Comment Details
| Comment Author: | Charles White |
| Organization: | Waste Management, Inc. |
| Comment Date: | Tuesday, 27 October 2009 |
| Comments: |
Other/General Comments : On behalf of Waste Management Inc, I am pleased to take this opportunity to comment on the Offset Limit Recommendations Paper issued October 6, 2009 by the CSAD of the Western Climate Initiative. Waste Management is the leading provider of comprehensive waste and environmental services in North America. We operate in 48 states in the U.S. and most Canadian provinces. Operations include a fleet of more than 20,000 collection vehicles, and our diverse operations include 413 waste collection operations, 370 waste transfer stations, 283 active landfill disposal sites, 17 waste-to-energy plants, 131 recycling plants, about 100 beneficial use landfill gas-to-energy projects, and six independent power production plants. We agree with the WCI approach to offsets that limits the use of offsets rather than limiting the supply; implements a common use limit across WCI Partner jurisdictions; sets the limit at an equal percentage of compliance obligations across compliance periods; and implements a region-wide “carry-over” approach. Although not specifically included in the paper now under review, we note that WCI currently is reviewing protocols for use in determining offsets. As with emissions reporting protocols, it is of paramount importance to select proper protocols that accurately reflect the greenhouse gas emissions savings due to certain solid waste management methods. In addition to offsets awarded from landfill recovery projects, WCI should include rewards of offsets as a result of increased recycling, effective long-term carbon storage practices, reduced well-to-wheels transportation fuel carbon intensity and generation of electricity from waste-to-energy. As the report states, a robust offsets program will be key to an efficient and effective cap and trade program. We believe a robust offsets program requires a diverse and inclusive supply of offset projects. Consideration of more, rather than less information will lead to greater insight, fewer emissions, and better policy decisions. A policy that broadens the supply and projects available for offsets will result in strong initiative to lower greenhouse gas inventories in a shorter time frame. Solid waste management can play an important role in lowering overall greenhouse gas inventories by promoting methods and technologies that prevent the release of greenhouse gas emissions such as recycling, carbon sequestration in landfills, waste-to-energy and other technologies that provide sufficient evidence of their savings. Once again, thank you for this opportunity to offer our views and your consideration of these recommendations. Sincerely, Chuck White Director of Regulatory Affairs Waste Management/West 915 L Street, Suite 1430 Sacramento, CA 95814 Phone: 916-552-5859 Fax: 916-448-2470 Cell: 916-761-7882 Email: cwhite1@wm.com |