July 30, 2012
Via e-mail: publicmeetings@calrecycle.ca.gov
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street--P.O. Box 4025
Sacramento, CA 95812-4025
Re: July 17, 2012 CalRecycle Monthly Public Meeting, Section J, Item #2: CalRecycle Landfill Data
Summary: Part 2. Landfill Methane Avoided Emissions and the July 3, 2012 report: “CalRecycle
Review of Waste-to-Energy and Avoided Landfill Methane Emissions”
To Whom It May Concern:
[YOUR COMPANY] commends CalRecycle for re-examining the quantification of landfill methane
emissions. CalRecycle’s report represents one of the first reports out of a government agency that
presents a defensible calculation of the greenhouse gas benefits which result from using wastes in
anaerobic digesters, compost operations and waste-to-energy systems instead of landfills.
From our view, the most important outcome from the July 17, 2012 Public Meeting was CalRecycle’s
acknowledgement that methane emissions from a landfill should be quantified on a lifecycle basis and
not just a snapshot in time. As a result, this acknowledgement will allow many waste-to-energy
technologies, like anaerobic digestion, to compete more fairly with regard to their significant methane
destruction capabilities compared to landfills. Anaerobic digestion systems capture methane from
cradle to grave. In contrast, landfills do not install collection systems immediately, nor does collection
continue indefinitely. Historically, the perpetual misapplication of default collection efficiency values
has made this contrast less apparent and led to consistent under-reporting of methane emissions by
landfills. We commend CalRecycle for opening the door to more accurate ways of quantifying landfill
methane emissions. This will allow alternative waste-to-energy technologies to more realistically show
their enhanced methane recovery/destruction attributes, which we hope will:
Boost clean energy business growth in California;
Reduce methane emissions overall
Offer more opportunities to convert organic waste into valuable products like: electricity,
renewable natural gas and environmentally-friendly fertilizers
As California continues to define policies and make tough financial choices, CalRecycle’s work comes at a
very opportune time. Anaerobic digestion and composting are important components of a sustainable
waste management strategy and will be an important component of meeting California’s targets for
recycling and handling organic waste. The Report provides critical data for evaluation of policy
alternatives and assessing the costs and benefits of each option, ensuring that the most beneficial
measures are provided an unfettered path to market and appropriate support.