Comment Log Display

The Industry Benchmark for the Gypsum Product Manufacturing
Industry should be Revised from a Weight-Based Metric to a
Production-Based Metric

When cap and trade regulations were established by the California
Air Resources Board (CARB), the Gypsum Product Manufacturing (GPM)
industry agreed to use a benchmark of metric tons CO2e per short
ton of stucco used to produce wallboard. This permitted the CARB
benchmark for gypsum board to be normalized with the EU ETS
benchmark for plasterboard.  

In the interim period since the establishment of the regulations,
GPM industry manufacturers have modified formulations for some
commodity products.  The re-formulation process has resulted in the
production of gypsum board materials that are characterized by a
lighter average product weight than those produced a few years
earlier.  This trend in weight reduction is on-going and points
toward a composite gypsum board product weight metric that will
continue to decline on an annual basis for the foreseeable future.

The Gypsum Association believes the downward trend in product
weight has created a scenario that will not allow the industry to
take advantage of improvements in energy utilization. While
formulation changes have permitted the GPM industry some reductions
in energy consumption, the rate of energy consumption decrease has
not kept pace with, and likely will not keep pace with, the rate of
decrease in product weight.  

The denominator in the product-based metric for gypsum board is
weight-based.  Conceptually, if product weight is continually
decreased and energy usage does not decrease at a proportionate
rate, members of the GPM industry may not be able to meet target
CO2e allocations regardless of energy usage. 

California is currently revising cap and trade regulations to
harmonize its system with the cap and trade system that is being
assembled by the Province of Quebec. Quebec has adopted a
production-based metric for the GPM industry. In keeping with the
goal to harmonize these two cap and trade systems, CARB should
adopt industry benchmarks that are comparable wherever possible. 

We propose that CARB work with the GPM industry through the Gypsum
Association to solicit and establish a new production-based
emissions benchmark for gypsum board production. The units of this
benchmark should not be in terms of metric tons of stucco, but
should reflect a 
production-based metric, such as CO2e produced per a normalized
unit or volume of board footage.    The GPM industry is conducting
an internal data review and intends to have a proposed metric
available for presentation to CARB for review and discussion in the
very near future.  As with the Industry Assistance Factor, the
Gypsum Association would appreciate being included in the
stakeholder process to evaluate industry benchmarks in 2012. 

(.pdf copy of statement attached)