Comment Log Display

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.”