Comment Log Display

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.”