California Air Resources Board

I am writing today on behalf of Zero Waste Sonoma. As a local government agency, working for the nine cities and towns and unincorporated areas of Sonoma County, our goal is to reduce, reuse, recycle, compost, and dispose of discarded materials safely and efficiently through programs, policy, and outreach. Our vision is an engaged and informed community with the shared goal of thriving in a sustainable region without waste.
We urge the California Air Resources Board to consider including Reuse Infrastructure as Measure 3 under the Waste section of the Priority Climate Action Plan as a key area to aid in the transition to a Circular Economy, which will reduce the demand for raw materials and new products, helping to reduce global emissions resulting from the extraction and processing of material, which accounts for half of the total emissions on the planet.
The social, economic, and environmental impacts associated with the existing reuse economy are vast and include:
• building deconstruction
• refill
• reuse retail
• repurposing
• repair
• remanufacturing
• refurbishing
• reupholstering
• upcycling
• vehicle repair
Without investment now in reuse, a circular economy will never come to fruition because the current linear waste focused system will be allowed to develop further unchecked. This is why we continue to fail to reach California's waste reduction goals. We will remain in a continual waste cycle of fast material consumption to landfilling, combustion, recycling or composting. Shifting consumption patterns and designing products that use materials more efficiently have the highest potential to reduce emissions.
The circular economy also has an important role to play in supporting clean energy, where a larger supply of materials and minerals is for the infrastructure. Now is the time to fund reuse infrastructure that can be used to leverage a more sustainable scaling of the clean energy transition by relieving pressure the raw materials supply chains, and preparing for end-of-life management challenges from solar panels, electric vehicle batteries, and wind turbines for example.
Vast resources have been allocated to recycling, which is a necessary facet of materials management, but recycling perpetuates the shortcomings of a linear economy and reinforces single-use consumption. It is time to act toward extending products’ useful lives through reuse activities such as repair, refurbishment, upgrading, and remanufacturing which yield a far greater climate benefits compared to manufacturing new.
Reuse across sectors will be a strong driver toward sustainable and regenerative consumption patterns and will only be successfully implemented at a systems level with government intervention through policy and investment.
The landmark packaging law, SB 54 will require 4% reuse of packaging and foodware by 2032, and while the producers will pay for these changes, it is institutional investment in reuse that will strengthen and solidify the foundation and expansion of reuse at a statewide level.
We urge the California Air Resources Board to include Reuse under the Waste Section of the PCAP. Please also consider selecting an alternate term for “Waste” referring to GHG measures, as it does not advance the concept of circular systems.