First Name | Thomas |
---|---|
Last Name | Carter |
Email Address | tcarter@calera.com |
Affiliation | Calera Corporation |
Subject | Calera Comments on Proposed Amendements |
Comment | Calera Corporation welcomes the opportunity to comment on the California Air Resources Board’s (ARB) proposed revisions to California’s mandatory greenhouse gas (GHG) emission reporting rule. 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. Calera therefore urges the ARB to revise the mandatory reporting rule so that major emission sources in the State of California are required to report only GHG emissions that leave their plant premises. Greenhouse gases emitted directly to the atmosphere from the facility or transported out in carbon dioxide or other GHG forms should be reported as emissions. While carbon dioxide that is captured on-site before it exits the stack and subsequently converted non-GHG chemical forms—such as carbonate—should not be part of the source's emission profile. The source would therefore not require matching these would-be emissions with allowances or offsets. The rule should treat on-site carbon conversion equipment as back-end equipment. Any energy demand from the carbon conversion equipment should be treated as part of the power plant’s net emission profile. 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 reporting rule encourage innovations that convert greenhouse gases to stable non-GHG forms. Specifically, Calera suggests the following language changes to the Proposed Amendments to the Regulation for the Mandatory Reporting of Greenhouse Gas Emissions: § 95101 (f) Exclusions – add subsection (6) “Carbon dioxide or other greenhouse gases that are capture onsite at covered units and chemically converted to stable non-GHG forms, such as carbonates.” § 95102 (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.” § 95102 (a) (156) – 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.” |
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Date and Time Comment Was Submitted | 2010-12-15 11:48:26 |
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