Submitted Comment Name scott shell Affiliation ClimateWorks Foundation Subject Cement in Cap-and-Trade: modify obligation from clinker to cement Message CARB should modify the obligation point for cement in cap-and-trade program from clinker output to cement output. California’s cement plants are regulated under the state’s cap-and-trade program, which requires state emissions to drop 40% below 1990 levels by 2030. The industrial sector includes many energy intensive, trade exposed industries (EITEs, including cement), which receive free allowances to cover the majority of their GHG emissions based on clinker output and efficiency. Since 2021, California’s cement industry is also bound to meet climate targets set by SB 596 which requires all cement used in the state to be net zero by 2045. One of the most immediately available decarbonization options for cement manufacturers is the use of blended cements to reduce the clinker content in cement products. Alternative lower-carbon materials like slag, pozzolans, and clays are mixed in with clinker to make cement with a lower clinker content. However, cap-and-trade allocates allowances to the cement industry based on clinker and mineral additives produced. CARB should instead allocate allowances under cap-and-trade based on cement output, to further encourage the use of blended cements, as such blends would serve to reduce the compliance obligation on covered cement plants. This is a simple, technical amendment that can provide a clear incentive for manufacturers to accelerate a switch toward lower carbon blended cements. Type 1L cements have successfully initiated this transition to blended cements, and are now being produced in 53% of U.S. cement plants. Thank you for your consideration. File Upload (i.e., Attachments): N/A
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