excess of ten million. Consistent with these responsibilities, and to ensure a
coordinated and cost-effective and environmentally-sound solid waste management system
in Los Angeles County, the Task Force also addresses issues impacting the system on a
countywide basis. The -Task Force membership .includes representatives of the League of
California Cities-Los Angeles `County Division; the County of Los Angeles Board of
Supervisors, the -City of Los Angeles, -the waste management industry, environmental
groups, the public, and a number. of other governmerital agencies.
We would like to offer the following comments/concerns .regarding your staff report on
options for siting of organic diversion. facilities as well as the Waste Board Strategic
Directive 6.1.
Ms. Margo Reid Brown
August 13, 2008
Page 2.
1. The- Waste- Board needs to define the -terms "Organic" and
"Compostable Organic"
The term "organic" is not defined by statute or regulation. WebsterGs Dictionary defines
the term. ''organic" as: "of, re/sting to, or derived from living organisms" and "of, relating
to, or containing carbon compounds. " As such, based on the Statewide Waste
Characterization Study released by the Waste. Board ~in .December 2004,_ the "organic"
fraction of solid waste disposed in California landfills ranges between 70 and 80 percent.
The June 17, 2008, Waste Board Staff report states that "Organic materials comprise
over 30 percent of the waste stream disposed in California landfills:" This. statement is
inconsistent with the Waste Board Gs 2004 Statewide Waste Characterization Study as
well as the staff report that was presented to the Waste- Board on December 11, 2007.
In that report, staff indicated that "Compostable organic materials comprises
approximately 25 percent, or about 90 million tons, of what is disposed in landfills
annually, .and paper and .woody portion of Construction. & Demolition debris constitute
another 93 or so million tons." Thus, it appears that Waste Board staff made a.
distinction between the terms "organic".and "compostable organic," but did not make an
attempt to define the terms:
The .terms. "organic" and "compostable organic" materials need to be clearly defined to
avoid confusion among the legislature and regulatory bodies,, regulated .communities,
and. local governments that ultimately have to bear the- cost. -Furthermore, there is a
need for the Waste. Board to reexamine its Strategic Directive 6.1, which calls for 50
percent reduction in the amount of "organics" being disposed in landfills by 2020.. Based
on the December 11, 2007, Agenda Item 15, it appears that the goal is focused on the
composting/diverting of source separated .streams, such,as green waste, food waste,
manure, etc., and not the total "organics".currently being disposed in landfills: If the
.latter is true, jurisdictions in California may be -faced with achieving a .mandatory
diversion rate of approximately 85 percent by 2020.
2. The Waste Board needs to .consider, the findings. of S#ate and local
efforts with. regards to conversion technology
The June 17, 2008, Waste Board staff report indicates "Organic diversion facilities
include compost, conversion technology, chipping and grinding, and transfer stations.."
The Task Force commends the Waste Board for its recognition and inclusion of
conversion technology into the organic diversion facilities .category. However, we .are
disappointed with the Waste. Board® staff report .and recommendations which fail to
recognize the findings of {a) the Waste Boards own three-year study on conversion
technologies conducted pursuant to AB 2770, Chapter 740 of the 2002 State Statutes;
Ms. Margo Reid Brown
August 93,.2008-
Page 3
(b) the conversion technology efforts by the County of Los Angeles; (c) the- State
Bioenergy Action Plan; and (d) the State Interagency Bioenergy Working Group.
Unfortunately, these findings were not considered by the Strategic Policy Development
Committee on June 10, 2008. We strongly believe that the Waste. Board needs to
:consider these studies -and efforts prior. to any further action. This reevaluation will
further substantiate that. the Waste Board must place a greater reliance on the
development and siting of conversion technology facilities rather than focusing on "soft"
..solutions such as forming more committees and conducting unnecessary duplicative
studies.
We would appreciate your written response which would be of great interest #o jurisdictions
in Los Angeles County as well. as those throughout the State. If you have any questions,
please contact. Mr. Mike Mohajer of the Task Force. at (909) 592-1147.
Sincerely,
Margaret Clark,. Vice-Chair
Los Angeles County Solid 1Naste Management Committee/
Integrated Waste IVlanagement Task Force and
Council Member, City of Rosemead
LL:kp
P:\SEClorganics Facilities Le(ter.doc
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda. Adams
Each Member of the California Integrated Waste Management Board
California Lntegrated Waste Management Board (Mark Leary, Ted Rauh,
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The League of California Cities, Los Angeles County Division
Eaeh Member of the County of Los Angeles~oard of Supervisors
Each City Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of Governments
- Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
LOS ANGELES COUNTY
SOLID WASTE MANAGEMENT COMMITTEE/
JNTEGRATED WASTE MANAGEMENT TASK FORCE
.900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacountyiswmtf.org
DEAN D. EFSTATHIOU
CHAIRMAN
August 21, 2008
Ms. Margo Reid Brown, Chair
California Integrated Waste Management Board
1001 I Street
Sacramento, CA 95812=2815
Dear Ms. Brown:
POLICY OPTIONS TO REDUCE GREEN MATERIAL ALTERNATIVE DAILY COVER
On behalf of the Los Angeles County Solid Waste Management Committee/Integrated
Waste Management Task Force (Task. Force), 1 respectfully request the California
lntegr-ated Waste Management- Board (Waste Board) to work with local governments in
formulating State policy to reduce green waste alternative daily cover (ADC) since such
policies will significantly impact their ability to comply with the State's 50 percent waste
reduction mandate-and result in other unintended environmental consequences. These
op#ions (Item 10 of the June 17, 2008, Waste -Board Agenda), were considered by-the
Waste Board's Strategic Policy Development Committee at its June 10, 2008,. meeting.
These options :included phasing out green waste ADC diversion credit, applying
disposal. and tipping fees on ADC, using generated revenues from these fees to
.promote development of composting facilities, as well as possible mandates on local
jurisdictions to develop and adopt a 15-year composting .capacity element similar to the
existing Assembly Bill 939 mandated Siting Element.. Unfortunately, these options were
developed with virtually no inputfrom cities and counties.
Pursuant to Chapter 3.67 of the Los Angeles County Code and the California Integrated
Waste Management Act of 1989 (AB 939, as amended), the Task Force is responsible
for coordinating -the development of all :major solid- waste planning documents prepared
for the County of Los Angeles and the 88 citiesin Los Angeles Countywith a combined
population in excess of ten million. Consistent with these responsibilities, and to ensure
a coordinated and cost-effective and environmentally-sound solidwaste management
system in Los Angeles County,-the Task Force .also addresses issues impacting the
system- on aCounty-wide basis. The Task Force membership includes representatives
of the League of California Cities-:Los Angeles County: Division, the County of
Los Angeles Board of .Supervisors, the City of Los Angeles, the waste management
industry, environmental groups, the public, and a number of other governmental
agencies.
i
Ms. Margo Reid Brown
August 21, 2008
Page 2
The use of greenwaste as ADC has numerous environmental and economic benefits,
including: preventing the mining .and wasting of clean soil that would have otherwise
-been .used as daily cover; conserving landfill capacity, by avoiding an additional cover
material layer and the ability of green waste to .compact and decompose over time;
creating markets for the beneficial use of green waste; maintaining a local outlet for the
beneficial use of greenwaste; and, strengthening the curbside collection infrastructure
for .greenwaste. These benefits are especially important in Southern, California. since
there is inadequate processing capacity for green .waste and a limited market for
compost made from greenwaste due to difficulties encountered in permitting/developing
these types of facilities. This is particularly acute in urban areas due to-lack of suitable
land, stringent air quality regulations, and community reluctance towards the .proximity
of such facilities. Even if such facilities were developed elsewhere, greenwaste would
still need ao be transported over long distances, leading to higher trash rates and added
araffic congestion and air pollution..
Because of These significant benefits, in 1996 the Legislature passed Assembly Bill
1647 (Bustamante) to provide- unrestricted. diversion credit to green waste used as ADC,
.making a distinction from .greenwaste disposed in the. landfill. Due to this diversion
credit, and .because of the benefits listed above, jurisdictions and private industry
invested millions of dollars in expensive equipment and infrastructure to implement
greenwaste collection and recycling programs which provide for the separate collection
of green waste to be used as ADC:- .Jurisdictions in Southern California and other parts
of the state now rely on this infrastructure to manage green waste to maintain
compliance with.the State's 50 percent waste reduction mandate. '
It is for the above reasons that the Task Force requests the Waste .Board to work
closely-with cities, counties and other impacted communities in formulating State policy
to reduce green waste ADC, especially those that-will be significantly impacted by such
policies.. Further, while we are supportive of composting, .shifting green waste away
from ADC towards composting facilities will also .result in .increased trash rates,- air
pollution, and traffic congestion in Southern California.. The Task Force also has strong
reservations regarding the proposal to eliminate ADC diversion credit and thus
mandating additional diversion .mandates on local jurisdictions without considering the
critical resources necessary to successfully meet ahem.. .Therefore, we respectfully
request the .Waste Board redirect its efforts to place a .greater emphasis on diverting
.green materials. currently being disposed _ rather than consuming resources on
investigating ways to decrease the beneficial use of green waste as ADC as legitimized
by Assembly Bill 1647.
While we share your desire to explore viable .green waste management enhancement
.opportunities we must also consider the feasibility of such options and -their relative
impact on the operational and economic structures currently in place. Accordingly, it is
requested that your Board include this Task Force in further stakeholder discussions to
Ms.-Margo Reid Brown
August 21, 2008
Page 3
a much greater contributive extent in order to develop a .more comprehensive set ofi
alternative green waste. management options.
We would appreciate .your written response which .would be of great interest to
jurisdictions in Los Angeles County as well as those throughout the- State. If you have
any questions, please contact Mr. Mike Mohajer of the Task Force at (909) 592-1147.
Sincerely,
Margaret Clark, Vice-Chair
Los Angeles County Solid Waste Management Committee/
Integrated Waste Management Task Force and
Council Member, City of Rosemead.
EKT:my
P:1SECIADC aptions.doc
cc: Governor Arnold Schwarzenegger
CaI:EPA Secretary, Linda Adams`
Each Member of the California Integrated Waste Management Board
California Integrated Waste Management. Board (Mark Leary, Ted Rauh;
Bobbie Garcia)
California State Association. of Counties
-The League of California Cities
The League of California Cities., Los Angeles County Division-
Each Member of the County of Los Angeles' Board of Supervisors
Each City Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
~ pF rER
w ~o~~y ~O
4•
~r4a~4ELY 1NOVg~e IU f ROVLV ~AY ~ ~ 9V! 1 ~V~~\~'C
6wrT~ .rt K`~ IBUT N
STAFF REPORT _
HEALTH & ENVIRONMENTAL CONTROL DEP R~TME~IT,
DATE: Apri127, 2009
TO: Mayor and City Council APR 2 9 2009
FROM: Lewis Pozzebon, Director /Health Officer CIS CLERKS OFFICE
RE: Request for Approval of Letter Supporting Comments by Los
Angeles County Solid Waste Management Committee on Interim
Report for Life Cycle Assessment of Organics Diversion Alternatives
The Los Angeles County Solid Waste Management Committee (Committee) has asked
for the City of Vernon's support of comments the Committee has developed (attached)
for submission to the California Integrated Waste Management Board (Waste Board)
regarding an Interim Report for Life Cycle Assessment of Organics Diversion
Alternatives, which is ,entitled "Facilities Data Collection Approach and Results for the
Life .Cycle Assessment and Economic Analysis of Organic Waste Management and
Greenhouse Gas Reduction Options," dated March 27, 2009.
The primary concern in the Interim Report is the determination that greenwaste
Alternative Daily Cover does not qualify as a legal -and viable diversion alternative.
There are significant benefits of greenwaste being utilized. as an Alternative .Daily Cover
material at landfills including:.- reducing landfill .operating costs, conserving landfill
capacity, and providing an environmentally sound diversion option. An additional
concern for the City of Vernon is That the City receives diversion credit for AB 939
compliance for the greenwaste being utilized as Alternative Daily Cover material.
Based on my review of the Committee's comment. letter, I concur with the Committee's
evaluation of the Interim Report and I recommend that the City Council authorize the
issuance of a letter of support (draft attached).
Attachments: Los Angeles County Solid Waste Management Committee Letter, April 20,
2009, with enclosure
Draft Support letter
Cc: Eric Fresch, City Administrator
Jeff Harrison, City Attorney
-F ~ ~ ~
~~~~~r
( ti o~ ~ ~
~ ~ ~ 11 a.~a,~
~ ~ .1; ~
~~;5
1 SI V}lY 1N~~-~
4305 Santa Fe Avenue, Vernon, California 90058
Telephone (323) 583-8811
DRAFT
Apri128, 2009
Ms. Margo Reid Brown, Chair
California Integrated Waste Management-Board
1001 I Street
Sacramento, CA 95812-2815
Support of Comments Regarding Interim Report. for Life Cycle Assessment of Organics
Diversion Alternatives
Dear Ms. Brown:
The City of Vernon appreciates the opportunity to provide input on the developmentof solid
waste decision making and policies. Please- note that the City is in support of the comments
developed by the Los Angeles County Solid Waste Management Committee in regards to the
California Integrated Waste Management Board's interim report for the Life Cycle Assessment
of Organics Diversion Alternatives. A copy of the Los Angeles County Solid Waste Committee
comment letter is attached for reference.
Thank you for your consideration. If you have any questions, please contact Lewis Pozzebon,
Director of Health and Environmental Control at (323) 583-8811 Ext. 229.
Sincerely,
Hilario Gonzales
Mayor
Attachment
Xc: Anthony Gonsalves
E.~cCusiveCy IndustriaC
LOS ANGELES COUNTY
SOLID WASTE MANAGEMENT COMMITTEE/
INTEGRATED WASTE MANAGEMENT TASK FORCE
900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacou ntyiswmtf.org
GAIL FARBER
CHAIR
April 20, 2009
Ms. Margo Reid Brown, Chair
California Integrated Waste Management Board
1001 I Street
Sacramento, CA 95812-2815
Dear Ms. Brown:
COMMENTS REGARDING INTERIM REPORT FOR LIFE CYCLE ASSESSMENT OF
ORGANICS DIVERSION ALTERNATIVES
On behalf of the Los Angeles .County Solid Waste Management. Committee/
Integrated Waste .Management Task Force, I want to thank the California :Integrated
Waste Management Board (Waste Board) for the opportunity to comment on the interim.
report for the Life Cycle.. Assessment of Organics .Diversion Alternatives, entitled
"Facilities Oata Collection Approach and Results for the Life Cycle Assessment and
Economic Analysis of Organic Waste Management and .Greenhouse Gas Reduction
Options," dated March 27, 2009.
Pursuant to Chapter 3.67 of the Los Angeles County Code and the California Integrated
Waste Management Act of 1989 (AB .939, as amended), the Task. Force is responsible
for coordinating the development. of all major solid waste planning documents prepared
for the County of Los Angeles and the 88 cities within with a combined population in
excess of ten. million. Consistent with these responsibilities, and to ensure a
coordinated and cost-effective and environmentally sound solid waste management
system in Los Angeles County, the Task Force also addresses issues impacting the
system on a Countywide basis. The Task Force membership includes representatives
of the League of California Cities-Los Angeles County Division, the County of
Los Angeles Board of Supervisors, the City of Los Angeles, the vvaste management
industry,. environmental groups, the public, and a number of other governmental
agencies...
Ms. Margo Reid Brown
ApriF 20, 2009
Page 2
We have reviewed the interim report and offer the following comments/concerns.
1. Greenwaste Alternative Daily Cover
The study is fundamentally flawed in .dismissing the use of greenwaste
Alternative Daily Cover (ADC) as a legal and viable diversion alternative
and equating it with disposal. Assembly Bill 1647 (Bustamante, 1996)
made a distinction between greenwaste used as ADC and that of disposal:
and recognized the significant benefits of greenwaste ADC in reducing
operating costs, conserving. landfill. capacity, and providing an
environmentally sound diversion option. In fact, the preliminary findings of
a study currently being conducted by the Center for the Study of
Sustainable Use of Resources at Columbia University indicates that
windrow .composting. has higher .adverse effects in comparison to
greenwaste ADC (copy enclosed).
It's imperative that greenwaste ADC remains a legal and viable diversion
.alternative since it's among the highest environmentally sound option. It
promotes a healthy and diverse solid waste infrastructure to manage the
sheer volume of greenwaste generated and prevents the State from
.becoming over dependent on a few arbitrarily. chosen options. This
diversity allows the marketplace to remain cost competitive, limits risks
due. to fluctuation in the marketplace, and `promotes a progressive
marketplace.
In addition, to enable decision makers to make informed' decisions
regarding organic waste management and evaluate the true costs of
,various options, the interim `report should be expanded to include the
environmental artd economic consequences of eliminating the use of
greenwaste ADC as a viable diversion alternative, such as, but not limited
to:
• Increasing soil mining for use as ADC; ,
• Decreasing .the decomposition rate of the solid waste disposed in
the landfill;
• Transportation impacts. (e.g., increased traffic congestion,- air.
pollution, and greenhouse -gas emission) as a result of transporting
greenwaste to out-of region composting facilities; and,
Ms. Margo Reid Brown
Apri120, 2009
Page 3
• Transportation impacts (e.g., increased traffic :congestion, air
pollution, and greenhouse gas emission) as a result of transporting
the compost material to end users.
The above impacts must be evaluated since they are acute. to Southern
California where greenwaste ADC has been a vital diversion alternative
due to inadequate. processing capacity for greenwaste and a limited
market for compost.
2. Emerging Technologies as a Diversion Alternative
The interim report limits its scope of technologies to anaerobic digestion,
biomass-to-energy, and waste-to-energy. As indicated in RTI
International's February 2, 2009, presentation, one goal is to "develop
transparent, consistent, and objective data to characterize alternatives on
an equal basis". If that is the. case, then all technologies, including the
broad- range: of conversion technologies, must be considered on a level
playing field.. Therefore, the interim report-must be expanded to recognize
the findings of:
• The Waste Board's own three-year study on conversion
technologies conducted pursuant to AB 2770, Chapter 740 of the
2002 State Statutes;
• The conversion technology efforts by the County of .Los Angeles
(www.SoCalConversion.org};
• The State Bioenergy Action Plan; and,
• The State Interagency Bioenergy Working Group.
Selectively choosing technologies limits progress and development of
"green" technologies in California and is in direct contrast to many of the
State's progressive environmental and energy goals and the State's goal
to create highly skilled jobs.
3. Greater Sampling Population
The number of facilities surveyed is too small to .provide meaningful and
representative data for the study. For .example, of the 155 landfills,
185 chipping/grinding facilities, and 50 composting facilities in California,
only 23, 6, and 16 facilities, respectively, were selected as survey
candidates.- Of this limited pool of potential participants, only a handful of
Ms. Margo Reid Brown
April 20, 2009
Page 4
facilities responded to the survey. In order for the interim report to provide
accurate greenhouse gas emission data and cost savings, if any, from the
data collected, the sampling effort must be carefully reevaluated to
determine whether this very small sample size will yield statistically
accurate data.
The Task Force appreciates your consideration and .respectfully requests a written
response to this letter as well as the August 21, 2008, and December .8,,.2008, letters
(copies enclosed) regarding the same subject as expeditiously as possible. If you have
any questions,- please contact Mr. Mike Mohajer of the Task Force at (909) 592-1147.
Sincerely,
y~~%G~.~~
Margaret Clark, Vice-Chair
Los Angeles County Solid Waste Management Committee/
Integrated Waste Management Task Force -and
Mayor, City of .Rosemead
LL: cw
P:\Sec\Taskforcelorganics LCA
Enc.
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda Adams
Each Member of the California'Integrated Waste Management Board
California Lntegrated Waste Management Board (Mark Leary, Ted Rauh,
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The .League of California Cities, Los Angeles County Division
Each Member of the County of Los Angeles' Board of Supervisors
Each City Mayor in Los Angeles. County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments.
Southern California Association of Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
Interim Progress Report of Center for Sustainable Use of Resources (SUR),
Earth Engineering Center of Columbia University
SUR Project Title: Comparison of Use of Green. Wastes as Alternative Daily
Cover in Regulation Landfills and by Composting in Open Windrows and In-
vessel Systems
Report by 1v.J. Themelis; LCA study by Rob van Haaren; co-PI: Morton Barlaz
Summary of results to date -March 23, 2009
This study is part of a SUR project to identify the best available technology for
processing green wastes. It consists of two parts: an in-depth study of the tonnages. of
green wastes processed by various aerobic composting methods and amulti-criteria
analysis -(MCA) to identify the best of these methods; and a comparison of the
environmental- impacts of using green wastes as feedstock for aerobic composting or as
Alternative Daily Cover (ADC) in regulation landfills.
The BioCycle-Columbia study of 2 006 data showed that 22.7 million tons of the
organic fraction of MSW in the ll.S. were composted or mulched, that is about 5.5°/d
of the total MSW generated.-This number is 1.7 million tons greater than the 2004
estimate. The tonnages processed by various aerobic composting methods
(windrow, static aerated pile, in-vessel) were not documented in the BioCycle
survey. However, it is known that the dominant, and least costly, method is windrow
composting. Also; there is insufficient data on the tonnage of food wastes processed
but EPA has estimated that only 0.7 million tons of food wastes were composted in
2006. Including the food fraction in the feedstock to the composting process is
beneficial for the subsequent use of the compost product, because of its high
nutrient content. However it is not recommended for open air windrow composting
because of undesirable odors.
The MCA study of SUR consists of assessing environmental impacts, investment and
operating costs. and associated effects, such as odors and use of land; in order to
determine the best available aerobic composting technology. The .environmental
impact assessment is carried out by means of a Lifecycle Analysis (LCA) using the
Eco-indicators-99 methodology of the SimaPro software that was developed in the
E.U. by Pre Consultants and is used widely in Europe and the U.S. This program is
described in detail at www.pre.nl/simapro.html.
The inventory of emissions needed to carry out the LCA study was developed by
combining life-cycle inventories from published papers and emission studies for
1
windrow composting and also for regulation landfills. However, the dataset for air
and water emissions of the Gore-technology (aerated. static pile) has not been
completed as yet. The Gore-Tex technology is less costly than in-vessel composting
and is increasingly being used in U.S. composting facilities.
The chart of Figure 1 below shows the results of the environmental impact
assessment of three green-waste. composting methods: Windrow Composting (WC),
Alternative Daily. Cover (ADC) and In-vessel aerobic Page: 2
composting (INV). The horizontal zero-line on the y-axis denotes that bars above
this line represent adverse effects on the environment and bars below beneficial
effects. The units on-the y-axis of the SimaPro graph are called "ecopoints". The
Ecopoint score is a measure of the overall environmental impact of a particular
product or process. Very roughly, the total environmental impact by all
anthropogenic activities in the E.U., divided by the E.U. population, is considered to
be equal to 100 Ecopoints per person.
Originally, this system was developed for assisting the Swiss government to compare the
total effect of different types of environmental impacts. For example, starting from the
top of the left bar on Figure 1, the dark blue bar denotes acidification and eutrophication
effects, the light blue bar climate change, the yellow respiratory effects, and the light
brown bar avoided use of fossil fuels. In order to compare effects in different categories,
weighing factors are used which maybe somewhat subjective. For example, the release
of 1 kg of NO3 (eutrophication) in water may be comparable to the release of S kg of
CO2 into the atmosphere (climate change). However, the most important use of these
graphs is the comparison of the effects between each method. For example, acidification
is 8 times- more severe in windrow composting as in in-vessel aerobic composting
because in the latter the composting gases are captured and cleaned in biofilter systems.
2
w
~ I ry' ~ _ ~m a,.._ ~
E
F
F
_ _ -
.
1..:::1 - .
Figure 1. Comparison of environmental impacts of windrow composting, ADC use in
regulation landfills, and in-vessel composting of green wastes. The functional unit for
the LCA comparison is one ton of green wastes.
It can be seen from Figure 1 that, according to the LCA, windrow composting
method has higher adverse effects than use of green wastes as Alternative Daily, '
Cover (ADC). The principal reason for the beneficial effect of using green wastes as
ADC is that one ton of shredded yard wastes. replaces nearly six tons of soilthat,
according to EPA regulations for sanitary landfills, must. be used as daily cover on
the surface of a working cell. The regulation requires a 15-cm (six-inch) daily cover
of soil. Several California landfills use a 23-cm (9-inch) ADC cover of yard wastes ip
place of soil.
It is evident that much less effort, and use of motorized equipment, is needed to
shred and spread one ton of green wastes than by digging up and spreading six tons
of soil. The use of green wastes ADC has the additional advantage that it increases
the capacity of a landfill cell because the nine inches of shredded green waste cover
per day are eventually compacted into less than one inch, while there is relatively
little compaction of the six inches of soil that must be used daily, as per EPA
3
regulation. Therefore, the use of green wastes ADC results in saving of landfill space
and,. consequently, land used for landfilling.
A beneficial factor for both windrow and in-vessel composting is that the compost
product can be used as aloes-quality fertilizer. This studyestimated that one metric
ton of green wastes replaces 16 kg of N-Fertilizer, 2.4 kg ofP-Fertilizer and 6.4 of K-
Fertilizer, both in windrow composting and in-vessel aerobic composting .The
principal advantage of in-vessel over windrow composting is th"at the latter is not fully
aerobic: Parts of the composting material within the core of the pile reacts anaerobically
emitting a gas similar to landfill gas but at a much lower quantity. This gas is not
captured and therefore results. in high ratings in the acidification/eutrophication, climate
change, and respiratory ailments categories.
The ADC scenario-was based on astate-of-the-art sanitary landfill that collects
leachate from the MSW and captures landfill gas within five years after starting a
landfill ce1L Therefore, no water emissions were included in this scenario. The fossil
fuel benefit results from the avoided soil excavation and from LFG collection. Green
wastes are used instead of soil as daily cover of the landfill. An estimated 82%
fraction of the methane generated in such a cell is collected by the LFG recovery
system and is used in a gas engine to generate electricity (thus avoiding the use of
fossil fuels).
In the in-vessel composting scenario, the energy used to compost and cure one ton
of green waste is lower than the avoided use of energy for producing an equivalent
amount of fertilizers. Therefore, the overall effect is positive for the environment, in
terms of net fossil fuel use.
It is expected that the MCA and LCA studies of SUR will be completed by May 2009.
NJT, March 24, 2009.
4
LOS ANGELES COUNTY
SOLID WASTE MANAGEMENT COMMITTEE]
INTEGRATED WASTE MANAGEMENT TASK FORCE
900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX.1460, ALHAMBRA, CALIFORNIA 91802-1460
wwwaacou ntyiswmtf. org
GAIL FARBER
CHAIRPERSON
December 8, 2008
Ms. Margo. Reid Brown, Chair-
. .California Integrated Waste Management Board
1001 I Street
Sacramento,. CA 95812-2815
Dear Ms. Brown:
DISCUSSION OF ORGANICS POLICY ROADMAPS I AND II
CALIFORNIA INTEGRATED WASTE MANAGEMENT BOARD MEETING
AGENDA ITEM 8, DECEMBER 16, 2008
On behalf of the Los Angeles County Solid Waste Management Committee/Integrated
Waste Management Task Force, we respectfully request the California. Integrated
Waste Management Board (Waste Board) respond to our August 13 and 21, 2008
letters. (copies. enclosed) expressing significant concerns regarding the. Waste Board®
direction to rely primarily on composting to reduce organics in the waste stream (50?
by 2020), rather than adopting a diversified and pragmatic- strategy.. By adopting
strategies in addition to composting (which has-significant shortcomings including siting
difficulties; the need for- large acreage of .land; odor, air quality/greenhouse gas
emission,-and water quality concerns; lack of markets for end products due to product
inconsistencies; and permitting/regulatory hurdles), California® -solid waste
infrastructure would be better insulated. from shifting and often uncontrolled factors such
as those. relating to global markets.
Pursuant to Chapter 3.67 of the Los Angeles County Code and. the California Integrated
Waste Management Act of 1989 (AB 939, as amended), the Task Force is responsible
for coordinating the development of all major solid waste planning documents prepared
for the County of Los Angeles and the 88 cities within Los Angeles County with a
combined population in excess of 10 million. Consistent with these responsibilities, and
to ensure a .coordinated and cost-effective and environmentally-sound solid waste
management system in Los .Angeles County, the Task -Force also addresses issues
impacting the system on a countywide basis. The Task Force membership. includes
representatives of the .League of California Cities-Los Angeles County Division, the
County of Los Angeles Board of Supervisors, .the City of Los Angeles, the.` waste
Ms. Margo Reid Brown
December 8, 2008
Page 2
management .industry, environmental groups, the public, and a number of other
governmental agencies.
On December 9, 2008, the Waste Board® Strategic Policy Development Committee will
be discussing Agenda Item C (Waste Board Item 8), Organics Policy Roadmaps I and
II. According to the staff report, the Waste Board will be continuing its discussions from
June-2008. Based on our review of the staff report, we were disheartened to learn that
our comments expressed in letters dated August 13 and 21, 2008 were not addressed,
let alone .responded to. As detailed in these letters, the Task. Force requests-the Waste
Board to:
1. Define the terms "Organic" and "Compostable Organic" since they are not
defined by statute, regulation or the Waste Board Strategic Directive 6.1.
Defining these terms is critical to the overall conversation especially since there
is wide disagreement .within the. Waste Board itself on what these terms mean.
For example, the staff report for this Item indicates organics account for 23
million tons of the disposal waste stream (approximately 55?) while the. June 17,
2008 (Item 10) staff report states [organic materials comprise over 30? of the
waste stream .deposited in California landfills.?Further, based on the Statewide
Waste Characterization Study released by the Waste Board in December 2004,
the "organic" fraction of solid waste. disposed in California landfills ranges
between 70 and 80 percent. Therefore, clear and distinct definitions are .needed.
to avoid confusion among the .legislature and regulatory bodies, regulated
communities, and local governments which ultimately bear the cost of meeting
fhe 50? organic. reduction goal by 2020 as stipulated by the Waste Board
Strategic Directive, 6.1.
Furthermore, it is also very important that the Waste Board identify which organic
waste stream category it is targeting for reduction. Based on the Waste Board
December 11, 2007, Agenda Item 15, it appears that the goal is focused on
composting/diverting source separated streams, such as green. waste, food
waste, manure, etc., and not the total. "organics" currently being disposed. of in
landfills. If the latter is true, jurisdictions.. in California may be faced with achieving
a mandatory [back doorCdiversion rate of approximately 85 percent by 2020.
2. Consider the findings of State and local efforts confirming that conversion
.technologies ([green?high tech technologies utilized in Europe and Japan
which convert post-recycled solid waste into renewable energy, useful
products, and. green fuels) are capable of managing organic material in an
environmentally sustainable manner. According to the Waste Board[ own
Ms. Margo Reid Brown
December 8, 2008
.Page 3
.three-year study on conversion technologies (prepared at the request of the
Legislature, Assembly Bill 2770, 2002 Statutes) and numerous other parallel
studies, conversion technologies have been demonstrated to have .numerous
tangible benefits, .including. reducing greenhouse gas emissions, waste
.transportation, and landfill disposal; displacing fossil fuels by producing fuel,
energy, and -other .products; and,. creating green-collar jobs... By .including
conversion technologies in the [tool boxC,7 it will help ensure the attainment. of the
desired. organic reduction goal. Otherwise, the Waste Board will continue to be
focused on Croft?solutions such as forming more committees and conducting
unnecessary duplicative studies and .solely emphasizing afavored-technology.
Such a direction is not consistent with Governor Schwarzenegger~
statement/position that mourning waste products into energy is good for the
state® economy, local job creation, and our environment. By implementing
biomass programs in California, we .will help fight critical waste-disposal and
environmental problems, including the risk of wildfires, air pollution from open
field burning, and greenhouse gas emission from landfills.?
3. Work closely with local jurisdictions in formulating State policy to reduce
green waste alternative daily cover (ADC). The use of greenwaste as ADC
has. numerous environmental and economic benefits, including:. preventing the
mining and wasting of clean soil that would have otherwise been used as daily
cover; conserving landfill capacity, by avoiding an additional cover material layer
and the ability of green waste to compact and decompose over time; creating
markets for the beneficial use of green waste; maintaining a local outlet for the
beneficial use of greenwaste; and strengthening the curbside .collection
infrastructure for greenwaste. These benefits are especially important in
Southern California since. there is inadequate processing capacity for green.
waste and a limited market for compost made from greenwaste due to difficulties
encountered in permitting/developing these types of facilities. This is particularly
acute in urban areas due to lack of suitable. land, .stringent air quality regulations,
and community reluctance towards the proximity of such facilities. Even if ,such
facilities were developed elsewhere, greenwas e would .still need to be
transported over long distances, leading to higher trash rates and added traffic
congestion and air pollution.
Although the formulation of State policy to reduce green waste .ADC would
significantly impact cities and counties, to date; the Waste Board -has largely
ignored seeking,. input from them. For example, the ADC :Policy Workgroup
convened by the Waste Board earlier this year to formulate ADC
recommendations to the Waste Board was comprised of selected members from
Ms. Margo Reid Brown
December 8, 2008
Page 4
the private sector and environmental interest groups with virtually no local
government representation. -Thus, it is .imperative that the Waste .Board be
inclusive in its solicitation for input rather than !~elective~nput.
Due to the. gravity of the concerns expressed, we respectfully request a written
response to this letter as well as the August 13 and 21, 2008 letters as expeditiously as
possible. If you have any questions, please .contact Mr. Mike Mohajer of the Task Force
at (909) -592-1147.
Sincerely,
Margaret Clark, Vice-Chair
Los Angeles County Solid Waste Management Committee/
Integrated Waste Management Task Force and
Council Member, City. of Rosemead
LL:
P:\eppub\ENGPLAN1Linda\Regs\Organics Policy Roadmaps I and Il.doc
Enc.
cc' Governor Arnold Schwar`zenegger
CaI EPA Secretary, Linda Adams
Each Member of the California Integrated Waste Management Board
California Integrated Waste Management Board (Mark Leary, Ted Rauh,
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The League of California Cities, Los Angeles County Division
Each Member of the County. of Los AngelesCBoard of Supervisors
Each City Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
LOS ANGELES COUNTY
_ SOLID WASTE MANAGEMENT COMMITTEE='
~ INTEGRATED WASTE MANAGEMENT TASK FORCE
900-SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacountyiswmtf.org
DEAN D. EFSTATHIOU
CHAIRMAN
August 13; 2008
Ms. Margo Reid Brown, Chair
California. Integrated Waste Management Board
1001. I Street
Sacramento, CA 95812-2815
Dear Ms. Brown:
DISCUSSION OF POTENTIAL OPTIONS FOR THE ORGANIC DIVERSION FACILITIES
SITING PROJECT (STRATEGIC DIRECTIVE 6.1)
On behalf of the Los Angeles County Solid Waste Management Committee/Integrated
Waste Management Task Force, 1 would like to commend the California Integrated Waste
Management Board (Waste Board) for its efforts in promoting environmentally beneficial
alternatives to reduce. the disposal of organics. However, as listed- below, we .have a
number of concerns regarding the Waste Board[ Directive 6.4 and its staff report for
Item 11 of the June 17, 2008, Waste Board meeting. On June 10, 2008, this item was
considered by the Waste Boards Strategic Policy Development Committee without
addressing concerns expressed by stakeholders.
Pursuant. to Chapter 3.67 of the Los Angeles County Code and the California Integrated
Waste Management Act of 1989 (AB 939, as amended), the Task Force is responsible for
coordinating the development of all major solid waste planning documents prepared for the
County of Los Angeles and the 88 cities within Los Angeles County with a combined
population in excess of ten million. Consistent with these responsibilities, and to ensure a
coordinated and cost-effective and environmentally-sound .solid waste management system
in Los Angeles County, the. Task Force also addresses issues impacting the system on a
countywide basis. The Task Force membership includes representatives of the League of
California Cities-Los- Angeles County Division; the County of Los Angeles Board of
Supervisors, the City of Los Angeles, the waste management industry, environmental
groups, the public, and a number of other governmental agencies.
We would like to offer the following. comments/concerns regarding your .staff report on
options for siting of organic diversion facilities as well as the Waste Board Strategic
Directive 6.1.
Ms. Margo .Reid Brown
August 13, 2008
Page 2
1, The Waste Board needs to define the #erms "Organic" and
"compostable Organic"
The term "organic" is not defined by statute or regulation. Webster~s Dictionary defines
the term ''organic" as: "of, relating to, or derived from living organisms" and "of, relating
to, or containing carbon compounds." As such, based on the. Statewide Waste
Characterization Study released by the Waste Board in December 2004,. the "organic"
.fraction of solid waste disposed in California landfills ranges between 70 and 80 percent.
The June 17, 2008, Waste Board staff report. states that "Organic materials comprise
over 30 percent of the waste stream disposed in California landfills." This, statement is
inconsistent with the Waste. Boards 2004 Statewide Waste Characterization Study as
well as .the staff report that was presented: to the Waste Board on December 11, 2007.
In that report; staff indicated that "compostable organic materials comprises
approximately 25 percent, or about- 10 million tons, of what is disposed in landfills
annually, and paper and woody portion of Construction & Demolition debris constitute
another 13 or so million tons." Thus, it appears that Waste Board staff made a.
distinction between the terms "organic" and "compostable organic,",.but did not make an
attempt to define the terms.
The terms "organic" and "compostable organic" materials need. to be clearly ..defined to
avoid confusion among the legislature and regulatory bodies, regulated .communities,
and. local governments that ultimately have to bear the cost. Furthermore, there is a
need for the. Waste- Board to reexamine its Strategic Directive 6.1,.which .calls for 50
percent reduction. in the amount of "organics" being disposed in landfills by 2020. Based
on the December 11, 2007, Agenda Item 15, it appears that the goal is focused on the
composting/diverting of source separated streams, such as green waste, food waste,
manure, etc.; and not the total "organics" currently being disposed in landfills.. If the
latter is true, jurisdictions- in California ,may be faced with achieving a mandatory
diversion rate of approximately 85 percent by 2020.
2. The -Waste -Board needs to consider the .findings of State and local
efforts with regards to conversion technology
The June 17, 2008, Waste Board staff report .indicates "Organic diversion facilities
include compost; conversion technology, chipping and grinding, and transfer stations.."
The Task .Force commends the Waste Board for .its recognition and inclusion of
conversion technology into the organic diversion facilities category. However; we are
disappointed -with the Waste Boards staff report and recommendations which fail to
recognize the findings of (a) the Waste. Boards own three-year study on conversion
technologies conducted pursuant to AB 2770,. Chapter 740 of the 2002 State Statutes;
LOS ANGELES COUNTY
SOLID WASTE MANAGEMENT COMMITTEE/
INTEGRATED WASTE MANAGEMENT TASK FORCE
900 SOUTH FREMONT AVENUE, ALHAMBRA, CALIFORNIA 91803-1331
P.O. BOX 1460, ALHAMBRA, CALIFORNIA 91802-1460
www.lacountyiswmtf.org
DEAN D. EFSTATHIOU
CHAIRMAN
August 21, 2008
Ms. Margo Reid Brown, Chair
California.Integrated Waste Management Board
1001 I Street
Sacramento, CA 95812-2815
Dear Ms. Brown:
POLICY OPTIONS TO .REDUCE GREEN MATERIAL ALTERNATIVE DAILY COVER
On behalf of the Los Angeles County Solid Waste Management- Committee/Integrated
Waste Management Task- Force (Task Force), I respectfully request the California
Integrated Waste Management Board (Waste Board) to work with local governments in
formulating State policy to reduce green waste alternative daily cover (ADC) since such
policies will significantly impact their ability to comply with the State's 50 percent waste
reduction mandate and result in other unintended environmental consequences. These
options .(Item 10 of the June 17, 2008, Waste Board Agenda), were considered by the
Waste Board's Strategic Policy Development Committee at its June 10, 2008,_ meeting.
These- options :included phasing out green waste ADC diversion credit, applying
disposal and tipping fees on ADC, using generated revenues from these fees to
promote development of composting facilities, as well as possible mandates on local
jurisdictions to develop and adopt a 15-year composting capacity element similar to the
existing Assembly Bill 939 mandated Siting. Element. Unfortunately, these options were
developed with virtually no input from cities and counties.
Pursuant to Chapter. 3.67 of the Los Angeles County Code and the California Integrated
Waste Management Act of 1989 (AB 939, as amended), the Task Force is responsible
for coordinating the development of all major solid waste planning, documents prepared
for the County of Los Angeles and the 88 cities in Los Angeles County with a combined.
population in excess of ten million. Consistent with these responsibilities, and to ensure
a coordinated and cost-effective and environmentally-sound solid.. waste management
system in Los Angeles County, the. Task Force also addresses issues impacting the
system on a County-wide basis. The Task Force membership includes representatives
of the League of California Cities-Los Angeles County Division, the County of
Los Angeles Board of Supervisors,- the City of Los Angeles, the waste management
industry, environmental groups, the public, anal a number of other governmental
agencies.
Ms. Margo Reid Brown.
August 13, 2008
Page 3
(b) the conversion technology efforts by the County of Los Angeles; (c) the State
Bioenergy Action Plan; and (d) the State Interagency: Bioenergy Working Group..
Unfortunately,. these findings were not considered by the Strategic Policy Development
Committee on June 10, 2008. We strongly believe that the Waste Board needs to
consider these studies and efforts prior to any further action. This reevaluation will
further substantiate that the .Waste Board -must place a greater reliance on the
development and siting of conversion technology facilities rather. than focusing on "soft"
solutions such 'as forming more committees and conducting unnecessary duplicative
studies.
We would appreciate your written response which would be of great interest to jurisdictions.
in Los Angeles County as well. as those throughout the State. If you have any questions,
please contact Mr. Mike Mohajer of the TasIC Force. at (909) 592-1147.
Sincerely,
j-,
Margaret Clark, Vice-Chair
Los Angeles County Solid Waste Management Committee/
Integrated Waste Management Task Force and
Council Member, City of Rosemead
LL:kp
P:\SEC\Organics Facilities Letter.doc
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda Adams
Each Member of the California Integrated Waste Management Board.
California Integrated Waste Management Board (Mark Leary, Ted Rauh,
Bobbie Garcia)
California State Association of Counties
The League of California Cities
The- League of California Cities, Los Angeles County Division
Each Member of the County of Los AngelesCBoard of Supervisors
Each City. Mayor in Los Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of Governments
Each City Recycling Coordinator in Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force
Ms. Margo Reid Brown
August 21, 2008
Page 2
-Thee use of greenwaste as ADC has numerous environmental and economic benefits,
including: preventing the mining and wasting of clean soil that would have otherwise
been used as daily .cover; conserving landfill capacity, by avoiding an additional cover
material layer and the ability of -green waste to compact and decompose over time;
creating markets for the beneficial use of green waste; maintaining a local outlet for the
beneficial use of greenwaste; and, strengthening the curbside collection infrastructure
for greenwaste. These benefits are especially important in Southern. California since
there is inadequate processing capacity for green waste and a limited market for
compost made from greenwaste due to difficulties encountered in permitting/developing
these types of facilities. This is particularly acute in urban areas due to lack of suitable
land, stringent air quality regulations, and community reluctance towards the proximity
of such facilities. Even if such facilities were developed elsewhere, greenwaste would
still need to be transported over long distances; leading to higher trash rates and added
traffic congestion and air pollution.
Because of these significant benefits, in .1996 the Legislature passed Assembly Bill
1647 (Bustamante) to provide unrestricted. diversion credit to green waste used as ADC,
.making a distinction from greenwaste disposed in the landfill. Due to this. diversion
credit, and because of the benefits listed above, jurisdictions and private industry
invested millions of dollars in expensive equipment and infrastructure to implement
greenwaste collection and recycling programs which provide for the separate collection
of green. waste to be-used as ADC.. Jurisdictions in Southern California and. other parts
of -the. state now rely on this infrastructure to manage green waste to maintain
compliance with the State's 50 percent waste reduction mandate.
It is for. the above reasons. that the Task Force requests the Waste Board to .work
closely with cities, counties and other impacted communities in formulating State policy
to reduce green waste ADC, especially those that will be significantly impacted by such
policies. Further, while we are supportive of composting, shifting green waste away
from ADC towards composting facilities will also result in increased trash rates, air
pollution, and traffic congestion in Southern California. The Task Force also has strong
reservations regarding the proposal to eliminate ADC diversion credit `and thus
mandating additional diversion mandates on local jurisdictions without considering the
critical. resources necessary to successfully meet them. Therefore, we respectfully
request the .Waste Board redirect its efforts to place a greater emphasis on diverting
green materials currently being disposed rather than consuming resources on
investigating ways to decrease the beneficial use of green waste as ADC as legitimized
by Assembly Bill 1647.
While. we share your desire to explore viable green waste managemenf enhancement
opportunities we .must also consider the feasibility of such options and their relative
impact on the operational and economic structures currently in place. Accordingly, it is
requested that your Board include this Task Force in further stakeholder discussions to
Ms.-Margo Reid Brown
August 21, 2008
Page 3
a much greater contributive extent in order to develop a more comprehensive set of
alternative green waste. management options.
We would appreciate your written response which would be of great interest to
jurisdictions in Los Angeles County as well as those throughout the State. If you have
any questions, please contact Mr. Mike Mohajer of the Task Force at (909).592-11.47.
Sincerely;
Margaret Clark, Vice-Chair
Los Angeles County Solid Waste Management Committee/
Integrated Waste Management Task Force and
- Council Member, City of Rosemead
EKT:my
P:\SECh4DC options.doc
cc: Governor Arnold Schwarzenegger
Cal EPA Secretary, Linda Adams
Each Member of the California Integrated Waste Management Board
California Integrated Waste Management Board (Mark Leary; Ted Rauh;
Bobbie Garcia)
California State Association. of Counties
The League of California Cities
The ..League of California Cities, Los Angeles County Division
Each Member of the County of Los Angeles' Board of Supervisors
-Each City Mayor in Los. Angeles County
South Bay Cities Counsel of Governments
San Gabriel Valley Counsel of Governments
Gateway Cities Counsel of Governments
Southern California Association of Governments
Each City Recycling .Coordinator in .Los Angeles County
Each Member of the Los Angeles County Integrated Waste Management Task Force