Saturday, February 25, 2012

San Diego Landfill-A Wasted, Mostly Buried Resource

This is the report I promised you back in December 2010. I might be more ashamed to be turning it in so late, were I not laden with multiple brain injuries and their attendant cognitive limitations, speech difficulties (fairly severe dysarthria which sometimes makes it difficult for me to talk clearly on the telephone or in dictating to my speech recognition software,), etc., perhaps I could have produced this report much earlier, even though I knew nothing of the subject matter. Basically, I am a medically retired former federal employee, who had time on his hands to research these wonderful relatively new waste management technologies, called conversion technologies (CTs). Still, given my lack of knowledge in Solid Waste Management, it took much longer than I thought it would, because I seriously misjudged the enormity of information I had to sort through/digest, starting with waste disposal and landfilling in general, and my trouble Goggling properly for the necessary information within the Environmental Services Department (ESD) San Diego City Government, plus finally, my own computer-based difficulties that are, I am sure, at least partly, a result of those brain injuries.

First, I'm not, nor have I ever had been, a Municipal Solid Waste (MSW) professional or a lawyer. Nor have I been a person employed in the fields of cultural affairs, naturalism, or a practicing labor economist. I am just a private medically retired city resident, who has only gotten my knowledge of this industry through Goggling various sources of information regarding waste disposal, and cities', municipalities', and waste management authorities' respective attempts to deal with their own MSW issues, and my own personal experience as a federal government employee user of waste disposal at one mass-burn Waste to Energy (WtE) facility.

Because some of these suggestions could be considered controversy or sensitive by some, I'm also sending this to Mayor Sanders, all other San Diego City Councilmembers, all in-County City Mayors and City Councils that I can reach via e-mail, and because it could affect the overall waste management plan for the County, all San Diego County Supervisors, most in-county and several out-of-county State Senators and Assemblymen, even though this is a redistricting year, as well as reporters and other MSW interested parties who can help do some reporting on this topic, and help sell the concept, not only for San Diego, but also for the rest of the state. Where used, URLs have been shortened using, a free URL shortening software product, that does not require downloading (the shortened link will automatically take you to the correct webpage).

Second, I recognize that there's been a lot of recent controversy regarding the possibility of contracting-out the city landfill function, and whether it was a contractable function, so I e-mailed my good friend from my days as the Security Director, Naval Ocean Systems Center, subsequently renamed, when the command's missions were redefined again, into the Space and Naval Systems Center, San Diego (SSC SD). During my 10 years of tenure there at NOSC/SSC SD as the Security Director from 1989 to my strep throat-induced medical incapacitation in 2000, we were frequently required to examine all of our internal functions for the possibility that those functions were not inherently governmental, and then if not, determine if the function could be contracted-out. This was part of the The Federal Activities Inventory Reform Act (FAIR), P.L. 105-270, OFPP Policy Letter 92-1, "Inherently Governmental Functions" (09/23/92).
Based on this type of periodic review, we had quite a few functional areas in the command which had been contracted-out, to include building sanitation (trash collection, floor sweeping and mopping, carpet vacuuming and occasional shampooing), grounds maintenance (grass cutting, general trash pickup, bush and tree trimming), waste hauling, a good portion of the command's software programming and related information technology (IT) services via the overall IT services contract, but also in my own Security Office, one IT contractor who helped program some unique, custom-developed software (which reorganized our locks and keys into some semblance of logical order), a major part of the badge and pass (employee/visitor badge and vehicle decal issuance) operation, classified document (documents which contained national security information) destruction, key and lock control, locksmith services (changing on a yearly, or on a as-necessary basis, combinations on security containers used to stored classified documents, the complete plant property triennial inventory, and all contact guard services. We also had thousands of contractors on-site, performing valuable research and engineering services, some of whom, in addition to having a security clearance and “a need-to-know” for the classified information on which they worked, were allowed to act as physical custodians of classified documents, as if they were permanent government employees on-site. These contractors all had security clearances and access to those selected classified documents to the security clearance level of their contracts, as a condition of employment, as part of their respective contracts. Given that the federal government was, in these cases, entrusting classified documents to contractors (individuals employed by private for-profit entities), as is routinely done when any federal classified contract is awarded for development or production of, say, the nation's most advanced fighter or bomber, all the way down, in terms of sophistication, to seemingly the most minor of classified services (like classified photography services or document duplication, for example) [admittedly though, through a whole different process, which is part of the overall Federal contracting process], I find it hard to believe that the city landfill function is an inherently governmental function. I believe these services are legitimately a function that could be contracted-out, as did my friend from work who was in charge of the Functional Review process in the command's Internal Review Office. Similarly, I see no “Inherently Governmental” distinction for the city employees performing the MSW curbside pickup services. In fact after a great amount of Googling the term “People's Ordinance of 1919”, I found the city attorney's ruling on this topic, confirming that, in response to the Environmental Services Department's question of whether the People's Ordinance of 1919 requires City employees to collect residential and small-business refuse generated within the City, thereby precluding the city from hiring private contractors to perform these refuse collection services. The short answer from the then city attorney, Mr. Aguirre, was “No”. As further confirmation of my recommendation in this matter, Reason Foundation's Local Government Privatization 101, in Table 1, shows that both waste collection and waste disposal are two of the top three services privatized to For-Profit entities, according to a survey preformed by the International City and County Management Association. In this same article, following a list of more than 15 potential service areas, says that “But more important, the question of "what can local governments privatize" is in many ways the wrong question to ask, as privatization is a policy tool that should be considered in most instances. A better question is "where can't local governments apply competition or privatization?." Virtually every service, function and activity has successfully been subjected to competition by a government somewhere around the world at some time. When asked what he wouldn't privatize, former Florida Governor Jeb Bush replied: "police functions, in general, would be the first thing to be careful about outsourcing or privatizing. This office. Offices of elected officials ... and major decision-making jobs that set policy would never be privatized.” Quoting from the article, “Governor Bush used competitive sourcing more than 130 times, saving more than $500 million in cash-flow dollars and avoiding over $1 billion in estimated future costs.” Furthermore, the California Republican Senate Caucus Study on Privatization, Briefing Report: Privatizing California's Local Governments, cites some interesting examples of city governments services that can be improved through privatization, and in the Infrastructure, Public Works, and Transportation section, says that:
“A decade ago, California voters approved Proposition 35, also known as the Public Works Project Act of 2000. This proposition granted local governments greater freedom to pursue partnerships with the private sector on infrastructure projects. As such, the infrastructure arena is amongst the ripest areas for employing a range of creative privatization techniques.”
Quoting from the first two paragraphs of Reason Foundation's Local Government Privatization 101 :

"It is not a government's obligation to provide services, but to see that they are provided."
former New York Governor Mario Cuomo

"Privatize everything you can."
Chicago Mayor Richard Daley (advice to an incoming mayor)

Manhattan Institute-This Works: Managing City Finances
, Authors William Eggers of the Manhattan Institute and Center for Civic Innovation Chairman Stephen Goldsmith, the former mayor of Indianapolis, outline the strategies needed to continue to reinvent urban governments; injecting competition into city services; making government performance-based; making use of information technology; improving asset and financial management; enhancing human capital; and creating institutions to drive continuous improvement.

And then there is every privatization advocate's Poster Children, that being “Privatizing City Hall: Sandy Springs and the New Georgia Contract Cities”, a subparagraph under Reason Foundation's Local Government Privatization 101 cites the following: “Sandy Springs, Georgia was the first. Fed up with high taxes, poor service delivery and a perceived lack of local land use control, 94 percent of Sandy Springs' nearly 90,000 people voted to incorporate as an independent city in 2005. What makes Sandy Springs interesting is that instead of creating a new municipal bureaucracy, the city opted to contract out for nearly all government services (except for police and fire services, which are required to be provided directly by the public sector under Georgia's state constitution). Originally created with just four government employees, the city's successful launch was facilitated by a $32 million contract with CH2M-Hill OMI, an international firm that oversees and manages day-to-day municipal operations. The contract value was just above half what the city traditionally was charged through taxes by Fulton County. The city maintains ownership of assets and maintains budget control by setting priorities and service levels. Meanwhile the contractor is responsible for staffing and all operations and services. According to Sandy Springs Mayor Eva Galambos, the city's relationship with the contractor "has been exemplary. We are thrilled with the way the contractors are performing. The speed with which public works problems are addressed is remarkable. All the public works, all the community development, all the administrative stuff, the finance department, everything is done by CH2M-Hill," Galambos said. "The only services the city pays to its own employees are for public safety and the court to handle ordinance violations." Sandy Springs recently successfully rolled out its own police and fire departments. Counting police and fire employees, the city of 90,000 has only 196 total employees. Nearby Roswell, a city of 85,000 has over 1,400 employees. Furthermore, Sandy Springs' budget is over $30 million less, and by most accounts provides a higher level of service.

The "Sandy Springs model" seems to be gaining steam. The city's incorporation was perceived as such a success that four new cities—Johns Creek, Milton, Chattahoochee Hills and Dunwoody—have been formed in Georgia since 2006 employing operating models very similar to Sandy Springs (though severe revenue shortfalls in 2009 prompted the two smallest to scale back their contracts). And in 2008, city officials in the recently incorporated Central, Louisiana (population 27,000) hired a contractor to deliver a full range of municipal services—including public works, planning and zoning, code enforcement and administrative functions—as part of a three-year, $10.5 million contract.
Sandy Springs and other contract cities demonstrate something very powerful from a public administration standpoint: there's hardly anything that local governments do that can't be privatized, so there's no reason policymakers shouldn't think big on privatization.”

Perhaps most importantly with respect to MSW, NSWMA-Privatization: Saving Money, Maximizing Efficiency, And Achieving Other Benefits in Solid Waste Collection, Disposal, Recycling fully explores why MSW privatization is perhaps the best choice for most local governments. Finally, Reason Foundation's Annual Privatization Report 2010: Local Government Privatization provides on page 12, an update on San Diego's attempt to implement the result of the approval of Proposition C in 2006 and the resounding defeat of Proposition D in 2010, of which you are well aware. Part 9 of the same document, page 28, details the latest update on the solid waste and recycling privatization efforts around the country.

But I digress, as privatization could be its own separate report.

Perhaps San Diego's current landfill and all associated municipal solid waste (MSW) issues initially began, I believe, when the city voters passed the People's Ordinance of 1919, by an astounding a 85%-15%,which established a precedent of offering no-fee residential trash collection service. The City's own Environmental Services Department (ESD) Collection Services webpage says that: “the city of San Diego has been providing trash collection services to the public over 90 years” effectively saying that the ESD has been responsible for all MSW collections since the law was passed in 1919. Changes to the system have been proposed at least twice during the last two decades, but voters have decided to pretty much leave things as they are now for residential households. Certainly, the best summary of this situation can be obtained by reading the City Attorney's Memorandum of Law of 16 July 2010 to the Mayor and City Councilmembers. Earlier, the KPBS video of 31 July 2009, entitled Free Trash Collection Could End for San Diego City Residents articulated the idea that free trash collection to residential customers in the city is not the norm in city government around the state or even the county and is considered the “Third Rail” in local City politics, splitting City Councilmembers, because they fear the anger of voters if they support additional taxes to cover this cost, rather than continuing to charge the General Fund for these services, and that charging residents a fee to cover this is the only fair means of avoiding using the General Fund for this cost.

I personally tend to side with Judge Larry Sterling (retired) when he says that, in response to comments regarding free trash pickups for property owners:
On the “free” trash collection issue, all property owners are paying their property taxes and a portion of those taxes were specifically designated for trash pickup via the “People's Ordinance” adopted by initiative in 1919, a direct order from the public. The voters did not command the birth of the dysfunctional Historic Site Board, or the Planning Department, the Development Department, subsidies to the San Diego Unified School Districts babysitting program, or even the Library Department. They did command the creation and operation of the trash pickup and for perfectly good public health and safety reasons. The voters of San Diego wisely wanted all trash picked up and disposed in a uniform and timely manner. Charging double for trash pickup guarantees that those who operate on the financial margins will dump their trash in nearby canyons, on vacant lots, and along our roadsides. There they will become unsightly fire and public health hazards. And much more expensive to pick up. Not only that but the people the mayor is proposing the double charge are already paying for their own streets. Does the mayor want all those streets deeded to the city? Although Judge Sterling did not directly say so, this possibility of trash being deposited in canyons, vacant lots, or along roadsides, is what is known as an unintended consequence of any potential changes to the law!
Judge Sterling continued:
The citizens pay into the general fund therefore there is no such thing as “free trash pickup.”
It is true that the lazy, sorry city amended its own ordinance some time back to prohibit additional “hold harmless” agreements to go off the public right of way to pick up trash. Who knew that? Probably passed on the consent calendar and done without fanfare or wide notice.
It is also not correct to say that the city is not required to pick up that trash. The city is not REQUIRED TO GO ON THE PRIVATE PROPERTY to pick up trash absent a hold harmless agreement. The city is still required to pick up the trash if the resident takes it to a public street.
Where are the savings exactly?

And nearby homes will suddenly find the streets in front of their houses crowded with dozens of trashcans from nearby “private” streets from which the trash has been collected by the city for over 70 years.
It is a sad thing to travel through San Diego and see the streets unrepaired, the traffic islands filthy, dilapidated and abandoned news racks trashing our sidewalks, unpainted city light poles, traffic signals that are not operating, and the city parks and other buildings ill maintained. There are fifty major reforms that I can think of myself that would save the city money or increase its income rather than abandon its basic health and safety duties like picking up the trash.
Given correct management and mayoral leadership, city staff could be driven to do more for less, not less for more. That is exactly what every other enterprise has to do to survive. Why are the city managers exempt from such exertions?

DISCLAIMER: As anyone who writes on a given subject, I will admit to a few biases. First, as most of my former work colleagues will tell you, I have a strong inclination towards using streamlining and technology as a means of solving problems in government, at least the portion of government of which I am most familiar (federal). My second bias is based on my service to the U.S. Navy as Security Director of SSC SD, mentioned above, where I was ultimately responsible for, among other things, the lifecycle management (management, annual inventory and destruction) of all classified (Confidential, Secret and Top-secret) general security classified documents and suddenly inheriting 13 thousand pounds of classified computer hardware (multiple-platter hard drives and other data-retaining electronic devices) when the Anti-Submarine Warfare Department shifted all their classified computer processing off of older Digital Equipment Corporation-brand mini-computers and the Security Office had to dispose of that equipment. Because the command had previously been almost solely concerned with tens of thousands of classified paper documents, and had consequently been using disintegrators (large machines with multiple spinning rows of knife blades which cut paper into very small particles) to destroy all these classified paper documents, and having no readily available method of destroying metal or other classified hardware, and acting on a tip from a former supervisor of one of the previous classified destruction contracts, we contacted the Plant Manager for the City of Commerce, CA WtE facility, who after hearing what we were looking for, readily agreed to accommodate our need for personal verification of hardware destruction. I and a couple of my security supervisors loaded two trucks with box after box of this heavy hardware/material and proceeded to drive to the plant. Following a demonstration of the plant's capabilities for emissions monitoring (I was and still am concerned with our air quality and the environment), we proceeded to dump some of the hardware into the available charging shoot, which led straight to the plant's furnace (federal security regulations do not allow one to simply dump classified material into an open pit and merely hope for a later claw pickup and burning in the furnace, like one usually does with MSW). After a nice long break to check whether the emissions monitors had spiked (which of course they hadn't significantly moved), and being reassured by the plant manager that this was not unusual (he intimidated that we were not his first customers requiring classified destruction), we just started dumping the computer hardware in as fast as we could carry it to the charging shoot. This classified material/hardware destruction effort was so successful, that we subsequently modified the command's entire classified destruction contract to eliminate the disintegrators as government-furnished equipment and, when asked by the potential contract bidders, told them that we had recently used that City of Commerce WtE facility as our disposal site. The successful bidder of the subsequent contract re-award also bid to use this City of Commerce WtE facility, not only saving the command significant money but also allowed the command to permanently shut-down the disintegrators and associated bailing machine which had been fouling the area both inside and around the building where they were housed with extremely fine paper dust particles, really too small to capture or preclude from being generated, from a practical standpoint.

Fast forward to 2008, after my strep-throat-induced series of brain injuries, resulting in my forced medical disability retirement, when I read either an environmental blog or Science Daily article on a waste-to-energy technology involving IST Energy's Green Energy Machine (GEM) technology and how this CT was being used in Boston, MA to power an entire office building using the buildings' own waste, admittedly mostly paper (although I believe the technology has been further improved and commercialized from when I first saw it). The thought of a possible CT operation dealing with San Diego's MSW while also possibly offering a closer site for the classified disposal requirements of SSC SD, (although I was medically retired from that Point Loma Research and Development facility) got me working somewhat more aggressively, hoping to find a way in which to effect this. During your 2 May 2009 community meeting in Scripps Ranch, I noticed that one of your priorities in the City Council was greater efficiencies in the ESD for curbside MSW pickup, so I notified Ms. Batten, your Scripps Ranch field Representative, of my admittedly limited knowledge on the subject of CT, but subsequently e-mailed her with the information I had read, and proceeded to both attempt to gain additional information on the subject matter, and even attempted to set up a meeting date with Mr. David Montella, then InfoSciTec (IST) Executive VP, Technology Solutions, now IST Energy, who was already going to be in San Diego on 8 October 2009 for other business, if we could meet at my house (rather than looking for another meeting site, which would have required transportation for me (having lost my license to drive a car because of my brain injuries) and anticipating the need for several attendees, both from your staff, potentially from the staff of Congressman Duncan Hunter (admittedly looking at the possibility of a federal grant for a demonstration project), as well as the City's Environmental Services Department (ESD). I also ended up inviting representatives of Visiam as well as Startech Environmental Corporation (Startech) . Unfortunately, neither of the three companies representatives could attend, nor could representatives of the ESD, your office, or Congressman Hunter's office. My guess is that because I had clearly signed each e-mail to these respective companies with a statement which admitted that I had absolutely no authority in the matter, but was only a concerned citizen, likely led the companies to write-me-off as a dead-end business lead. Later, Ms. Dolce of Congressman Hunter's field office was tasked with following-up to see if any significant activity had occurred or any plans have been made during the meeting. I had to admit to her via e-mail, that no meeting had taken place, but I had received a call from the West Coast representative of Startech to extol the virtues of their gasification solution, and how much cleaner electricity from gasification was compared to coal burning, just before her (Ms. Dolce's) call to me.

Not one to casually admit defeat, I started contacting all of the other CT providers I could find around the country in an attempt to try to determine which one was best. Some of those companies I contacted included W2 Energy Corporation, Waste2Tricity, ILS-Partners , which has now partnered with Pyromex Group, and looked at the CT offerings of S4 Energy Solutions (a collaboration of Waste Management, Inc. and InEnTec, [a spinoff of technology developed jointly by the Massachusetts Institute of Technology (MIT) and the Battelle-operated Pacific Northwest National Laboratory (PNNL)] , EnerSol Technologies, Inc., Westinghouse Plasma Corp..(a division of Alter NRG Corp), Jacoby Group Geoplasma, and contacted several integrators of these thermal conversion and anaerobic conversion technologies, both in the US as well as in Europe. I found the AITKIN COUNTY, MN PLASMA GASIFICATION STUDY assessment of whether to move forward with a full feasibility analysis regarding a potential CT solution in the International Falls, MN area. Subsequently, I also discovered Fulcrum Bioenergy , with whom Waste Management has now entered a strategic partnership. and Sun Energy Group LLC In total, I literally spent 3 yrs. (admittedly part-time, as a brain-injury person trying to perform other household tasks) reviewing the history of waste disposal from the basic of burn cans in one's backyard (as I had experienced with paper/cardboard growing up), vacant lots dumping, county dumps, cities and waste agencies as diverse as New York City; Puerto Rico; St. Lucia County, FL; Hawaii; Los Angeles city/county; Santa Barbara city/county, and reviewed various references on the subject, feeling like I should have earned at least an Associates degree in Solid Waste Management, if it exists. It was about this time that I realized that the City of San Diego was broke, and really unable to purchase or invest in any equipment, even if such investment would help solve the MSW situation. The response to one of my many inquiries, from Plasco Energy Group, referred me to an international competition held by the Salinas Valley Solid Waste Authority (SWSWA), in which the authority had already begun to study the potential for CT of MSW starting in 2005, apparently when the communities that make up the Authority resisted further landfilling. I found the Authority's entire process of looking for a public-private partnership for MSW destruction, establishing a Conversion Technology Committee (CTC) to recommend long-range diversion goals, it's two-phase approach to contracting for such a solution (first, a Request for Qualifications, [RFQ]), and then a Request for Proposals (RFP), to be very instructive. Also, the CTC actually took field trips to selective/referenced MSW CT sites around the world to witness firsthand those operations (pages 7-28 of HDR's slide presentation). In looking at some of the proposals for the SWSWA, led me to Urbaser S.A , EBARA-TwinRec Gasification and Ash Melting Technology, a Japanese CT technology which has been used in several applications in that country as well as Interstate Waste Technologies and Entech Industries . Subsequently, I also discovered PyroGenesis Canada, Inc. a CT firm which has recently been awarded a contract with the U.S. military, Recovered Energy, Inc. , WPP Energy Group , Ze-gen , Zeros, Global Energy Solutions, Bull Moose Energy, FutureFuelCorp.

Also, Mr. Mathews, SWSWA General Manager/Chief Administrative Officer and his staff, particularly his Diversion Manager, Ms. Susan Warner, were very helpful and tolerant of my incessant calls and e-mail questioning on how they achieved what they did. I believe that CA State Sen. Anthony Cannella and CA Assemblyman Louis Alejo, can be very proud of the work that SWSWA has achieved, in setting a standard for the rest of California to strive for.

The city of San Diego's planning for future MSW handling was the hardest for me to find, as its name didn't initially seem to apply. The Long-term Range Management Operational Strategic Plan (LRMOSP), put together with the assistance of Bryan A. Stirrat and Associates (BAS) lays out many waste diversion options for the City. Similar to the SVSWA's CTC is the establishment of a Resource Management Action Committee (RMAC) which is tasked with recommending short-term and long-term diversion goals. I was able to find minutes from RMAC Phase I meetings 1 through 5 on the Web, but nothing since. So if further decisions have been made since then in Phase II, I'm not aware of them.

Center on Policy Initiatives OnlineCPI's Petition titled KEEP MIRAMAR LANDFILL PUBLIC argues that “Turning the public's business over to private operators-whose goal is profit rather than the public good-puts quality and safety at risk and often cost the community much more in the long run” and continues later with “There are significant risks in operating the landfill for profit, rather than for the public good, including environmental damage, added expenses and the loss of community services funded by landfill revenue.” I personally believe that with proper contractural monitoring and oversight, landfilling (what is left of it, when CT is applied to the MSW) can not only be safely done by a qualified CT contractor while also benefiting the public sector (San Diego) financially.

As far as the landfill itself is concerned, Online CPI:Miramar-A Public Asset that benefits all San Diegans, states that the Miramar landfill brings in about $6 million more than it cost to operate, and that these surplus funds pay for vital services in other/related areas. However, the report of the Grand Jury of 2008-2009, Time for Repeal of the People's ordinance of 1919, would seem to imply that the cost to the city's General Fund for all Municipal Solid Waste(MSW) curbside pickup and disposal in the landfill is in excess of $50 million/per year, if not greater. However, how much of that cost is related to operation of the Miramar landfill itself is not defined.
But, the financial analysis performed by BAS, as part of the city's LRMOSP, chapter 4.3.1, says “For 2009, the annual budgeted expenditures in the General Fund are $40.5 million. The General Fund portion of the ESD funding provides for weekly residential refuse collection, refuse container management, underground tank management, asbestos and lead management, hazardous materials, and other related services.”

Furthermore, chapter 4.4.4, Overall Financial Picture, of the LRMOSP says that in summary, “While the city has implemented cost-cutting measures and increased efficiencies to extend the lives of the funds. However, given the overall trends of the funds, the success of recently implemented waste reduction and diversion efforts, and the impacts of the economic crisis, the Recycling Fund is currently projected to be in a deficit in Fiscal Year 2010, and the Refuse Disposal Fund is currently projected to be in a deficit in future years.”

So in summary, it appears that the landfill is far from a moneymaker, and is in fact, is a significant drain on the General Fund, which will only increase over time. Unfortunately, the waste reduction and diversion efforts implemented by the ESD, while probabl important for the environment and potentially lengthening the life of the landfill, have only made the landfill less financially self-sufficient.

Sierra Club San Diego Chapter in their letter on privatization of the landfill, addresses several potentially important issues. Not being qualified to review all of these legal citations, I will have to leave their letter to the City attorney to decide what is correct, but I believe that both the Online CPI and Sierra Club documents miss the major point of discussion, and that is, in spite of using the best landfilling processes available, like making the landfill more dense by compacting it to industry standards, using full cost accounting on an as-needed basis to determine ESD expenditures, using alternate daily covers, leachate recirculation, achieving International Standards Organization (ISO) certification, the city is still rapidly running out of landfill space in Miramar's West Cell, and with no other city-owned landfill to which we can retreat, city residents will likely be forced to start paying for their waste disposal at distant, and more expensive, non-city-owned landfill sites, even though tax increases which had been proposed in the past, have been soundly defeated, I believe a different tact is necessary to continue disposing of our MSW. The situation seems even more bleak when one considers that as the local economy recovers, total MSW will likely increase in volume. The key to reducing this volume, I believe, is as BAS has indicated in the LRMOSP, is the use of CT to drastically reduce the massive volume of MSW currently destined for the landfill.

I also contacted Dr. G. Fred Lee, of G. Fred Lee & Associates, a noted authority on landfill sitings, risks,and inadequacies and, and when asked: ”What I'm interested in knowing is whether applying any of the various current MSW conversion technologies available (biological or thermal conversion, or even older waste-to-energy [WTE] solutions), in your mind, has any significantly less negative impact on the environment following this conversion when disposing of the remains/non-salable product into a landfill? As and admitted untrained observer/novice, I tend to believe that such conversion might go a long way towards minimizing any deleterious effects on the environment. “ Dr. Lee responded with this: ”These MSW conversions approaches can be conducted with little or no impact on the environment/public health. However the siting and operation of these technologies with full environment/public health protection make them far more expensive than the typical Subtitle D landfilling as allowed today in California and under the US EPA regulations. The basis issue is that the politics are such that administrations are unwilling to cause the public to experience paying double to triple the cost of MSW management.”

The presentation “Health Risk of Landfilling Versus Combustion of municipal solid waste: An Illinois Comparison”, of which Drs Lee and A. Jones-Lee co-authored work was referenced, the abstract states in part “Risks of either technology [landfilling versus combustion] fall within the regulatory precedents for acceptability during the operational phase (30 years) and the early closure phase (40 years), but the ultimate releases of leachate from the landfill generate potentially large risk over time interval beyond this horizon.”. This statement would seem to indicate that, in the long run, the choice between landfilling versus combustion is an easy one in favor of some form of combustion.

Even the 2006 National Latino Congreso Resolution 3.15 (Floor Submission)-- Conversion Technologies and Zero Waste resolved that:

WHEREAS, The California Integrated Waste Management Board indicates that over 40 million tons of waste are land filled every year just in California, despite a 50% recycling rate; and

WHEREAS, landfill space is at a premium and disposal rates are estimated to increase; and

WHEREAS, the siting of landfills and solid waste disposal facilities is a major Environmental Justice issue, and eliminating the need for disposal reduces the impact on communities with nearby disposal facilities impacting their quality of life; and

WHEREAS, conversion technologies are processes capable of converting residual post-recycled solid waste and other organic feedstocks into useful products, alternative fuels, and clean, renewable energy, and offer strategic energy, economic, social and environmental benefits; and

WHEREAS, biofuels derived from solid waste and excess biomass via conversion technologies and can be a clean, renewable fuel source that reduces our dependency on fossil fuels; and

WHEREAS, the use of conversion technologies can contribute solutions to California's critical waste disposal and environmental problems, and result in substantial environmental benefits for California, which include reducing the amount of waste disposal in landfills, production of renewable energy, and reduction of air emissions including greenhouse gas emissions; and

WHEREAS, conversion technologies can create "green collar" jobs with good wages and benefits through increased private investment;

1. Support the enhancement and expansion of waste reduction and recycling programs nationwide, and the adoption of zero waste goals to eliminate the concept of waste;

2. Conserve natural resources and reduce the amount of hazardous materials in the waste stream by supporting and promoting preferable purchasing programs, product redesign, advanced disposal fees and other manufacturer responsibility measures as well as enhanced collection and recycling infrastructure;

3. Urge state and local communities throughout the country to invest in landfill alternatives, such as conversion technologies, which create "green collar" jobs and make use of abundant biomass and organic waste resources in an environmentally beneficial manner; (emphasis added)

4. Lobby lawmakers at the State and Federal level to provide clear permitting pathways for the development of conversion technologies, and properly define and incentivize the development of these technologies based on sound science ad their life-cycle environmental impacts and benefits in relation to other solid waste management options.
In looking around the state for evidence of other waste disposal issues, the article BioEnergy Producers Association-AB 222 Gutted by Senate Environmental Quality Committee states that five Democrats on the Senate Environmental Quality Committee yielded to "environmental" opposition orchestrated by lobbyists for the traditional waste industry, and stripped the bill of its RPS [renewable portfolio standard] and landfill reduction provisions--the two major elements necessary to finance the construction of these projects. During the following week, the Committee's staff published further amendments that would have made it even more difficult to permit and operate these facilities than it is under existing statute.
The Bioenergy Producers Association report titled “California's Waste Conversion Technologies-Ensuring an Environmentally Clean and Abundant Future states "the Bioenergy Action Plan was created years ago and was available for review yet nothing has changed or have been done." So Senators Joe Simitian, Fran Pavley, Lori Hancock, Ellen M. Corbett, and Alan S. Lowenthal,(your names were the only ones on an old Facebook page, which incorrectly compared CT to incineration [a technique that the Global Alliance for Incinerator Alternatives (GAIA) has been known to subscribe, regardless of the science that shows otherwise] so it would appear that you are the members of the Senate Environmental Quality Committee who defeated AB 222). As intelligent as I assume you are, how could you possibly fall for this sophomoric and shallow rhetoric delivered by the Californians Against Waste (CAW) when they address the issue of Conversion Technologies, and say that “Conversion Technologies do not “Recycle”. I have read AB 939 and other related legislation, and I cannot find any wording that mandates that recyclers must sell their recycling residue (scrap aluminum, glass, metal) to manufacturers of such initial products.*

Insert something saying that Eight Great Myths of Recycling shows that
To suggest that they must would seem to impose a business model on the beverage industry that was rejected in the 1960s. Furthermore, this seems to impose a completely different standard on the state's recyclers, whereby they are not allowed to seek the highest price for their recycled products.

In fact, the Executive Summary of the Draft Conversion Technologies Report To the Legislature of March 2005, at the board meeting of 15-16 March 2005, Agenda item 23, Attachment 1 says: ”Visualize millions of tons of yard trimmings and wood that cannot be composted, of low value paper and plastic residuals from material recovery facilities (MRF) for which there is no recycling market demand, and of agricultural residues that can no longer be burned in the fields. All of these materials are either landfilled today may be headed for landfills tomorrow. Now imagine a future where unwanted materials destined for landfills instead are converted into high-value products such as energy, ethanol and other fuels, and citric acid and other industrial products. That future could revolve around a new generation of “conversion” technologies that have potential that help solve vexing environmental problems and could help achieve California Environmental Protection Agency's Strategic Vision and goals, including continuous improvement and application of science and technology and ensuring the efficient use of natural resources. ... The California Integrated Waste Management Board (CIWMB) has been researching conversion technologies because, although California has achieved a 47 percent statewide diversion rate and has a current composting infrastructure that processes 10 million tons annually, more than 39 million tons of material was disposed of in landfills in 2003. Of the amount disposed of in landfills, nearly 80 percent is organic material (paper, wood, green waste, food waste, etc.)”

Later on in the Environmental and Public Health Impacts section, page 33, the following information is provided: “While biological processes have gained widespread acceptance for various feedstocks,thermochemical processes have met with resistance from the environmental community and the public. Some of this resistance has stemmed from the perception that pyrolysis and gasification processes are variations of incineration. Some commenters have stated that federal law includes gasification and pyrolysis as part of the definition of incineration. ... The federal definition does not include gasification or pyrolysis. According to the University of California researchers, thermochemical conversion technologies differ widely from incineration in several key respects: the volume of output gases from a paralysis reactor or gasifier is much smaller per ton of feedstock processed than an equivalent incineration process. While these output gases may be eventually combusted, the alternative processes provide a intermediate step where gas cleanup can occur. Mass burn incineration is limited by application of air pollution control equipment to the fully combusted exhaust only....
Today the level of dioxin air emissions from combustion of MSW in the US has decreased from 8900 g-TEQ per year in 1987 to 12 g-TEQ per year by 2000, a decrease of 99.9 percent. The MSW combustion industry represents less than 1 percent of the dioxin/furan (emphasis added)

I ask you Senators, why didn't you at least publicly challenge the authors of the draft UC Riverside study on CT, on their study conclusions and opinions on why California should not be pursuing these CT opportunities, as part of the overall statewide RPS goals and landfill reduction provisions before choosing politics over hard science conducted by the state's own university system?

I can only assume that you have become enamored by the idyllic nature of the The Story of Stuff but before you pat yourself on the back, you should read a four-part critique of Ms. Leonard's work starting here. For those who believe that recycling is a noble goal, you should read the Eight Great Myths of Recycling . Furthermore, Dr. Milton Friedman, our nation's Nobel prize-winning economist, further destroys some of the basic tenets of Ms. Leonard's thesis regarding capitalism's effect on native peoples as he shows why people everywhere will strive for freedom and prosperity in this video Freedom to Choose.

As the Draft CA Integrated Waste Management Board Conversion Technologies Report to the Legislature, February 2005, Executive Summary says: “Thermochemical Conversion Technologies are technically viable options for the conversion of waste streams, including post-recycled municipal solid waste (MSW). This conclusion is based on the peer-reviewed information from the Evaluation of conversion technology processes and product report prepared by UC Riverside and UC Davis, the Life Cycle and Market Impact Assessment of Non-combustion Waste Conversion Technologies prepared by RTI International, and the independent evaluation of emissions from dozens of facilities worldwide. Thermochemical conversion technologies possess unique characteristics that have potential to substantially reduce the amount of material that is landfilled.” *Similarly, the Conversion Technologies Processing Municipal Solid Waste and Biomass, Final Report June 21, 2009 concludes with “Independently verified emissions test results show that thermochemical conversion technologies are able to meet existing local, state, federal, and international emissions limits. Today, there are advanced air pollution control strategies and equipment that were not available even 10 years ago. It is obvious from the results that emissions control of thermochemical conversion technologies is no longer a technical barrier. That said, it is recommended that facilities and agencies provide both continuous and periodic monitoring to keep the public informed and ensure ongoing compliance. Thermochemical technologies can process a wide variety of feedstocks than biological processes, and can have a greater effect on landfill reduction. Thermochemical technologies can also produce a larger variety of products than incineration, which can displace the need for non-renewable traditional sources of energy and fuel. Other indirect effects include eliminating diesel fuel truck trips and reducing landfill gas emissions.”

According to the UC-R Issues Report on Thermal Conversion Technologies, ...“Currently California is annually landfilling approximately 35 million tons of MSW. When factoring in the substantial decrease in waste generation resulting from the recession, the progress in recycling has been totally offset by population growth and increased per capita disposal.

It is unrealistic to believe that the post-recycled fraction of municipal solid waste that is being placed in California’s landfills can be significantly reduced through source reduction, traditional means of recycling and composting alone.

The state’s population is expected to grow by some 10 million people over the next 25 years. If the legislature fails to achieve final passage of AB 222, California will landfill more than one billion tons of municipal solid waste during that time--and a major opportunity to advance energy independence, reduce AB 32 GHG emissions and advance the production of Low Carbon Fuels will be lost.”

But, perhaps you were merely persuaded by the zero-waste advocates to defeat this effort to handle our existing MSW problem in the state. Personally, I can't tell you how many old toothbrushes I threw-away in my youth because I had no more need for yet another shoe polish welt brush.
But as Mr. Rick Brandes, formally of the US EPA, said at the Cooperation, Not Conflict: Municipal Solid Waste Management in the 21st Century in March-April 2010,

“Having recently retired after 31 years working on waste management regulations and policy at the US Environmental Protection Agency, I’d like to voice a massive frustration on the state of municipal solid waste management policy in this country.
In one camp are the “zero wasters.” They see a world where real integrated materials management means all
materials are contained in a continuous use/reuse cycle: organics to composting and soil enhancement, recyclables returned to use either in closed or open loop recycling systems, metals and glass back to new metals and new glass, and paper back into paper. They see the public as ready for a massive change to a more sustainable lifestyle, trashwise. And, incineration is viewed as the enemy of zero waste, not a complement.

In the other camp are the “energy recoverers.” They see a practical, realistic world, where real integrated materials management is driven by market forces, where recycling occurs when it makes market sense and energy is recovered from the bulk of the remainder of the non-recyclable municipal wastestream through mass-burn incineration or advanced thermochemical conversion. They see it as a decision on whether to landfill or recover energy, not whether to incinerate or recycle. They see the public as most likely to do what they are currently doing—and that doesn’t include a big change in lifestyle, trashwise.
It’s not like there are no alternative strategies. There are many, many ways to beneficially use this trash mountain of ours. Augment soil. Generate power. Make paper and save trees. Reduce bauxite mining. Recover even more metal out of the ash. Make park benches and roads. Produce ethanol and biodiesel. Use all alternatives where they make sense. Use different waste management strategies in different places. Do more of some of these things in some places and less of them in other places. But don’t editorially gun people down when they don’t do what you think they should do. Give communities the best available information, and they will probably do what is best for them. Let them make their trash more valuable.

About the only thing we can say right now is that there exists a massive lack of consensus on what constitutes an effective integrated materials management strategy. That has to change.”

Even former Gov. Schwarzenegger said the following in apparent agreement with Mr. Brandes'
position regarding available means for handling waste
“Environmentalists must stop letting the perfect become the enemy of the possible.”
- Governor Arnold Schwarzenegger

State Sen.Pres. Pro Tem Daniel Steinberg, I know you're a better man than the letters referenced in this blog, would indicate, sir. As California State Sen.Pres. Pro Tem, I believe that your office should have the goals and needs of the entire state in mind when taking action, yet your office could have greatly reduced the opportunity for CTs to be employed at the SVSWA by submitting those letters. May I very respectfully suggest that, if you have not done so already, please retract these letters submitted on your behalf by Kip Lipper, as it would appear to a layperson, that your office is trying to reinterpret the regulations that specifically carve-out MSW gasification as a qualifying renewable energy technology, and such duplicitious at the least, or at it's worst, Machiavellian behavior may lead California citizens/voters to think that you do not support the Global Warming Solutions Act of 2006,(AB 32) .Perhaps you should consider shortening your leash on Mr. Kipper, to avoid further such problems.or it's further implementation for land-use planning, as you have been advocating doing here, here, here.
Quoting portions of the letter from Mr. Roberti, President of the Bioenergy Producers Association, and a former Senate President Pro Tem himself, to you, ”Does it makes sense for this state to continue to place 35 million tons of post-recycled waste in landfills every year, when they could potentially support the in- state production of 1.6 billion gallons of ethanol and 1250 MW of power? Of course not.”
The logic of utilizing our post-recycled waste streams as a feedstock for renewable energy production is so clear and universally recognized, everywhere but in California, that the short-sighted view of a minority of members of our party is already becoming the subject of ridicule.”
When I asked Mr. Mathews of the SVSWA: “Since Salinas Valley have become the CA leader in the move towards better MSW management, might the SVSWA be willing to help create and lead a state-sanctioned group on MSW management, CT legislation, etc., if commissioned by the Governor on a pay-as-you-go basis for meetings/telephone/videos setups, etc.? (In my former life [pre-brain injury] as the Security Director of the major Naval full-spectrum R&D laboratory here in San Diego, I was lucky enough to be invited to join a group of security professionals which reviewed all types and kinds of security issues at our respective research laboratories and engineering centers. We met face-to-face twice a year at a member facility whose director would give the group a tour and a location to sit down to discuss our issues for a couple of days. This went on for several years and I found it very beneficial.) With current video teleconferencing technology, face-to-face meetings could be obsolete, or at least unnecessary. I would hope that sometime in the future, San Diego would be able to benefit from such a regular/periodic meeting of like-minded MSW professionals. Mr. Mathews responded as follows: “We would be interested in forming a working industry group to discuss and advance new waste management technologies. “
Perhaps as possible recompense for seemingly abandoning the state's CT advocates, so to speak, Sen.Steinberg might you consider sponsoring no-cost legislation whereby Governor Brown designates the SVSWA, the County of Los Angeles, or City and County County of Santa Barbara, as the initial head of a working industry group, perhaps titled the “California Conversion Technology Working Group” (CACTWG) and that such working group members pay their own expenses for establishing needed video teleconferencing equipment and such, and that the working group only be required to report to the California Energy Commission (CEC) once or twice a year on its meetings and such. I would suggest that, initially, that these three entities be designated as members, and that other waste management associations of cities/counties be included at the discretion of the Working Group head until formal meeting rules have been established.
Also in talking about the Global Warming Solutions Act of 2006,(AB 32), why are you, Assembly Speaker Perez, and Gov. Brown continuing to push it, and continuing to further the destruction of the California economy. I was intending to highlight how Eric Bays,a University of Oregon student, prepared a document A Logical Argument Against Man-Made Global Warming For the Layman, laying out in his conclusion on page 32 (that even I can understand) that “1) the IPCC is a political body, not an objective scientific body. It's conclusions are untrustworthy. 2) There is still scientific debate about global warming.3) Computer climate models are unreliable. 4) Earth's temperature has been warmer in the past. It is not hotter than normal. 5) Changes in energy from the sun drive climate change on Earth, not carbon dioxide. Therefore, global warming has not been proven.” I was also going to refer you three to The Great Global Warming Swindle. Even Reason Magazine, a nonpartisan research body, produced a report titled Misled on Climate Change-Policy Study 399, the Executive Summary, on the first two pages, details how there is an internal contradiction in the IPCC's own claims. The contradiction is over whether poor countries will suffer greatly from global warming or if they will be much better off than they are today, because apparently both claims are asserted in the IPCC report. But I'm afraid I'm probably too late to make a difference, because if Gov. Brown hasn't taken to heart California Watchdog's numerous articles on global warming such as Study Discredits Global Warming, AB 32 , which details the Climategate fraud. Maviglio Eclipses Global Warming Logic discusses when Democratic strategist Steve Maviglio took to using the Ad Hominem fallacy attack against Dakin Sloss, President of California Common Sense, an open government, nonprofit organization brought into a press conference to defend Assemblyman Anthony Portantino, against charges that the assembly had manipulated budget numbers to make him look bad. Maviglio accused Sloss of, among other things, of being a “climate change denier”. As John Seiler so systematically summarized following his discussion of the latest Climate Warming Refuted and following with Climate Warming Laws: “If we have any sense, we'll repeal all of the legislation that's based on man-caused global warming, beginning with ex-Gov. Arnold Schwarzenegger's AB32, the Global Warming Solutions Act of 2006. That's its actual name, before the “global warming” propaganda was changed to “climate change” It mandates draconian reductions in greenhouse gas of 25 percent by 2020. It's killing 1 million jobs. No wonder California's unemployment rate is 12 percent, almost 3 percentage points higher even than the dismal US rate. And earlier this year, Gov. Jerry Brown made matters even worse, by signing into law a mandate that renewables must comprise 33 percent of electricity production by 2020.” After discussing the text of state Sen. Joe Simitian's bill, SBX12, Mr. Seiler goes on to say ”California probably will be the last place to give up the man-made global warming – excuse me, “climate change” -- superstition. It's especially popular among Simitian's billionaire Silicon Valley constituents, who fund most of the state's politics....”
But recently, Gov. Brown has displayed some of the same Ad Hominem fallacy in discussing the Global Warming. It is apparent by his demeanor that doesn't tolerate dissension when it comes to discussing Global Warning. In fact, his behavior seems to be more like that of a adololecent child at his own Birthday Party, who decides by himself which rules apply to the game being played (and this he thinks it's science). Actually, if Gov. Moonbeam would like to anoint himself as as the titular head of the local “Sacramento-based Junk-Science Club” before abdicating his Royal Governorship, I have no problem with his making-up what passed as his own Science Rules (for those individuals who voluntarily agree to abide by them), but as long as he intends to remain the Governor of California, I take great umbrage at his so cavalierly destroying the opportunity for the roughly 2 million Californians who want to get and hold jobs by continuing to follow this now discredited Global Warning alarmism he so obviously is self-absorbed in. And as Mr. Sieler has eloquently noted in his 16 December 2011 article entitled “Brown Ignores Climategate Revelations”: “California has 2% of the world economy. So, if AB 32 continue to be imposed, with its 20 percent reduction in greenhouse gases in the state by 2020, that means Greenhouse Gases globally will be cut just 0.4 percent.” What also makes AB 32 interesting to me, is that nowhere in the debate regarding November 2010 Proposition 23, was the fact that the world is currently cooling as documented here, here, here and here. Unfortunately, most of what the voters heard leading up to that vote was about how “that two giant Texas oil companies, Valero and Tesoro, are behind the measure and have spent millions of dollars in order to escape accountability and increase profits. Finally, opponents say Proposition 23 prolongs our dependence on foreign oil that comes from countries that support terrorism and are hostile to the US.” But can California alone have a strong influence on national energy policy? Perhaps Moonbeam's continuing to hang this unexorcised poltergeist around the neck of those California citizens who have even casually observed the Climategate scandal in all its misdeeds, secrecy, “hide the decline” perturbations, might take exception to his characterization of the debate as “settled science” but I feel certain that the more than 31,000 scientists (including more than 9,000 with PhD's) who have signed the Global Warming Petition Project, definitely would not agree with the Governor; as these individuals have rejected the Kyoto Accords or any similar agreement ”As proposed limits on greenhouse gases would harm the environment, hinder the advancement of science and technology, and damage their health and welfare of mankind.”Given that AB 32 was roughly based on Kyoto, this enormous number of scientists seems to overwhelm the allegedly 2,500 or so (many of whom don't agree with the results) climatologists, meteorologists,and other scientists who are listed as contributors on the final IPCC reports. In his ad hoc committee report to the Senate Chair of the Committee on Energy and Commerce, Edward J. Wegan, noted that “43 individuals of whom have close ties Ito Dr. Mann” and “one of the interesting questions associated with the 'hockey stick controversy' are the relationships among the authors and consequently how confident one can be in the peer review process” (page 38.)
How ironic that the Gov. is not only willing to subject the citizens of the state to huge increases in fuel prices simply to achieve this relatively small objective (0.4 percent global reduction), but more importantly, that he, and many if not most US environmental organizations, are also willing to subject the citizens of developing countries to a life of no electricity, as these global warming alarmist individuals believe that wind and solar energy are the only forms of energy that underdeveloped countries should use, despite the fact that these intermittent sources of energy cannot fully supply even the needs of a modest grass hut. I really wish that the governor and some of his supporting greenie minions and their financial backers actually had to cook their meals and live in their idyllic grass hut in sub-Saharan Africa, for just seven days, without so much as a light switch, much less a electric or gas stove, not to mention a remote control. Perhaps then they would then understand how primitive the developing world is, and how not having electricity is very restrictive, if not devastating, to those developing-world families. But actually, the 40+ scientists who wrote to the UN saying that “Attempting to Stop Global Warming is Futile and a Mistake” have made extremely valid points. Also, you might want to watch The Real CLIMATE-GATE - THE AGENDA . Professor Bob Carter, Geologist, James Cook University, probably has the most thorough graphical/visual discussion of the entire 400,000 year examination of ice cores as well as seabed cores, on global warming issue in a four-part YouTube segment starting at Climate Change - Is CO2 the cause? , and why the term Holocene Climactic Optimum has disappeared from the vocabulary of Climatologists. In parts 2, 3, and 4 Prof. Carter demonstrates eight significant problems with the IPCC conclusions, which he terms torpedoes, either of which he believes is sufficient to sink the IPCC ship and it's recommendations! I believe that even a superb scientist such as yourself Gov.Brown, can understand why Prof. Carter considers himself an agnostic on the issue of Global Warning. Finally, Burt Rutan, a flight test engineer with decades of data analysis/interpretation/presentation, provides an engineering viewpoint of the anthropogenic global warming debate.
Perhaps the US District Court of Eastern California 28 December 2010 decision to halt implementation of CA's Cap and Trade will ultimately be upheld at the US Supreme Court and end this entire statewide nightmare known as AB 32 and will end the disaster this idiotic law has afflicted our state employment as well as state revenues.

Back to you San Diego Councilman DeMaio, I would not recommend that either you, the mayor or the other City Councilmembers consider selling the landfill as a short-term solution to the city's financial problems (as the city cannot, I believe, totally absolve itself of liability in the event of a major leachate leakage in the future, as Dr. Lee has suggests could happen in many landfills over their lifetime) but I would certainly recommend proceeding with using the SWSWA contract as a template to develop San Diego's own RFQ reflecting a desire to award a public-private partnership contract to handle the entire lifecycle management of MSW from curbside pickup through CT and disposal, but one that clearly spells-out which entity will be responsible for each of those tasks currently funded by the portion of the General Fund ESD monies. I believe that the entire lifecycle management of MSW should be privatized/outsourced, as this is not a core function for the city to perform. Just as my own SSC SD security office introduced commercial barcode scanners into the command's triennial inventory of thousands of items of plant property (eliminating the need for inventory personnel to carry up to 10 pounds of paper documents on a airline luggage cart) and introduced the issuance of badges with barcodes and magnetic stripes, produced by commercially-developed badge printers to more easily gain to the controlled perimeters of the command, automate the recording of mass training in the auditorium, and transfer of accountability for documents, etc.), the city needs the introduction of commercial CTs to take the overwhelming majority out of the total amount of MSW that ends having to be landfilled. No city, state, or federal government, to my knowledge, has the ability to produce or authorize the transfer of such a system, hence the need for the private sector to be involved. The preferred approach, I believe, is for the private sector to be given the right to earn a reasonable financial return on their investment in building the infrastructure needed to achieve MSW conversion while obtaining permitting, etc, for doing so. I also fully support the idea of using the 19 or so remaining acres at MCAS Miramar landfill lease (if it still remains) to devote to an enhanced recycling center, to continue reviewing the possibility of landfill mining of the Miramar North landfill cell (probably as a separate contract/effort), to have the ultimate CT facility be used not only as a educational facility for kindergartners/junior high schools students, but also integrated as part of an overall environmental or waste management program at a local college or university, as well as encouraging the San Diego city government to consider the ultimate CT site to be a minor El NiƱo-year rainy-day backup visitor tourist attraction. If such a CT operation is effected, I also believe that the city can cease its exclusion of selective households for MSW curbside collection, as is currently done, because under a CT public-private partnership contract, the city would also benefit financially, by having all households' MSW picked-up and disposed-of. I would not recommend that the city tell the bidders how to do their job, for example, don't specify which equipment should be used, or that they must use a two-can system [one for recycling, one for trash] as some vendors might choose to perform recycling sorting themselves, saving money with fewer trucks and trips.

Ms. Lamb, since the RMAC meeting minutes have not been available since Meeting number 4, I do not know what has been recommended in Phase II, nor do I know whether the test landfill-mining has started (although I see large piles of earth just west of Route 163 in the area of Kearny Villa Road interchange) which I believe to be the area of Miramar North landfill cell,so please submit this e-mail into the RMAC records as my public nonconcurrentance.

What I am proposing is that in addition to a public-private partnership CT build and operate contract, bundled together with an MSW curbside pickup contract, and including, if possible, the sifted valuable MSW resources from the mined North Miramar landfill cell, and also to include what the Point Loma Wastewater Treatment Facility referred to as rags (sand, grit, gravel, cooking oils, polymers) that is currently extracted from sludge headed toward the Point Loma Sewage outfall, but currently landfilled. As I have shown above, there are more than enough CT suppliers who have already partnered with traditional waste haulers to make such a all-encompassing contract possible. Those CT suppliers who have not yet partnered with a waste hauler can easily do so to bid on this contract.

Also, I've also noticed within the last year, that a contract has been negotiated between Foristar Methane, the city, and the Miramar MCAS, whereby Foristar will supply landfill gas to supply a portion of the base's requirements. But since combustion of waste (WtE) generates up to 10 times more energy than landfill-gas-to-energy (LFGTE) systems do, I believe the city would be advised to do everything possible to legally break the contract with Foristar Methane, as a WtE or gasification plant would likely be much more advantageous in terms of energy output, even if the city must pay Foristar Methane from it's share of the revenue stream from the new contract. I suspect that the LFGTE contract may have broken anyway, just to mine the north landfill cell. For this reason, please ensure that Capt. Keith Hamilton's e-mail address is correct.

I believe that if you follow the SWSWA example on this issue, the contract awardee can easily obtain the proper permits for the site with little difficulty, most likely answering the questions raised by the Sierra Club San Diego chapter letter Miramar Landfill Privatization and KPBS's Sierra Club San Diego Chapter letter, and other critics of outsourcing the landfill .
To answer the concerns of those advocating total elimination of landfills through source reduction, the University of California, Riverside Report on thermal conversion technologies, says that: “It is unrealistic to believe that the post-recycled fraction of municipal solid waste that is being placed in California’s landfills can be significantly reduced through source reduction, traditional means of recycling and composting alone.” In reviewing the composition of the San Diego landfill, I personally doubt that the San Diego MSW situation would not be different enough to dispute this summary statement for the entire state.

Even the US Department of Defense (as energy intensive as the department is) is becoming more knowledgeable and interested in the possibility of renewable energy sources, from waste.

The Governor of Maryland, Martin O'Malley has issued a statement giving his backing to Senate Bill 690, which would give Tier 1 renewable status to waste to energy facilities… Meanwhile, the state of California seems to be falling further behind, by excluding waste-to-energy from its RPS!

Let's not further delay San Diego's opportunity to plan to use this enormous and continually growing resource that is mostly buried! I only hope that by incorporating CT technology into the city's waste disposal lifecycle, in 15 to 20 years, San Diego will be vying for a Waste to Energy Research and Technology (WTERT) Council’s annual award for Sustainable Waste Management, Global Bright Lights.

One might even find that the US Marine Corps is willing to further extend the current lease of the landfill if the city demonstrate it's intent to exercise excellent waste disposal management policies in embracing new technology for future landfill disposal, as well as landfill mining of previous landfill cells, where appropriate (Miramar North).