First Name | Thomas |
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Last Name | Carter |
Email Address | tcarter@calera.com |
Affiliation | Calera Corporation |
Subject | Calera Comments on Proposed Rule |
Comment | Calera Corporation welcomes the opportunity to comment on the California Air Resources Board (ARB) proposal on California’s market-based greenhouse gas (GHG) reduction program. Calera is an innovative carbon capture firm based in Los Gatos, California. At our demonstration plant in Moss Landing, California, we capture carbon dioxide emissions from the flue gas of an operating power plant and convert the carbon dioxide (CO2) to carbonate (CO3) forms. We are developing processes for cost-effectively producing both mineral carbonates for building materials—such as cement—and bicarbonates for products and/or geologic reinjection. In either case, this conversion to solid or liquid carbonate forms would be stable and not revert to carbon dioxide under anything short of apocalyptic temperature and acidity conditions. The Governor, the California legislature, and the ARB are to be commended for taking a leadership role in the important mission of reducing GHGs and lessening man’s adverse impact on global climate systems. This program promises to be a model for compliance mechanisms in other states and in the federal governments of the United States and abroad. For that reason, Calera would like to suggest a few changes that will make the regulation even more forward thinking and supportive of innovation, particularly innovative technologies born in the State. The most effective way of maintaining stable levels of atmospheric GHG concentrations is to prevent emissions from entering the atmosphere. This can be done in one of two ways: by using less energy and energy-intensive products, or by producing energy and goods in ways that result in lower emissions. Calera’s process would enable the use of domestic fossil fuel resources to create energy without the conventionally attendant GHG emissions. Unlike traditional carbon capture and storage (CCS), carbon conversion does not simply store captured CO2 and transport it to a storage facility. It is instead a means of avoiding CO2 emissions by converting the gas to a carbonate solid or liquid state, which is no longer a greenhouse gas and will not revert to one. Obviously, emission reductions anywhere on the earth have the same impact in terms of atmospheric concentrations of GHGs. For this reason, Calera urges the ARB to revise the proposed cap-and-trade rule to encourage out-of-state sources to reduce emissions through any means, including conversion of greenhouse gases to non-GHG forms. This can be done through enabling such sources to sell offset to covered sources within the State. Calera suggests, therefore, that sources outside the State of California that capture and convert their carbon dioxide gas to non-GHG forms can sell offsets for emission reductions to California sources under the cap. This will provide an incentive for California sources to encourage out-of-state emissions that might be more cost effective but have the same benefits on atmospheric concentrations as in-state reductions. Calera would like to meet with ARB staff early in 2011 to discuss our processes and changes in the rule in more detail, but it important that the cap-and-trade rule encourage innovations that convert greenhouse gases to stable non-GHG forms. Specifically, Calera suggests the following language changes to the Proposed California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation, Including Compliance Offset Protocols: § 95802 (a) Definitions – add a subsection for the following definition: “ ‘Carbon conversion’ means the generally permanent conversion of carbon dioxide to non-GHG forms, such as carbonate, calcium carbonate, magnesium carbonate, bicarbonate, and other stable chemicals that are not greenhouse gases and will not readily revert to GHG forms.” § 95802 (a) (85) – add the following language to the end of the current definition for “greenhouse gas emission reduction”: “…and shall include chemical conversion of greenhouse gases to stable non-GHG forms.” § 95971 – add the following language to the end of the current provision on Procedures for Approval of Compliance Offset Protocols: “…and protocols related to standards from other jurisdictions, such as the Voluntary Carbon Standards or the American Carbon Registry.” |
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Original File Name | |
Date and Time Comment Was Submitted | 2010-12-15 11:44:59 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.