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Comment 10 for Public Workshop on CA Plan for Compliance with the Clean Power Plan and Potential 2016 Amendments to the Cap-and-Trade Program (capandtradecpplan-ws) - 1st Workshop.
First Name: Matt
Last Name: Carr
Email Address: mcarr@algaebiomass.org
Affiliation: Algae Biomass Organization
Subject: Role of Algae Carbon Capture and Utilization in Meeting Clean Power Plan Targets
Comment:
Dear Air Resources Board, On behalf of the Algae Biomass Organization (ABO), I hereby submit comments on California’s plan for compliance with the U.S. Environmental Protection Agency’s Clean Power Plan, and the scope and regulatory schedule for potential amendments to the Cap-and-Trade Regulation (Regulation or Program) relating to electricity sector emissions. ABO is the trade association for the algae industry, representing the leading developers of renewable, sustainable products from algae. Our membership includes pioneering algae technology companies, research institutions, leading academics, utilities, airlines and other end users, and a range of other industry partners throughout the algae supply chain. Carbon capture and utilization (CCU) technologies, such as algae cultivation, can transform carbon dioxide emissions into valuable products, simultaneously reducing harmful greenhouse gases and providing economic benefits. Algae companies across the country are working to commercialize new technology advances that convert concentrated sources of CO2 to renewable fuels, chemicals, fertilizer, plastics and feed ingredients, as well as high-value products such as Omega-3 nutritional supplements, powerful antioxidants, pharmaceuticals and cosmetics. EPA in its final Clean Power Plan regulation recognized the value that carbon utilization technologies can provide states in reducing and meeting their CO2 emissions goals, by noting that: "state plans may allow affected EGUs to use qualifying CCU technologies to reduce CO2 emissions that are subject to an emission standard, or those that are counted when demonstrating achievement of the CO2 emission performance rates or a state rate-based or mass-based CO2 emission.” A newly published analysis (http://www.cbmjournal.com/content/10/1/26/abstract) finds that algae carbon capture and use can make a major contribution to achieving climate objectives, especially if directed to animal feed markets. Carbon capture and utilization is adequately demonstrated and technically feasible. It can be implemented at reasonable cost, provide meaningful emission reductions, and its inclusion in state plans will serve to promote further deployment of this technology. Additionally, by creating a market for captured carbon, carbon utilization can mitigate or offset the cost of carbon capture, providing a CO2 reduction mechanism that minimized the cost to ratepayers. As such, we urge CARB to include carbon capture and utilization in its portfolio mix of technologies that may be used by EGU’s to meet the state’s CO2 emissions reduction targets. Additional information on algae-based CCU technologies is attached by way of background. ABO looks forward to working with CARB to find ways to ensure algae and other CCU technologies play their part in helping the state meet and exceed its emissions objectives under the Clean Power Plan and other state-based programs. Sincerely, Matt Carr Executive Director Algae Biomass Organization
Attachment: www.arb.ca.gov/lists/com-attach/11-capandtradecpplan-ws-UDEAZFQ6UV1XMgdm.zip
Original File Name: ABO CARB CPP Comments Attachments.zip
Date and Time Comment Was Submitted: 2016-01-11 15:02:25
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