{"id":18579,"date":"2024-02-26T15:38:37","date_gmt":"2024-02-26T15:38:37","guid":{"rendered":"https:\/\/ilsr.org\/?post_type=article&p=18579"},"modified":"2025-11-10T09:47:03","modified_gmt":"2025-11-10T14:47:03","slug":"public-comments-on-epas-warm","status":"publish","type":"article","link":"https:\/\/ilsr.org\/es\/article\/composting-for-community\/public-comments-on-epas-warm","title":{"rendered":"Comentarios p\u00fablicos sobre el Modelo de Reducci\u00f3n de Residuos (WARM) de la EPA"},"template":"","class_list":["post-18579","article","type-article","status-publish","has-post-thumbnail","hentry","article_type-article","initiatives-composting-for-community","topics-climate-change","topics-zero-waste","impact_areas-climate-and-environmental-justice","authors-julia-spector"],"acf":{"details":{"featured_image":18580,"background_color":"tan","article_type":[134],"initiative":15,"display_event_fields":false,"start_date":null,"end_date":null,"start_time":null,"end_time":null,"time_zone":"America\/New_York","virtual_event":false,"location":"","topics":[62,121],"impact_areas":[16],"abstract":"Help us improve E.P.A's measurements to compare the climate impacts of materials management practices. They are accepting public comments on the Waste Reduction Model (WARM), a tool that influences policy, regulation, funding, and more. See here for ILSR's recommendations and guidance to submit your comment before March 15, 2024.…","authors_tax":[624]},"sidebar":{"title":"\u00cdndice"},"page_layout":[{"acf_fc_layout":"layout_wysiwyg","_acfe_flexible_toggle":"","component_wysiwyg":{"content":"

Echa un vistazo a la cobertura de nuestros comentarios p\u00fablicos sobre WARM en WasteDive.<\/a><\/h3>\r\n\r\n
\r\n\r\n ","":null,"settings":""}},{"acf_fc_layout":"layout_wysiwyg","_acfe_flexible_toggle":"","component_wysiwyg":{"content":"The E.P.A. is accepting public comments<\/a><\/strong> until March 15, 2024, on the <\/span>Waste Reduction Model (WARM) version 16<\/a><\/strong> and its <\/span>supporting documentation<\/strong><\/span><\/a>. In an effort to \u201cimprove the usability, integrity, and functionality of WARM,\u201d the EPA intends to use these comments along with findings from an external <\/span>peer review and data quality assessment<\/a><\/strong> to update the current model.\u00a0<\/span>\r\n\r\nWARM<\/a><\/strong> is a measurement tool to estimate and compare potential greenhouse gas (GHG) emissions, energy savings, and economic impacts of various materials management practices, including source reduction, recycling, composting, anaerobic digestion, combustion (incineration), and landfilling. Emissions, energy units, and economic factors are measured across materials commonly found in municipal solid waste and construction and demolition debris.\u00a0<\/span>\r\n\r\nThe methodology and assumptions used for WARM\u2019s estimations have significant implications \u2013 the tool is used to weigh and compare the benefits and drawbacks of materials management practices relative to each other. These estimates are used in consequential decision-making for policy, regulation, funding, and more, and inaccuracies in measurement assumptions elicit biased results.\u00a0\u00a0<\/span>\r\n\r\nIn response to the EPA\u2019s request and to strengthen the measurement model and reduce current biases, the Institute for Local Self-Reliance submitted the comments below. The U.S. Composting Council also developed recommendations<\/a><\/strong> to include in public comments. <\/span>\r\n\r\nWe urge you to also submit public comments, and we welcome the use of our comments to inform or guide responses or to be copied and pasted directly into your submission.<\/strong><\/span>\r\n\r\nPublic comments can be submitted through March 15, 2024, through <\/b>docket number EPA-HQ-OLEM-2023-0451 in Regulations.gov<\/b><\/a>.<\/b>\r\n

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Comments on the E.P.A. Waste Reduction Model version 16 (WARM 16) Docket No. EPA-HQ-OLEM-2023-0451<\/b><\/h4>\r\nSubmitted by the Institute for Local Self-Reliance<\/span><\/i>\r\n\r\nDear Administrator Regan, <\/span>\r\n\r\nThank you for the opportunity to submit comments on EPA\u2019s Waste Reduction Model version 16 (WARM 16). The Institute for Local Self-Reliance (ILSR) is a national nonprofit research and educational organization that advocates for thriving, diverse, and equitable communities. We respectfully request your consideration of our comments and recommendations outlined in this letter, which have been informed by nearly 50 years of experience providing assistance to communities to reduce and recycle wasted materials.\u00a0<\/span>\r\n\r\nILSR commends the EPA for its continuous efforts to improve and update the measurement tool and for seeking input through public comments. However, WARM 16 continues to have several flaws that hinder progress in mitigating and adapting to climate change. The current form falls short of its goal to allow for an adequate comparison among available solid waste management options. In response, ILSR offers the following recommendations to rectify several shortcomings in the tool that bias results and impede future efforts. <\/span>\r\n
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  1. Include decentralized composting systems in emissions factors\u00a0<\/span><\/li>\r\n \t
  2. Consider increased soil water retention in composting emissions factors<\/span><\/li>\r\n \t
  3. Update research on compost\u2019s ability to displace synthetic fertilizers, fungicides, and pesticides\u00a0<\/span><\/li>\r\n \t
  4. Factor bCO<\/span>2\u00a0 <\/span>emissions (carbon dioxide emissions from biogenic materials) into emissions calculations<\/span><\/li>\r\n \t
  5. Update methane\u2019s Global Warming Potential (GWP) to 80.8 \u2013 82.5 over 20 years and an atmospheric life of 11.8 years to reflect IPCC\u2019s 2021 Assessment Report (AR 6)<\/span><\/li>\r\n \t
  6. Reconsider utility CO<\/span>2\u00a0 <\/span>emissions in combustion net emissions calculations<\/span><\/li>\r\n \t
  7. Report methane emissions separately from other GHGs<\/span><\/li>\r\n<\/ol>\r\nFurthermore, we urge EPA to strongly consider the copious additional benefits of composting not represented through emissions calculations when comparing solid waste management options. Excluding benefits such as improved climate resiliency and living natural systems creates an unfair disadvantage for closed-loop, nature-based solutions like composting. We thank you for your consideration of our recommendations. <\/span>\r\n\r\n \r\n\r\nRecommendations for Waste Reduction Model (WARM)<\/b><\/em>\r\n

    1) Include decentralized composting systems in emissions factors<\/b><\/h4>\r\nWARM 16 models composting only in central composting facilities with windrow piles, citing a lack of data for small-scale composting and other large-scale operations as the reason.\u00a0<\/span>However, decentralized, distributed composting is a <\/span>quickly growing<\/a><\/strong> part of <\/span>the sector<\/a><\/strong>, warranting its inclusion in WARM to represent the field accurately. 90% of composting programs in <\/span>our 2022 census<\/a><\/strong> launched since 2010, with over half launching since 2016. Of <\/span>2,987 composting facilities with scale data<\/a><\/strong>\u00a0in a 2017 study, 79% were small-scale composters (composting less than 5,000 tons of feedstock per year). With this increase in decentralized activity, access to data should not be a barrier.<\/span>\r\n\r\nDecentralized solutions, such as composting at home, community gardens, urban and local farms, schools, and local government sites, are managed by local, distributed networks of independent businesses, worker cooperatives, nonprofit organizations, and local governments. Community-based composting operations often make and use compost within the same community where wasted food and other materials are generated. Keeping the processes and products as local as possible keeps benefits and profits local and within the community. Decentralized composting offers abundant co-benefits that protect the climate, build healthy soils, stimulate economic growth, enhance food security, and build more prosperous, equitable, and resilient communities. Omitting decentralized composting operations from WARM 16 has created emissions factor modeling inaccuracies. <\/span>\r\n