California Air Resources Board

Thank you for including the waste and materials recycling sector in the State's PCAP. EPA has advised that proposals that include cross-sector participation of multiple sectors will be viewed more favorably for funding.

However, Figure 10 Waste Sector emissions do not include the more significant savings of Scope 3 emissions indirectly from the reduction of mining, manufacturing and distribution of products that we know in the waste sector as "upstream". The EPA WARM model recognizes these Scope 3 emissions, and an EPA systems analysis study in 2009 by Josh Stolaroff found that Scope 3 emissions include between 40-50% of all GHGs that could be reduced through Zero Waste and Sustainable Materials Management (SMM) programs. Recognizing these benefits should encourage you to include an additional PCAP investment in reduction and reuse measures. Under a more recent update of that 2009 analysis, Zero Waste USA calculated that Provision of Goods and Provision of Food account for as much as 46% of nationwide greenhouse gas emissions and some of these emissions can be reduced through Zero Waste strategies. Such measures would also reinvest resources into the local economy, make available more affordable reused products (e.g., surplus food, clothing, and building materials) to those who need them, and create significantly more jobs.