Submitted Comment Name Nicole Tai Affiliation GreenLynx Subject California’s draft PCAP Message Dear CARB, I'd like to advocate for reuse and deconstruction to be included in the Waste Section as Measure #3 of the California Priority Climate Action Plan. Ideally, measure #3 includes support to build a new program in both CalRecycle, GoBiz, and the Governor's Office of Business and Economic Development focused on reuse, deconstruction, design for disassembly and reuse, and different forms of reuse and repair. These sectors are currently at risk due high costs of space, aging repair and reuse business owners, and at the same time no government investment, incentives or mechanisms to help these industries manage our reusables. This is a gargantuan task that is taken up by small businesses and nonprofit organizations. By the time the State decides to get around to funding reuse, we may all have decided it is time to retire, or have sold our properties to simply keep smaller operations running. Already in the past 7 years just in just my small sector of reuse (building materials reuse), 7 companies have closed their doors in the San Francisco Bay Area. Those of us that are left are hanging on in hopes of a sea change. Investment is needed now in order to prevent any more closures - especially when the industry is on the precipice of solving many of our scaling issues. Without societal investment and a transition to a reuse focused circular economy, we will not be able to prevent a climate catastophe. We must change our consumption habits and move to a circular regenerative system and away from our current linear waste system. Nearly 1/3 of organic waste is dimensional and other lumber and wood products, and there is likely a high percentage of wood waste in the 1.5 million pounds of California's bulky waste. Meeting SB1383's requirement of 75% diversion of organic waste by 2024 will not be possible with the limited current CalGreen code which does not require any organic waste be recycled or reuse at all. The 65% rule in CalGreen is easily met by most construction projects with concrete alone, thus most wood is chipped and used for alternative daily cover for landfills or is sent to biomass plants. The grant California Air Resources Board Received from EPA suggests that specific measures be included in the waste section and a major measure with 13 submeasures is "Built Environment: Deconstruction and Reducing Construction and Demolition Materials". You can find these examples here: https://www.epa.gov/smm/example-government-climate-action-plans-address… . Also included in that list is Reuse and Repair. These sectors should be given a higher weight than all others within the waste section when it comes to climate change prevention because they are highest on the waste management hierarchy. One of the main benefits of the reuse sector is that it displaces new products and prevent upstream emissions. I urge you to reconsider including reuse in the PCAP to show that California is not only a world leader on environmental solutions of the 21st century, but is serious about climate change. Best, Nicole Tai File Upload (i.e., Attachments): N/A
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