California Carbon Capture and Storage Review Panel
[From Executive Summary] Recognizing the importance of CCS for California’s industrial and electricity sectors, the California Public Utilities Commission (CPUC), California Energy Commission (Energy Commission), and the Air Resources Board (ARB) created a CCS Review Panel in February 2010….
The Panel identified a number of key legal and regulatory issues that require greater clarity and possible legislative action before CCS can be broadly deployed as a GHG mitigation measure under state laws and policies to reduce CO2 emissions. Key questions include:
- Will CCS be eligible to meet the requirements of AB 32 or other relevant California laws and policies?
- Is there a clear regulatory framework and related permitting pathway for CCS projects in California?
- Are there clear agency rules that would allow for early CCS demonstration projects in the State?
- What additional considerations must be addressed and resolved to allow for the deployment of CCS?
The Panel deliberated on the issues enumerated above and put forth the following key findings and recommendations for consideration by the three principal agencies and the legislature. The body of this report provides more extensive background discussions of these key findings and recommendations, which were adopted at the Panel’s final public meeting on December 15, 2010…
- There is a public benefit from long-term geologic storage of CO2 as a strategy for reducing GHG emissions to the atmosphere as required by California laws and policies.
- Technology currently exists for the safe and effective capture, transport, and geological storage of CO2 from power plants and other large industrial facilities.
- High costs, inadequate economic drivers, remaining uncertainties in the regulatory and legal frameworks for CO2 storage, and uncertainties regarding public acceptance are barriers to the near-term deployment of commercial-scale CCS projects in California.
- There is a need for clear rules under AB 32 regarding the treatment of CO2 emission reductions from CCS projects involving capped and uncapped emission sources.
- Multiple state and federal agencies are currently responsible for permitting CCS projects in California.
- There is a need for clear, efficient, and consistent regulatory requirements and authority for permitting all phases of CCS projects in California, including CO2 capture, transport, and storage.
- Standards are needed to ensure the safe and effective operation of geologic storage projects.
- Consistent requirements are needed for monitoring, measuring, verifying, and reporting injected CO2, and releases, if any, and for GHG accounting protocols necessary to comply with federal and state laws and policies to reduce CO2 emissions.
- There is a need to establish clear financial responsibility for the stewardship of geologic storage sites during the (a) operating phase; (b) post-injection (pre-closure) monitoring phase; and (c) post-closure phase.
- The right to use subsurface pore space for geologic storage needs to be clarified.
- There is a need to address any potential environmental justice aspects of CCS projects.
- There is a need for increased public understanding of CCS benefits and risks.
- Absent new initiatives, economic barriers to early CCS deployment will delay the technological learning needed to drive down the costs of CCS.
[H/T Green Car Congress]