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CA Study of "Conversion Technologies"
- Subject: CA Study of "Conversion Technologies"
- From: Gary Liss <firstname.lastname@example.org>
- Date: Tue, 19 Aug 2003 12:53:56 -0700
- Delivered-To: email@example.com
- Delivered-To: firstname.lastname@example.org
- List-Name: p2tech
- Reply-To: Gary Liss <email@example.com>
Apologies for Cross-Postings
Pasted in below is a letter (without its attachments) just sent from the
GrassRoots Recycling Network (GRRN) to the CIWMB regarding their upcoming
studies of the Life Cycle Assessment and Market Impacts of
"conversion technologies." For purposes of these studies,
"conversion technologies" mean the processing, through
non-combustion thermal, chemical, or biological processes, other than
composting, of residual solid waste to produce electricity, alternative
fuels, chemicals, or other products that meet quality standards for use
in the marketplace. Processes include, but are not limited to,
gasification/pyrolysis; hydrolysis (acid and enzyme); fermentation,
distillation, and digestion; catalytic cracking; plasma arc; and steam
Please let me know of other proposals that are being made in your areas
regarding these technologies in the U.S., and other studies that have
been done or are underway that assess the environmental or market impacts
of these technologies.
If you would like a copy of the attachments to the GRRN letter, and/or
would like to be included in an email discussion group about these
issues, please email me.
If you would like more info or background on the CIWMB studies underway,
please contact Fernando Berton at <FBerton@CIWMB.ca.gov>. If
you would like an overview of these issues, go to:
August 18, 2003
CA Integrated Waste Management Board
1001 I Street
Sacramento, CA 95814
Re: Conversion Technologies Studies
I am writing on behalf of the GrassRoots Recycling Network (GRRN).
As you know, GRRN is a network of waste reduction activists and
professionals dedicated to achieving a sustainable economy based on the
principle of Zero Waste (for more info, see www.grrn.org). We see our
task as encouraging a combination of community responsibility and
industrial responsibility towards the way materials pass through our
society. Where "waste" is currently produced, we would like the
emphasis placed on better industrial design to eliminate its production,
wherever humanly possible, rather than finding a technology to make the
Thank you for the opportunity to provide input on the proposed
methodology for the Life Cycle Assessment and Market Impact studies on
emerging conversion technologies being done for the California Integrated
Waste Management Board (CIWMB). Gary Liss reported that you had an
active discussion of many issues at the focus group meeting on August 11,
2003. We are pleased that you are taking great care to make sure
your research is asking the right questions, with appropriate
methodologies that will best accomplish your objectives.
GRRN would like to highlight some key points of concern to our network:
Moreover, please find attached additional concerns that we ask you
to address in the scoping of this project, as well as additional detail
relative to those briefly referenced above.
- Air emissions - The study needs to broaden the list of air emissions
evaluated to include all known emissions for all systems under
consideration, regardless of whether data is available for all
technologies on a consistent basis. The absence of data should be
explicitly noted and indicate an area of precaution. In this respect we
would draw attention to the fact that a huge discrepancy has been found
between dioxin air emissions when collected in six hour testing (the
usual method) and two-week tests (the dioxin emissions found can be 30-50
times higher). The latter methodology (AMESA) is now available on a
commercial basis and should be specified as the appropriate method for
gauging dioxin emissions from new sources in California.
- The studies should focus on residues from material recovery
facilities (MRFs) and individual materials that are problems to reuse,
recycle or compost and are currently landfilled. However, we are
concerned that a huge capital (and political) investment in
"converting" these materials could distract decision makers in
government and industry from the primary task of designing packaging and
products which can be reused, recycled and composted. For this reason,
the studies should assume that no diversion credit is given for
conversion technology systems.
- The evaluation of technologies should classify the wide range of
technologies into technologies that operate above life temperatures
(above ~200oF.), and those operating below that (e.g., composting and
anaerobic digestion). At high temperatures acid gases are produced, toxic
metals are liberated (as gases or fine particulate) from otherwise stable
matrices and dioxins and furans (PCDDs and PCDFs) are generated and put
into the air and one is left with problematic residues. As a consequence
society is left with the huge burden of monitoring these facilities as
well as disposing of these problematic residues.
- Emissions and cost data should only be used from commercial scale
operating facilities. This should not be an academic exercise of
theoretical information. Technologies without such data should be
noted as not developed enough yet for commercial municipal applications,
and not considered further in the studies.
- Identify any environmental impacts that are not clearly understood
and that would be subject to the Precautionary Principle (as recently
adopted by the City and County of San Francisco), if adopted by other
cities and companies.
- The studies should not only compare the impacts of conversion
technologies on "recycling and composting," but also on:
eliminating waste and source reduction (and the significant upstream
benefits of avoiding wastes from mining, manufacturing and distribution
of products, the energy conservation and reduced greenhouse gas emissions
benefits of waste prevention and recycling, and to ensure industry will
still have an incentive to redesign products and packaging to eliminate
waste and design them for reuse, recycling and/or composting.
We believe that some conversion technologies may help us to develop the
Carbohydrate Economy that eliminates our society's reliance on scarce oil
and gas supplies. However technologies used must be designed first and
foremost to protect the public's health and safety, and the environment
as well as ensuring that we remain focused on truly sustainable
Thank you for including our concerns in the scoping for this
project. We look forward to continuing to participate in the review
of the results of this research, and the development of policies
governing conversion technologies in California.
If you have any questions about our concerns, please do not hesitate to
contact Gary Liss at 916-652-7850 or me at 608-232-1830.
David E. Wood