Page 44 - 2021 Sustainability Report

ENVIRONMENTAL STEWARDSHIP

Understanding the Impact of Blending and Fuel Choice

While we are proud of these achievements — and, in fact,
as discussed below with respect to our 2030 Scope 1 GHG “Thisalsoplacesuswellbelow the
reduction goals, we have committed to further reduce the U.S. cement industry average
carbon intensity of our cement and magnesia businesses intensity of 0.80 metric tonnes of
— we also believe it is important to recognize both critical
regulatory differences between the U.S. and the EU (and CO e/metric tonnes of domestic
2
other international jurisdictions) and differing calculation cement in 2020 (the most recent
methodologies that result in meaningful differences in the year for which data is available from
makeup of corresponding end-products and reported
emissions metrics. Those differences, in turn, make like-for- the USEPA) and makes us one of the
like comparisons of the emissions performance of such more carbon efficient cement
companies challenging.
producers in the United States.”

Clinker Substitution and Blending

For example, outside of the U.S., the allowable rate of Alternate Fuel Use
“clinker substitution” — the replacement of ground clinker
in cement with alternate materials such as pozzolan, slag Similarly, not only is clinker substitution different around
and fly ash — is much higher than it is in the U.S. because the world, but the reported numbers are being generated
of the limitations imposed by the American Society for using different calculation methods. Our reported intensity
Testing and Materials, Inc. (ASTM) and Department of is based upon the USEPA Clean Air Act Part 98 and the
Transportation (DOT) standards for cement. While our data generated by our Continuous Emission Monitors
clinker substitution rate (like other U.S. producers) (CEMs) and reflects actual measured CO 2 e. If instead of
generally does not exceed 10 percent, the average clinker this method, we were simply to switch to the World
substitution rate for international cement companies is in Business Council For Sustainable Development (WBCSD)
the range of 28 percent to 50 percent, depending on the calculation method, and make no change to our actual
type of cement. Accordingly, even where their clinker clinker factor, our intensity would drop from 0.77 to 0.63
1
intensity (the amount of CO generated in producing a (taking full credit for the biogenic component of our GHG).
2
tonne of clinker) is comparable to our 2021 rate of 0.85
In addition, alternative fuel use by the cement industry
net metric tonnes of CO /metric tonnes of clinker (and in in the United States averages only 15 percent of the fuel mix,
2
many cases is actually higher), international cement
compared to 36 percent of the fuel mix used in the European
companies can reduce the carbon intensity they publicly
Union and as high as 60 percent in Germany. In large part,
2
report by simply substituting higher percentages of non-
this is because combustion of secondary alternate fuels is
clinker products for clinker in their end product, rather
incentivized in the European Union, whereas in the U.S.
than actually reducing total emissions or improving
environmental laws and USEPA regulations create hurdles to
efficiencies in the manufacturing process.
using these materials as fuel sources. Moreover, the
calculation of reportable CO 2 emissions under international
In fact, if we were to use a hypothetical 75% clinker
regulations differs materially from the calculation allowed
factor for our cements, we estimate our intensity
would be reduced from 0.77 to approximately 0.64 under USEPA regulation. The European Union Gross CO 2
Emission rates exclude CO 2 emissions from biogenic fuels
net metric tonnes of Absolute Gross CO /metric
2
tonnes of cement equivalent. while the widely reported Net CO 2 emission rates using the
WBCSD method as noted above do not include the biogenic
or alternative fuel CO 2 contributions. Again, if we used a
hypothetical 75% clinker factor and calculated our
emissions using the Global Cement and Concrete
Association (GCCA)/European calculation method and
our current fuel mix, we estimate that our intensity
would see a further reduction to approximately 0.53
net metric tonnes of CO 2 /metric tonnes of cement
equivalent basis.
1 European cement standard EN 197-1 “Cement – Part 1: composition, specifications and conformity criteria for common cements”, as reported by CEMBUREAU.
2 PCA Response to House Select Committee on Climate Crisis dated 11/22/2019, pg. 5.

42 2021 SUSTAINABILITY REPORT