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Comment 4 for Public Input on Cap-and-Trade Auction Proceeds (investmentplan-ws) - 1st Workshop.


First Name: Dominic
Last Name: Meo III
Email Address: dommeo@verizon.net
Affiliation: Meo & Associates

Subject: Reducing GHG Emissions and Combating Leakage
Comment:
During the public workshop, several ARB Board Members expressed the
importance of using C&T auction proceeds to find novel ways to
reduce GHG emissions while combating leakage.  I would like to
suggest that we have a simple, yet very effective way to do this. 


Cement producers should receive a carbon credit for partnering with
concrete batch plants to produce "low-carbon" concrete formulations
which use supplementary cementitious materials (SCMs) to reduce the
amount of cement used in concrete.  The less cement used in a
concrete formulation, the lower the GHG emissions in California,
which is a main goal of AB 32.

The use of SCMs in not new.  For years, Caltrans has used SCMs such
as fly ash to improve the properties of the concrete used to make
our freeways.

Right now, C&T regulations restrict carbon credits available to
cement producers to GHG reductions made in the process used to make
cement.  CARB should recognize the linkage between cement, which is
made solely to make concrete, and the overall GHG emissions
associated with making concrete.

By allowing cement producers to obtain carbon credits for promoting
low-carbon concrete formulations, they would be less keen on
importing cement to show GHG reductions at the cement kiln, a clear
indication of leakage.

Making low-carbon concrete is a bit more expensive than producing
conventional concrete.  Proceeds from C&T auctions should be used
to provide a subsidy to cover this increased cost, thereby
promoting the use of low-carbon concrete, which will result in an
overall reduction in GHG emissions in our state without creating
leakage.  Please review the attached PowerPoint for additional
information.

Please let me know if you would like any additional information.

Attachment: www.arb.ca.gov/lists/investmentplan-ws/4-low-carbon_concrete_progress_report_06-24-11__rev._2_06-30-11_.ppt

Original File Name: Low-Carbon Concrete Progress Report 06-24-11 (Rev. 2 06-30-11).ppt

Date and Time Comment Was Submitted: 2012-05-29 08:57:09



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