Comment Log Display

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