Submitted Comment Name Jordan Palmeri Affiliation Carbon Leadership Forum - University of Washington Subject Cement Plants: CARB should modify the obligation point in the cap-and-trade program from clinker output to cement output. Message To CARB: One of the most immediately available decarbonization options for cement manufacturers is the use of blended cement to reduce the clinker content in cement products. In fact, the California Nevada Cement Association’s Recent July 2023 report on “Achieving Carbon Neutrality in the California Cement Industry” cites the use of blended cement as a key near-term emissions reduction strategy with the potential to reduce emissions by 10-50%. In order to encourage lower carbon blended cement, CARB should allocate allowances to the cement industry based on cement output rather than clinker and mineral additives produced. This action would accelerate the adoption of this near-term strategy and thus accelerate emissions reduction under the cap and trade program and the cement emissions reduction targets set by SB 596. This is a simple, technical amendment that can provide a clear incentive for manufacturers to shift toward lower-carbon blended cement. Thanks for your consideration, Jordan Palmeri Senior Researcher, Carbon Leadership Forum File Upload (i.e., Attachments): N/A
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