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Comment 166 for California Cap-and-Trade Program (capandtrade10) - 45 Day.

First NameDavid
Last NameRubenstein
Email Addressdrubenstein@CaliforniaEthanolPower.com
Affiliation
SubjectAgricultural Carbon Capture and Credit for the Process
Comment
California Ethanol + Power (CE+P) is in the process of developing a
sugarcane and sweet sorghum to energy project in the Imperial
Valley.  

CE+P intends to plant 40,000 acres of sugarcane that will support
the facility.  The cane will absorb massive quatities of carbon,
much of it being stored in the roots of the cane.  After 5 years of
production, the cane that is in the ground will be turned and left
in the ground.  During that 5 year period a large amount of carbon
would have been captured and stored.

CE+P believes that some sort of carbon capture should be calculated
and credited and that the benefit of that should fall into the Cap
& Trade analysis.  In the end, growers of the cane can apply those
credits as a way to off-set the cost of planting, growing and
harvesting the carbon absorbing crop.  It would be the same type of
plan we see today, when trees are planted and credit is given or
when forests are protected from being chopped down and credit is
given.

Thank you.

Attachment
Original File Name
Date and Time Comment Was Submitted 2010-12-07 07:01:19

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