Andrew Steckel

U.S. EPA Region 9

75 Hawthorne St.

San Francisco, CA 94105-3901

RE: Agency/Docket Numbers EPA-R09-OAR-2012-0252 and FRL-9687-4 Concerning ‘Revisions to the California State Implementation Plan, South Coast Air Quality

Management District; San Joaquin Valley Unified Air Pollution Control District’

Dear Mr. Steckel:

Thank you for the opportunity to comment on the U.S. EPA’s proposed revision of the

California State Implementation Plan (SIP) to include two air district prohibitory rules

that provide the first-ever restrictions on emissions from piles of decomposing green and food material at commercial composting facilities. The Department of Resources

Recycling and Recovery (CalRecycle) has a vital interest in this proposed revision.

CaIRecycle is charged with achieving the state’s new, far-reaching 75% reuse,

recycling, and composting goal. Since compostable organics still comprise at least 1/3

of the disposed waste stream (with food waste being the largest portion of organics), the ability to maintain and expand our organics management infrastructure is critical if we

are to achieve this 75% goal.

As described below, CalRecycle has worked closely with the San Joaquin Valley Unified Air Pollution Control District and the South Coast Air Quality Management District on

Rules 4566 and 1133, respectively. On the basis of these interactions and new

research findings described below, CalRecycle supports the proposed action in

general. However, CalRecycle also requests that the U.S. EPA, as part of this SIP

approval process, allow and direct air quality regulators to provide more

flexibility when considering new regulations on low-reactivity sources (for ozone

formation) of VOCs, such as composting, especially when those sources have

other environmental benefits. I view this as a critical need as we move forward in

expanding our organics management infrastructure in California; in addition, these

issues apply anywhere in the United States where there is poor air quality as well as

mandates or goals to reduce greenhouse gas emissions, improve the sustainability of

agriculture, and decrease the amount of materials landfilled. CalRecycle recommendsadditional changes described further below.

ORIGINAL PRINTED ON 100% POST.CONSLJMRR CONTENt PROC00S CHLORINE FREE PAPER
the existing green material composting infrastructure to continue to provide environment

benefits to California.

However, the combined effect of these district rules and additional Clean Air Actrequirements, especially New Source Review provisions requiring Best Available

Control Technology and offsets for new compost facilities, remains a significantdeterrent to expanding the composting infrastructure in California. As noted above,

CaiRecycle is charged with achieving 75% recycling and composting in California by

2020. In 2010, some 37 million tons were still being disposed in California landfills,

leaving more than 12 million tons of compostable organics in that waste stream which

will need to be processed. California’s compost and mulch facilities currently process

about 9 million tons annually, but few of them operate at maximum capacity, so this

means the composting infrastructure in California needs to roughly double its capacity inorder to achieve 75% recycling and composting. Under the current economic paradigm

where compost facilities must compete for feedstocks with low-cost disposal, and where

local governments face increasingly tight budget restraints, federal help and guidance is

needed to grow the nation’s organics management infrastructure.From 2009-2011, CalRecycle and interested stakeholders, including the AlamedaCounty Waste Management Authority, the California Association of Sanitary Agencies

(CASA) and numerous organics handlers, contracted with the UC Davis School of Civil

and Environmental Engineering to conduct a series of experiments to determine theozone formation potential of composting process emissions. The experiments used a

mobile ozone formation chamber, as well as gas chromatography and modeling to cross

check the results. Composting emissions were found to be roughly 1/3 as potent for

ozone creation as the typical VOC mix found in urban areas. Composting emissions

were proven to be less reactive than vehicle emissions and silage piles, and also less

reactive than the naturally occurring VOCs emitted by oak, pine and orchard trees all

over California every day (these biogenic plant VOCs make up about half of all VOCs in

the San Joaquin Valley). The results of these studies were published in the peerreviewed journal “Atmospheric Environment and on the CASA and CalRecycle web

sites. All 3 documents are linked to this page:

http ://www.calrecycle.ca.qov/Orqanics/Air/default. htm.
formation, and that U.S. EPA direct air quality regulators to allow more flexibility

when considering regulations on low-reactivity sources such as composting.

Additional Recommendations

CalRecycle also wishes to provide the following additional recommendations, some of

which are directly related to the SIP rulemaking and others more indirectly to U.S.

EPA’s role in promoting recycling and composting:

1) Clarify the availability of offsets for implementation of mitigation measures by

existing facilities: It appears that one avenue for growth of the composting

infrastructure subsequent to rules 1133.3 and 4566 is to make existing facilities

more productive through the use of aerated static piles and anaerobic digesters.

These additions will improve California’s ability to move food waste away from

landfilling. We are pleased that U.S. EPA shares CalRecycle’s goal of removing

food waste from the disposed waste stream, and look forward to future collaboration

in this regard. However, there is some question in the regulatory community about

whether existing compost facilities should be able to receive offset credits for

implementation of mitigation measures which reduce VOCs beyond what is requiredby existing rules. These same mitigations can potentially reduce greenhouse gas

emissions as well. Availability of offsets for surplus reductions improves the

prospects for modernizing existing facilities, and we strongly urge U.S. EPA to clarify

this issue in the affirmative.

2) Revise pollutant inventories: Reactivity also has an important role to play in

improving the accuracy of emissions inventories, especially when these emissions

are attributed to composting. We request that U.S. EPA help ensure that pollutant

inventories are revised whenever the knowledge base changes, and to specificallyreconsider the amount of ozone formation attributed to composting in California.

3) Support research on emissions from green materials applied to farmland:

CalRecycle agrees with U.S. EPA’s call for testing of food waste composting

emissions. However, there is an even more urgent need: to test emissions from

green materials directly applied to farmland. Direct land application is a likely outlet

for organic materials if composting is restricted or made more expensive by air

quality rules. In addition to unknown emissions impacts, direct application has

proven more difficult to regulate and provides a potential pathway for spreading

pests and pathogens. This research was requested by U.S. EPA in a meeting in

July, 2010, and a team consisting of CaiRecycle and the UC Davis School of Civil

and Environmental Engineering submitted a research proposal for this concept to

U.S. EPA in 2011, but it has not yet been funded.
g 

p

p

use agricultural water more efficiently, they reduce air emissions from irrigationpumping—as well reducing costs and energy inputs. An additional benefit is

reduced runoff from fields and less potential impact on groundwater from fertilization.

However, these benefits have not been adequately quantified. U.S. EPA assistance

in funding water savings research associated with composting use could help

provide incentives to composting facilities that could partially offset higher costs

associated with Clean Air Act compliance.

In closing, I would like to reiterate the critical nature of CalRecycle’s primary request

that U.S. EPA provide flexibility to air districts when they consider regulations on lowreactivity VOC sources with other environmental benefits, such as composting. We

need U.S. EPA to take a leadership role in resolving this issue so that air quality

continues to improve and the composting industry can continue to grow. I look forward

to U.S. EPA’s consideration of these comments. If you have specific questions about

our comments, please contact Mr. Bob Horowitz, Supervisor, at (916) 341-6452 or at

Robert.horowitz@CalRecycle.ca.gov.

Sincerely,

-,

..

,/.

/ ./_/,•‘._

Caroll Mortensen

Director

Cc: Jared Blumenthal, U.S. EPA Region 9

Jeff Scott, U.S. EPA Region 9

JUL 1 7 RECD